In South Africa, honey is regulated through the Department of Agriculture, Land Reform and Rural Development (DALRRD), under the Agricultural Product Standards Act (Act No. 119 of 1990), specifically the Regulations Relating to the Grading, Packing and Marking of Honey and Mixtures of Bee Products intended for sale in the Republic of South Africa (R. 835/2000).
This regulation defines honey as “the sweet foodstuff derived from the nectar of flowers, sugary excretions of insects, plant juices or sugary secretions of living plant parts other than flowers, after it has been gathered, partially converted and stored in the comb by honeybees or stingless bees”.
There are various types or variations of honey products on the market. It is important to understand how these products are classified under R. 835, to ensure that they are correctly labelled.
Raw honey
Per R. 835, raw honey is honey that is ‘unfiltered’ (has not passed through a filter under pressure) and ‘unheated’ (has not been heated above 38°C).
Raw honey is permitted under R. 835.
Creamed honey
Creamed honey is honey that has undergone a controlled crystallisation process using a tiny seed crystal. This crystal is incorporated into the honey to initiate the formation of many uniform tiny crystals.
R. 835 defines ‘creamed honey’ as crystallised extracted honey purposely processed to be of a uniformly creamy consistency and of a smooth, spreadable texture. Creamed honey is permitted under R. 835.
Vegan honey-imitation products
There are several vegan products on the market that imitate honey. These products may be comprised of apple juice, cane sugar and lemon juice; coconut sap; or have a base of rice syrup or molasses. They do not contain any honey, and do not fall under the definition of honey in R. 835.
R. 835 provides a definition for honey substitutes, which include “any foodstuff consisting of a food substance or mixture of substances that have been made to resemble honey”. Therefore, vegan honey products are classed as honey substitutes.
Regulation 9 of R. 835 goes on to state that the word ‘honey’ or any representation thereof may not appear anywhere on any honey substitute, its label or packaging.
Therefore, vegan honey-imitation products should be named and labelled appropriately, and should not include the word ‘honey’.
In a case in which a honey-substitute product contains honey, then the word ‘honey’ may only appear in the list of ingredients of the honey substitute.
For more assistance on this matter, please contact us.
Flavoured honey products
For a product to be labelled ‘honey’, it should comply with the definition of honey in R. 835, be comprised only of honey, and should not contain any additions.
Foodstuffs may be added to honey for a specific purpose, such as adding a non-typical honey flavour. However, the product name must then include a true description of the product and any additions, as per regulation 8 (2) and 9 (1) in R. 835.
For example:
‘Strawberry-Flavoured Honey’ if a strawberry flavour is added to honey.
‘Strawberry-Infused Honey’ if strawberries are steeped in honey to impart a specific flavour to the honey and are then removed.
‘Strawberry Honey’ would be an incorrect naming convention for a flavoured honey product, as this would imply that the honey originates mainly from the nectar of strawberry flowers (i.e. it is a monofloral honey).
If herbs or spices are added directly to honey, then the product can be described as (for example) ‘Honey with nutmeg’.
Beyond naming conventions, the following requirements apply when additions have been made to honey:
- The product name and additions must be indicated as a unit in the same letter type and size, e.g. ‘RASPBERRY-FLAVOURED HONEY’, not ‘RASPBERRY-flavoured HONEY’.
- When pictorial representations of an addition are indicated on the label, the actual foodstuff must have been added to the honey.
- Choice grade honey must be used for honey-flavoured products. This should be indicated on the product label.
- The product label for a honey-flavoured product must still comply with R. 835.
- A honey-flavoured product must contain at least 50% honey.
- In a case in which honey comprises less than 50%, the product will be classed differently to what is described above, and different requirements will apply.
- For example, if a product is 49% honey and 51% chocolate, then the product would be described as ‘chocolate with honey’, but not as ‘honey flavoured with chocolate’.
FACTS strives to stay on top of honey-fraud trends and come up with testing solutions that best support our clients’ needs. For more information on honey testing, assistance with food fraud, and/or consulting on regulatory requirements, please contact us.
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