Honey labels are increasingly carrying the words ‘Raw Honey’, but what does the term mean and what do the relevant authorities think?
Definition
Raw: ‘not prepared for the use as food by the action of heat, uncooked’.
For milk, there is an added specific definition: ‘unpasteurised’ and for sugar: ‘unrefined or partly refined’.
Shorter Oxford Dictionary
Ask anyone (and we did, on social media) what they mean by ‘raw honey’ and you will receive an array of answers. Nonetheless, it’s a term that is growing in popularity, especially in foodie circles. It has probably been inspired by the interest in raw milk – a term which does have a clear dictionary definition: unpasteurised.
Definitions for raw honey that we have heard include ‘not pasteurised’, ‘not heated above hive temperature’, ‘comb honey’ and ‘just a faddy term used to sell more to hipster folk’. Not pasteurised is sometimes defined as ‘partial sterilisation’ sometimes defined as not heating above hive temperature, generally 32–35 °C. The degree of filtering also sometimes enters the brawl with an unclear distinction between coarse and fine filtering.
So, there is some ambiguity among beekeepers. But the ambiguity doesn’t stop there. It extends to the various food authorities and their approach to the term.
Raw in England and Wales
Unknown to most beekeepers, in September 2017, a voluntary group (the Food Standards and Labelling Focus Group) of the Association of Chief Trading Standards Officers (ACTSO), representing senior trading standards managers from across England and Wales, issued ‘technical guidance’ about raw honey. Their guidance was for trading standards officers and specifically not for producers because interpretation and implementation are devolved to the local council trading standards. In England and Wales, trading standards officers may interpret and implement the guidance as they see fit. Businesses and producers therefore must refer to local trading standards personnel – which causes obvious difficulty if you are selling your honey nationally.
The Focus Group
Aside from the complication of local interpretation of the ACTSO guidance, what did its focus group actually say? They didn’t like the term raw because they thought it implied properties above and beyond ‘honey’. They consider that the composition of honey is not altered by the usual permitted heat application (up to about 45 °C), and that the term ‘raw’ could therefore be applied to all honey. If it is heated to the point where enzymes are destroyed (temperature undefined), it becomes ‘baker’s honey’.
Therefore, raw honey has no special characteristics and the term becomes misleading. However, I need to warn readers that this is my interpretation of the guidance – and it is not up to me to interpret it – that’s the job of trading standards officers as it clearly states in the guidance preamble.
Raw in Scotland
North of the border, responsibilities lie with the country’s food standards agency. Stephen Hendry, senior policy advisor at Food Standards Scotland, told Bee Craft, ‘The use of the term “raw” when describing honey could be considered misleading, according to the European regulations covering this, as it suggests that the honey possesses special characteristics which almost all honeys possess. It is not a recognised term and we would therefore advise that businesses do not use it when describing honey on food labels.’
In any event, Dr John Wilkinson, general secretary of the Scottish Beekeepers’ Association, was not aware of anyone using the term in Scotland.
Raw in Northern Ireland
Similarly, the term raw honey does not seem to be used much or at all in Northern Ireland where food labelling issues are dealt with by environmental health officers in its district councils.
Raw in the USA
Rusty Burlew, famed US beekeeper and friend of Bee Craft, says that the US Food and Drug Administration (FDA) once stated on its website: ‘It is widely accepted that raw honey is honey which was not filtered or heated above normal ambient temperature.’
The definition of ambient could be contentious, but it doesn’t matter much now because the statement has been withdrawn from the website and currently the only FDA website reference to raw honey is in a warning letter to a Texan honey company about misbranding violations on several health-related terminology counts.
Raw in Practice
Dale Gibson of Bermondsey Street Bees is one of the growing band of advocates for the use of the term raw honey. ‘We use “raw honey” to distinguish our artisan honey from the supermarket product. Our customers don’t really know the meaning of the term, but it opens a conversation and then we can tell them how we produce our honey.’
However, one of Bermondsey Street Bees’ retailers objected to the use of the word raw. ‘We’re having to redesign and relabel a whole batch of our honey – that will run into hundreds of pounds at least,’ explains Dale. ‘As artisan beekeepers we want to keep beekeeping alive in the UK and if we can’t use the term we don’t think the consumer can make a judgement about the honey they buy – it’s the key to the door to enabling the consumer to distinguish between small producers and the industrial product sold by supermarkets.’
Dale claims to produce a premium product and wants to distinguish it from the industrial product that often, he says, involves flash heating or worse. ‘To equate our honey with that on supermarket shelves is like comparing barista coffee with instant coffee!’
Dale adds that since the oilseed rape (OSR) honey crop usually needs to be heated above 45 °C, it is clearly not raw under any current definitions. ‘This demonstrates that raw is a special and differentiating description in the artisan honey world between OSR and other honeys – even if the industrial processors pretend that they do not heat honey to temperatures above 45 °C.’
Bryden McKinnie, of Jacobite Apiaries a small-scale producer near Edinburgh, also toyed with using the term raw, but withdrew it when objections were raised to the use of the word on labels that he had produced on request for a colleague in England. ‘I believe that there was some sort of complaint against my English colleague’s labelling and trading standards came down very firmly on him,’ explains Bryden.
How then can small-scale producers distinguish their honey from the industrial-style packers? Ponts’ Bee Products and Services posted a statement about raw honey on its website last year: ‘… we see no need to over emphasise the quality of our honey and mislead customers. The taste of our pure English honey speaks for itself.’ (http://pontshoney.com/raw-honey-statement/)
Looking for a single word to distinguish artisan from industrial honey, Dale Gibson, only partly in jest, has suggested the term ‘braw’ honey. Braw is of Scottish origin with meanings including worthy, fine, good and splendid according to the New Shorter Oxford Dictionary. The internet’s Urban Dictionary offers perhaps an even more appropriate definition: ‘unintelligible, yet somehow mysteriously compelling, Scots word for grand, fine, super…’
Meanwhile, in America, there are reports of jars labelled as ‘Bee Free Honey’ with, in much smaller letters: ‘substitute made from organic apples’.
Written by Stephen Fleming | Appears in the October 2018 Edition of Bee Craft Magazine