EC Directives and Regulations
It is important to understand that honey buyers and supermarkets may have market requirements of their own which may be influenced by, but not the same as legislation. Here is a list and explanation of some of the EU legislation which has an impact on honey trade.
First let us clarify the difference between an EC Directive and an EC Regulation
A Directive is a general instrument which does not come in to force until it is transferred into national law - and in the process it will be altered slightly - therefore the consequence of an EC Directive is many different national laws. These laws will have the same main aims but there will be slight local variations in the detail. This can be confusing. EC Regulations are designed to overcome this lack of harmonisation. An EC Regulation is law in every Member State in an identical format.
For example the EC Honey Directive is a directive and provides guidance for each Member State to develop their own Honey Standards. The result is that the UK Honey Standard is not exactly the same as the French Honey Standard.
Directive 96/23/EC Residue monitoring
This Directive concerns the requirement for monitoring residues in animal products. This is the Directive which makes it necessary for all EU countries to monitor residues, and all countries which sell animal products to the EU, to monitor residues. Countries must comply at the national level. Information about acceptable residue levels can be found in supporting legislation such as Regulation 2377/90 (see below). The general rule for honey is that no residues are acceptable.
Directive 2001/110/EC The Honey Directive
This Directive describes honey and is used to guide all EU countries to develop their own Honey Standards. Any sample or consignment of honey can be tested against these Honey Standards to check that the product in question really is honey and not another substance. Only honey which meets the Standard can be sold as honey.
Regulation 470/2009 Residues of pharmacologically active substances
Honey is considered an animal product and it is common practice everywhere for the health of animals to be maintained through the use of medicines. It is however considered unacceptable if some of the residues or breakdown products of these medicines enter the animal food product, which is then eaten by humans. This regulation sets the limit of what is acceptable and what is not acceptable. If a beekeeper never uses any medicines this means they will be producing honey with no residues of pharmacologically active substances. However, buyers will still analyse the honey to check.
Regulation 178/02 Food Safety
This Regulation must be observed by all companies handling, processing, storing and transporting food in the EU. The Regulation does not apply outside the EU. However, in order for EU companies to be sure the food they have bought from outside the EU is safe to eat the company may place certain requirements on the supplier. For example, buyers will demand full traceability for all food products, and expect suppliers to be able to show records showing the origin of all produce. Buyers may also demand suppliers to comply with local laws concerning food safety and provide evidence.
Regulation 396/05 Pesticides
Where honey bees forage on crops which have been sprayed with pesticides it is possible for these pesticides to be present in the honey and they may pose a risk to human health. This Regulation establishes the maximum quantities of pesticide residues permitted in products of animal origin, including honey, that are intended for human consumption.
Regulation 852-854/04 Hygiene
This Regulation must be observed by all companies handling, processing, storing and transporting food in the EU. The Regulation does not apply outside the EU. However, in order for EU companies to be sure the food they have bought from outside the EU has been handled in a hygienic way the company may place certain requirements on the supplier. For example, the buyers may ask the suppliers to implement a HACCP system and write a HACCP plan. Buyers may also demand suppliers develop Good Hygiene Policies and Practices and provide evidence of how these are implemented.
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