The European Commission’s report ‘From the hives‘ (2023) – in setting out the outcome of the work it coordinated with its Joint Research Centre (JRC) and the European Anti-Fraud Office (OLAF)-offers an ambiguous representation of the monitoring performed between November 2021 and February 2022 on a small sample of imported honey from non-EU countries (1,2). Insight.
1) Honey, EU rules
Production, processing and packaging of honey are subject to the hygiene requirements of the Hygiene 2 Regulation (EU) No 853/04. Marketing standards-composition and purity parameters, commercial categories, specific labeling requirements-are instead defined in Honey Directive No 2001/110/EC, now under review (3,4). Honey, in essence:
– can be distinguished in relation to origin (flower honey, nectar honey, honeydew honey), (5) and method of production (honeycomb honey, drained, centrifuged, pressed, filtered, industrial),
– is composed mainly of sugars (glucose and fructose, about 80 percent) and other substances (e.g., organic acids, enzymes, solid particles). Traces of pollen possibly residual by bees do not qualify as ingredients,
– color, aroma and flavor depend on the botanical species of origin, as does the consistency (fluid, dense or crystallized), a function of the glucose/fructose ratio,
– cannot contain any ingredient other than honey nor any additives or foreign substances (including sugars),
– must not have abnormal odors and tastes, ongoing fermentation processes, artificially regulated acidity, and/or have undergone high heat treatments such that all naturally present enzymes are denatured (e.g., diastase).
2) From the hives. Brief monitoring on non-EU imported honey
The European Commission, DG SANTE (Directorate General for Health and Food Safety), coordinated a succinct monitoring action aimed at assessing the incidence of, non-compliance with the ‘honey directive’ and possible food fraud – in particular, by adding sugar syrups – on imported honeys from non-EU countries only.
This action involved the authorities of some member states, the EU Food Fraud Network, the Joint Research Centre (JRC) and the European Anti-Fraud Office (OLAF). The monitoring action, named ‘From the hives,’ consisted of the following three phases.
2.1) Sampling and control
In the four months between November 2021 and February 2022, sixteen member states, as well as Norway and Switzerland, performed random sampling on 320 consignments of imported honey, at the EU borders. Of these, 147 samples (47%) were reported as ‘not complying’ with the requirements of the Honey Directive.
The checks involved 123 honey importers in the EU, 70 of whom were ‘flagged’ for importing ‘suspicious’ consignments, for hypothetical adulteration with foreign sugars. Sixty-three of the 98 importers subject to audits reportedly handled at least one batch of suspect honey, according to authorities.
2.2) Traceability
Participating countries collected information on the destinations of imported honey subject to the controls. In turn, the Commission collected traceability data from exporters in third countries and importers in the EU, also using the TRACES system.
2.3) Investigations
The authorities of the states involved, with the cooperation of OLAF, then carried out investigations into the procurement, processing, blending and packaging stages of the various batches of imported honey.
However, investigations have not yielded reliable results beyond the few cases where food fraud could be established. As in Bulgaria, where controls have verified the addition of sugar syrups to imported honey, or the removal of pollen residues to disguise the botanical and geographic origin of honeys.
The unreliability of controls is due to the absence of harmonized tools and methods of analysis to detect adulteration due to the addition of foreign sugars. Analyses performed by different methods can therefore lead to contradictory results on identical samples.
3) From the hives. The analytical methods used
JRC used several analytical methods to identify honeys suspected of adulteration with sugar syrups:
– Elemental Analyser/Liquid Chromatography – Isotope Ratio Mass Spectrometry.
(EA/LC-IRMS). Method based on the difference between the 13C/12C carbon isotopes of proteins and sugars. Widely used in the past, EA/LC-IRMS is considered one of the best methods for identifying corn or sugarcane starch syrups and also other sugar syrups (e.g., rice, wheat, or sugar beet),
– High-Performance Anion Exchange Chromatography – Pulsed Amperometric Detector.
(HPAEC-PAD). Identifies the presence of polysaccharides with a degree of polymerization (DP) ≥10,
– Liquid Chromatography – High Resolution Mass Spectrometry.
(LC-HRMS). Identifies oligosaccharides with DP < 10 and ≥ 6, as well as other markers such as 2-acetylfuran-3-glucopyranoside (AFGP) and difructose anhydride (DFA),
– Proton Nuclear Magnetic Resonance (1H-NMR) Spectroscopy.
It allows detection of mannose, as a marker, as well as profiling honey based on standards set by private laboratories.
The criteria used by JRC to identify honeys as ‘suspect’ by applying the above methods were:
– Exceeding the thresholds defined for the analyses performed with the EA/LC-IRMS, or
– Oligosaccharides with DPs between 6 and 9, identified by C-HRMS, or
– Polysaccharides with DPs between 10 and 19, detected by HPAEC-PAD, or
– mannose detected by LC-HRMS and confirmed by Nuclear Magnetic Resonance (NMR), or
– DFA or AFGP identified by LC-HRMS.
The combination of these methods can make it possible to identify, through various markers, the presence of elements that are generally foreign to the natural composition of honey. However, none of these methods allow the amount of these elements to be measured, and their presence is not always due to adulteration.
4) AAA uniform method of analysis wanted
‘The Commission may adopt methods to permit verification of compliance of honey with the provisions of this Directive (…). Until the adoption of such methods, Member States shall, whenever possible, use internationally recognized validated methods such as those approved by Codex Alimentarius to verify compliance with the provisions of this Directive‘ (‘Honey Directive‘ No 2001/110/EC, Article 4).
Twenty-two years after the ‘Honey Directive‘ came into force, member states-while waiting for a validated and uniform method of honey analysis-continue to perform pout-pourri of analyses that are not sufficient to identify with certainty the various possible adulterations. And it is on these that the report ‘From the hives‘ (2023) is based, the results of which are therefore unreliable.
5) Coordinated honey inspection plan, 2015-2017
As far back as 2015, the European Commission had issued a recommendation on the coordinated program of official controls, under Reg. (EC) 882/2004). The coordinated honey control plan-the only one no longer available on EUR-Lex (6)-differed from the ambiguous ‘From the hives‘ operation in several respects:
– expressly referred to the Official Controls Regulation (EC) No 882/04, rather than generic ‘samplings‘ and ‘investigations‘,
– official controls covered all types of honey, EU-produced and imported, without discriminating against products on the basis of origin or assuming (falsely) a priori that adulteration occurs only in non-EU countries,
– all 28 member States (instead of only 16 countries), plus Switzerland and Norway, were involved. With the goal of analyzing at least a reasonable number of samples (2,310 samples. Goal 98 percent achieved, with 2,264 samples). (7)
5.1) Quality of official controls
In 2015-2017, controls were not limited-as they were in 2021-2022-to looking for hypothetical adulteration with ‘foreign sugars.’ Indeed, the coordinated plan of official controls carried out in 2021-2022 considered, in a much broader geographical context of production and marketing, every possible noncompliance. Including those on the botanical and/or geographical origin of honey, imported and ‘Made in EU‘. And different types of analysis had been conducted for this purpose, in addition to LC-IRMS or EA-IRMS:
– sensory, to assess characteristics of honey that cannot be measured with available instruments (e.g., abnormal odor, color, taste),
– microscopic, to verify through pollen residues the botanical and geographical origin of honeys. As well as possible traces of filtration, dilution, contamination or other nonconformities,
– electrical conductivity and diastase, as markers of honey quality and possible indications of adulteration,
– determination of the content of various sugars, by gas chromatography (GC) or high-performance liquid chromatography (HPLC).
The ‘suspect’ honeys (1,200 samples, or 53% of the total) were sent to JRC-IRMM(Joint Research Centre – Institute for Reference Materials and Measurements) and subjected to further analysis by methods such as EA/LC-IRMS and NMR. As a result of these checks, only 14 percent of the total honey samples (European and imported) taken were found to be non-compliant with the requirements of the ‘Honey Directive.’
5.2) Methods of analysis. JRC’s support
The results of the analyses carried out by the JRC in 2015-2017 were reported in a report not accessible today on the European Commission website. (8) Among other things, JRC had considered both adulterations of honey (European and imported) with added syrup and indirect adulterations. Namely, the practices of feeding sugar syrups to bees during the nectar flow period, in the absence of any justification related to animal health and welfare.
Isotopic determination had been considered an ‘excellent’ method for identifying sugars from syrups, as also confirmed in a later report. (9) Without neglecting the sensitivity of the method, in relation to various plants (C4,C3), and the importance of the EA/LC-IRMS method for identifying syrups of some plant species. The di- and tri-saccharides were then considered among the most important markers to be defined by this (as yet unvalidated) system.
The recommendations at the time, from JRC-which you may recall is not an official laboratory-were:
– Harmonize analytical methods to be approved by the International Honey Commission (IHC) or an equivalent body. The ‘Harmonised Methods of the International Commission,’ it will be recalled, are the basis for the revision of the Codex Alimentarius standard, (10)
– Develop a biobank of honeys, sugar syrups and bee nutrition products to cover the wide variety of honeys currently available on the European market,
– enter a database of samples, analyzed by validated EC/LC-IRMS or other equivalent methods to define purity criteria and establish the natural variability of different honeys, into the biobank to be stored in such a centralized reference database,
– validate emerging analytical methods, as a result of their verification with data available in the biobank and expert committee evaluations, for further development.
6) Stakeholder contributions
FEEDM, European Federation of Honey Packers and Distributors, represents many honey importers and packers in the EU. A technical working group of his is working on identifying alternative methods to identify exogenous sugars in honey as a result of adulteration. FEEDM and its working group – in acknowledging that the most widely used methods of analysis are not yet harmonized, validated and accredited – offered to cooperate with the JRC to address the problem it reported back in 2016. (11)
Hungarian citizen Zoltán Tóth submitted a petition to the European Parliament (No. 0432/2016), aimed at stopping the marketing in the EU of honey products handled with synthetic macroreticulation resins, which release particles that contaminate honey and may pose a health risk due to the presence of styrene copolymers and divinylbenzene granules, which are believed to be mutagenic and carcinogenic. (12)
The citizen’s petition-who also requested funding for tests to be carried out at EU borders-seems to have surprised the European Commission. The latter, in declaring itself unaware of the reported practice and recalling the execution of the 2015-2017 control plan, merely reported that only the competent authorities of the member states can detect non-compliances as a result of official controls, and, if necessary, arrange for them to be reported on the RASFF. (13)
7) Official Control Regulation
Official Controls Regulation (EU) No 2017/625 provides special measures for cases of ‘suspected non-compliance’ on products within its scope, including honey. These include:
– the duty of the competent authorities to carry out official controls to confirm the suspicion or prove it unfounded (Art. 65.1),
– in case of suspicion on food fraud or violation of applicable rules by an operator, as a result of official controls, competent authorities may intensify official controls on consignments with the same origin or use (Article 65.4).
The requirements and criteria to be applied to sampling methods, the designation of official laboratories for performing official controls and the analyses performed by them are defined in Reg. EU 2017/625 in Chapter IV (Art. 34, 37).
8) Interim conclusions
The sensationalist messages that followed the publication of the ‘From the hives‘ report-where the European Commission reported ‘47 percent non-compliance and adulteration‘ in imported honey-are baseless. And they unfairly put non-EU imported honey on which food security in the Old Continent depends in a bad light. (14)
The uncertain data are based on a sample number bordering on the ridiculous (320), certainly not representative of a segmented and complex market. These were taken from a limited number of member states and analyzed, only in part, by a variety of methods without scientific or official validation. (15)
In all cases, the analyzed honeys were considered as ‘suspect’. With no definite evidence of adulteration, outside of the few cases where investigations have shown possible indications of food fraud. Of note in this regard is one in Italy, where the accusatory theorem has been refuted by review analyses.
Dario Dongo
Notes
(1) European Commission (2023). EU Coordinated Action ‘From the hives’ – Sampling, investigations and results. Publications Office of the European Union. https://food.ec.europa.eu/system/files/2023-03/official-controls_food-fraud_2021-2_honey_report_euca.pdf
(2) European Commission (2023). EU Coordinated action to deter certain fraudulent practices in the honey sector. JRC Publications Repository
https://publications.jrc.ec.europa.eu/repository/handle/JRC130227
(3) Directive 2001/110/EC, concerning honey. Tesso consolidated on Eur-Lex http://data.europa.eu/eli/dir/2001/110/2014-06-23
(4) Dario Dongo, Alesaandra Mei. Honey, fruit juices, jams and marmalades, dehydrated milk. Proposals for reform of marketing standards in EU. GIFT (Great Italian Food Trade). 3.5.23
(5) Honeydew honey is obtained mainly from substances secreted by sucking insects(Hemiptera) found on living parts of plants or from secretions from living parts of plants. According to the circular July 12, 2007, no. 3, in Italy it is also known and marketable as ‘forest honey,’ only if it has been obtained from woody essences. If the source is from herbaceous species, the honey can only be called ‘honeydew honey’
(6) SEE https://food.ec.europa.eu/horizontal-topics/official-controls-and-enforcement/legislation-official-controls/coordinated-control-programmes_en. Missing from the roll call is document 12.3.15 (C(2015) 1558 final), which is supposed to report results on the coordinated honey control plan
(7) European Commission (2016). Coordinated control plan to establish the prevalence of fraudulent practices in the marketing of honey – Outline. https://food.ec.europa.eu/system/files/2016-10/official-controls_food-fraud_honey_control-plan-outline_201512.pdf
(8) European Commission (2016). Scientific support to the implementation of a Coordinated Control Plan with a view to establishing the prevalence of fraudulent practices in the marketing of honey – Results of honey authenticity testing by liquid chromatography-isotope ratio mass spectrometry
(9) European Commission (2020). Determination of 13C/12C ratios of saccharides in honey by liquid chromatography-isotope ratio mass spectrometry. Results of an interlaboratory comparison. https://knowledge4policy.ec.europa.eu/sites/default/files/honey_pt_report_lc-irms_va.pdf
(10) International Honey Commission (2009). Harmonised Methods of the International Honey Commission https://www.ihc-platform.net/ihcmethods2009.pdf
(11) FEEDM. The need of harmonization of analytical methods for honey authenticity. 09.05.23. https://www.feedm.com/download/f.e.e.d.m.-statement-on-harmonisation-of-analytical-methods
(12) European Parliament. Petition no. 0432/2016, submitted by Zoltán Tóth, a Hungarian citizen, on stopping the sale of honey products manipulated with synthetic macroreticulation resins that pose a health hazard to European consumers. https://www.europarl.europa.eu/doceo/document/PETI-CM-605989_EN.pdf 8.6.20
(13) The ‘General Food Law’ on closer inspection provides the possibility for the European Commission to consult EFSA on emerging food safety risks and other issues within its competence (Reg. EU No 178/02, Art. 29,31,34). As it should have done – and did not do – to verify the soundness of scientific methods for risk analysis related to cross-contamination of food with ‘traces’ of allergens. V. Dario Dongo. Allergens and RASFF, European blackout. GIFT (Great Italian Food Trade). 13.7.22
(14) The European Commission’s DG SANTE, in its report ‘From the hives,’ thus followed up on recurring fake news about honey from the People’s Republic of China, the world’s leading producer of bee nectar, and other BRICS countries. V. Dario Dongo. Counterfeit Chinese honey, fake news. GIFT (Great Italian Food Trade). 5.12.18
(15) The Joint Research Center itself expressed doubts, at least in part, about the validity of some methods (such as isotopic determination, which JRC had also previously supported)
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
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