From Hive to Honeypot (Part 5): Heating, HMF and Labelling

From Bee Craft: July 2009

Andy Pedley

We conclude our look at the regulations associated with producing honey


Honey properly prepared and labelled for sale


Heating leads to the production of HMF (hydroxymethylfurfural) and a reduction in diastase activity, for which there are legal controls. It is best to avoid heating the honey at all but if this is needed then use as little heat as necessary and control it carefully. Use just enough heat for just long enough to liquefy the honey.


HMF levels can be measured with laboratory testing but this is expensive. See also a method using hydrogen peroxide testing strips {BBKA News, 162 m December 2006). Due diligence is to treat the honey in such a way that the conditions leading to excessive levels of HMF do not arise.

How would you know if the way the honey had been handled could have led to an excess of HMF?

The answer is that you have kept control of the honey so you know how it has been stored and handled. Research will give you information about the time and temperature needed to give high levels of HMF (eg, http://snipurl.c0m/3pggc) so your due diligence is to keep well on the safe side of that.


It would be appropriate to give a separate lot number to each batch that has been heated and keep a record of the length of time that the heating was carried out and, for instance, the highest temperature reached. This means that if a batch is found to be unsatisfactory, it can be recalled and other batches that were given similar treatment can also be tested and/or recalled. Your HACCP assessment would be amended in the light of the experience.


Testing may be appropriate. Refractometers are now inexpensive, readily available and will give quick and accurate readings of the moisture content in honey. There are legal requirements about moisture levels and the test is quick, simple and reliable.

Note the readings that you have taken for each batch of honey against the lot number or some other identifier. It may be appropriate to test each bucket of honey. Any that has a higher than 23% water content must be sold as baker’s honey and labelled appropriately.

You should calibrate the refractometer before use and keep a record.

This is the only test that small-scale beekeepers can reasonably undertake. Larger operations, importers, etc, may want to put testing regimes in place under their HACCP procedures.


The Honey (England) Regulations 2003 define honey and place strict and complicated requirements on its composition. It is these Regulations that impose the control on moisture content. It is here that the ‘country of origin’ labelling is required. There is guidance from the Food Standards Agency at, a pdf file at and the British Beekeepers’ Association (BBKA) has guidance at


Statute requires specific labelling. There are good summaries of labelling and other Trading Standards requirements at and the BBKA leaflet ‘Selling Honey’, ( but we need to consider what other labelling is appropriate.

In addition to the statutory requirements – weight, type of honey, country of production and producer’s contact information, how about:

  • some hints about storage
  • that the honey is not finely filtered so will contain pollen and may look cloudy – that this is natural and expected it has not been heat treated so is likely to granulate

The advantages of putting this type of information on labels is that it helps the customer keep the honey in prime condition.

Since 1996, the British Honey Importers and Packers Association (BHIPA) has a voluntary labelling code whereby all honey on retail sale includes a warning that ‘honey should not be given to infants under 12 months of age’ (see the Food Standards Agency document at You could consider doing this even though it is not a legal requirement.

Printing labels is easy using computer technology. I am often asked for ‘local’ honey – so labelling the jar to say where the honey came from and that it is not processed to ‘factory’ standards may be a good marketing ploy.


Products which contain an ingredient which could trigger an allergic reaction must be labelled if they contain specific allergens.

There are 12 named allergens, ie, cereals containing gluten, eggs, fish, crustaceans, molluscs, any kind of nut (including almonds, hazelnuts, walnuts, cashew nuts, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts and Queensland nuts), peanuts, soybeans, milk, celery, mustard, sesame seeds, lupin and sulphur dioxide and sulphites at levels above 10 mg/kg, or 10 mg/litre, expressed as sulphur dioxide.

If an ingredient is made from one or itself contains one of these compounds, it must be labelled. Those who are allergic to these foods can have a severe reaction from even a tiny amount, so it is important that they are warned.


This requirement is not likely to apply to pure honey in the jar but if you were making a product that included honey – honey and almond biscuits, for instance – then they would have to be labelled ‘contains nuts’.

If there is a possibility that the food could contain one of the allergens, even trace amounts that could trigger a reaction, then the phrase ‘may contain’ can be used. -This could be particularly important if you process your honey in a domestic kitchen where there is a risk of cross-contamination. It is not a legal requirement but is good practice. ‘May contain’ should not be used indiscriminately. There is a balance to be struck, of course. Those with allergies need to be warned if there is a danger to them, but not unnecessarily.

There is good advice and further reading at


You must indicate the ‘durability’ of the food. For honey this is likely to be a ‘best before’ date.

The term ‘best before’ should be followed by:

1 the date up to which the honey can be stored

2 storage instructions necessary to achieve this.

‘Best before’ dates need to be day, month and year, in that order.

Other formats may be used depending on the ‘shelf-life’ (see table below). There is a good summary at


Many beekeepers use their honey as an ingredient and then go on to sell honey products such as honey cakes and honey marmalade. Give these a lot number so that you can identify specific batches.

You need to do separate HACCP assessments for each product and keep appropriate records for each lot comprising the ingredients, their source, batch number, best before date and copies of the receipts.

Use sell by, best before and use by dates as above. ‘

Obviously choose appropriate time periods during which you can be confident the product will be in good condition. For example, a honey loaf may go mouldy within a week but honey mustard will keep longer. You can pay a public analyst to undertake shelf-life testing. Although this will be expensive and is not likely to be economic for small-scale producers, you can benchmark against similar products.

If the product deteriorates before the date you select, the consumer has grounds for complaint, so use realistic timescales. Your label needs to specify storage instructions required to achieve this timescale (‘keep refrigerated’, etc).


Anti-tamper seals of some kind are essential. They reassure the consumer and protect against interference with the honey. They also protect you from malicious adulteration and fraudulent allegations.


It is worth reviewing how things go. Did you have all the equipment you needed? Did it all work OK? Does anything need replacing? Is

there anything you could do better, for next year?

Keep a record and make a shopping list of equipment you need to buy.

You should review your HACCP assessment from time to time and keep it up to date to ensure it is still relevant to your process. Has anything that you do changed, so as to introduce new hazards that need to be incorporated? Has food law, or science identified a new hazard? Certainly any new medications or treatments need to be incorporated.


This all probably looks and sounds frighteningly complex. To put it in perspective though, compare it with the legislation concerning driving. There are parallels. The legislation is there to protect the public. It is very complex and not always clearly defined, and there are penalties that can be imposed if you go too fast, etc. Few of us have a one-hundred per cent understanding of driving law but many of us drive.

Similarly, the food safety legislation is there to ensure our food is safe and wholesome, to protect us from harm. To a large extent, this is about doing things carefully, being responsible and complying with the manufacturer’s instructions, following ‘Good Agricultural Practices’ (; in other words, traditional beekeeping in accordance with normal practices and processes that you can demonstrate by reference to experts or published material.

If you stray from normal practice, it will be hard to demonstrate that you have exercised due diligence. ‘It seemed like a good idea at the time’ or ‘I thought it would be OK’ simply will not do. If you based your actions on experience, research, wise advice from suitably qualified experts or something you read in a reputable journal, you can refer to that but don’t ‘try things out’ unless you have regard to any implications for your honey crop and are in a position to carry out tests to ensure it is safe.

Much of this is common sense and ought to be normal practice – primary responsibility for food safety rests with the food business operator (EU Regulation 852/204). It is always the producer’s responsibility to ensure the product is safe and wholesome.


There is a huge amount of information available.

Particularly good is the free ‘Safer Food, Better Business’ material available from the Food Standards Agency. This can be downloaded directly from the website ( uk goes direct to the download page) or can be ordered from FSA Publications on 0845 606 0667 or by e-mail to foodstandards@ecgroup. Your local authority Environmental Health Department is likely to have copies available. There are two versions. One is for caterers (the target market is those who prepare food) and the other for retailers (food shops). The caterer version is probably most appropriate for beekeepers.

The Hart District Council website has good clear presentation, http://snipurl.c0m/4anfc goes directly to their food hygiene guidance pages.

A set of comprehensive leaflets, including checksheets, is at

The CookSafe site ( has information about HACCP including a range of templates.


I am grateful to Allison Grace, Carol Gilbert, Andrew Spencer, Gillian Asbury, Vincent Greenwood, Keith Gregory, Modupe Ige at the Food Standards Agency and Tina Garrity, Librarian, Chartered Institution of Environmental Health Officers, for reviewing the draft of this article and suggesting amendments, corrections and improvements.


These articles are intended for guidance and to inform of the principles of HACCP, due diligence and food safety. They should not be regarded as comprehensive or as a complete statement of the law or its requirements. They apply principally to small-scale beekeepers producing bottled honey. They do not cover honey processing or the production of other foods, drinks or medications using honey. Separate HACCP assessments would need to be undertaken for these.

Only the Courts can interpret the law.

Changes in legislation, beekeeping practices, scale of operation, etc, will require review and revision of HACCP assessments and implementation of modifications.

References are to English law but similar legislation is likely to apply elsewhere.

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