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August 5, 2022
Ongoing Efforts to Address Fraud and Adulteration of Honey

In the next farm bill, Congress may address concerns raised
by U.S. honey producers about the adulteration, misbranding,
and fraudulent mislabeling of both domestically produced
and imported honey. Some producer groups claim such
concerns could be addressed through regulatory standards for
what constitutes honey, enhanced country of origin labeling,
and enforcement of intentional fraud and adulteration of
honey imports in violation of U.S. customs and trade laws.
Background
Honey is a food product with documented reports of food
fraud, adulteration, and misbranding. As highlighted by the
Food and Drug Administration (FDA), some companies
intentionally dilute honey by mixing in cheaper sweeteners
such as corn syrup, rice syrup, sugar beet syrup, or cane
sugar, which lowers their cost of production, and then
market and sell that product to consumers as pure honey at
higher prices. U.S. honey production has steadily declined,
while imports have sharply increased (Figure 1, Table 1).
The Customs and Border Protection (CBP) and the
Department of Justice have pursued cases involving illegal
imports of fraudulent or adulterated honey. FDA has seized
honey imports in response to tests indicating some products
contain unapproved chemicals and antibiotics or other
agricultural chemicals, triggering FDA import alerts.
Product Standards for Honey
The U.S. honey industry has tried to address fraud and
adulteration concerns by advocating for stricter product
standards. In 2006, honey producers, packers, exporters,
importers, and marketers petitioned FDA to develop a
national standard of identity for honey under 21 C.F.R. 130.6
(Docket No. FDA-2006-P-0207-0001). Standards of identity
are established by regulations that determine what a food
product must contain to be marketed under a certain name
(see text box). FDA is the agency responsible for developing
a standard of identity for food products, such as honey, under
the Food Drug and Cosmetic Act (21 U.S.C. §341).
The 2006 petition asked FDA to implement a federal
standard of identity for honey based on the 2001 international
standard established by the Codex Alimentarius Commission,
an intergovernmental organization within the United Nations.
Codex standards are voluntary and intended to promote food
definitions and requirements to support harmonization and
ensure fair practices in international food trade. Codex's
Standard for Honey (CXS 12-19811), for example, describes
allowable moisture content and specifies sugar, fructose,
glucose, and sucrose content (and in some cases, nectar
source); water insoluble solids content; additives,
contaminants, and pesticide/veterinary drug residue levels;
hygiene and codes of practice; and product labeling. While
Codex standards are voluntary, they often serve as a basis for
national legislation. Separately, the U.S. Pharmacopeia, a

nonprofit organization that publishes the pharmacopeia for
the United States, is examining honey in its 2020-2025 Food
Chemicals Codex standards review.
Figure 1. U.S. Honey Production and Imports
(00                                                 0
4a
Source: CRS from USDA (https://quickstats.nass.usda.gov/) and USITC
DataWeb (https://dataweb.usitc.gov/). Data not adjusted for inflation.
Notes: Natural honey (Harmonized Tariff Schedule, HTS 0409). Does
not include other related imports (e.g., HTS 1 702, 2106.90.9988).
Table 1. U.S. Honey Production and Imports, 202I
U.S. Production (million lbs.) U.S. Imports (million lbs.)
State            Vol.       %   Country       Vol.       %
North Dakota      28.3    22%   India         124.7    26%
South Dakota      12.3    10%   Vietnam       123.5    25%
California         9.6     8%   Argentina      95.3    20%
Florida            8.5     7%   Brazil         76.0    16%
Texas              7.7     6%    Ukraine       1 3.1    3%
All Other         60.2    48%   All Other      53.0     1 1%
Total           126.5           Total        485.7
Sources: CRS from USDA data (https://quickstats.nass.usda.gov/) and
USITC DataWeb (https://dataweb.usitc.gov/).
Note: In May 2022, an antidumping duty investigation by the U.S.
International Trade Commission concluded that some leading import
suppliers in India, Vietnam, Argentina, and Brazil were selling honey at
less than fair value that have materially injured the U.S. honey industry.
Perceived delays in FDA's response to the 2006 petition
prompted House appropriators to add language to a FY2010
committee report directing FDA to respond to the 2006
petition (H.Rept. 111-181). The report also urged FDA to
address products illegally marketed as honey that contain
other ingredients in order to protect consumers and the
domestic honey industry from misbranded honey and honey-
derived products that are currently entering the U.S. market.

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