177 | Honey Fraud Fight | Colour Coding Guide |
Plus, what the new regulatory landscape in the US means for food safety
Honey fraud fight (including insights from the trenches);
Save the date: Feed Safety Webinar 13th, 14th March;
A guide to colour coding for food businesses;
Food Safety News and Resources;
Did the USDA really accidentally fire its bird flu experts?
Food fraud news, emerging issues and recent incidents.
Hello, lovely readers,
Welcome to Issue 177 of The Rotten Apple. And an extra special welcome to our new subscribers from contract manufacturing, academia and government 👏👏Brenda from Alabama, Karsten from Germany, Ross from Scotland, Alexandra from New York State and Jessica from Australia 👏👏 Thank you for your financial support, I couldn’t do this without readers like you.
This week’s issue revisits honey fraud, with new insights from an expert panel in the United Kingdom, and a personal story from a honey packing house. There’s also a guide to colour coding for paying subscribers, and an announcement about our first live webinar for 2025.
Also this week, a high-level view of the new regulatory landscape in the USA (did they really just accidentally fire the bird flu experts at the USDA?). And, as always, I’ve got food fraud news for paying subscribers - not much today I’m afraid - and food safety news for everyone.
Have a fabulous week,
Karen
Note: Subscription fees for new subscribers increase on 28th February for the first time in 3 years. Current subscribers are unaffected and retain access to the current price ($10 per month or $100 per year). Free subscribers should upgrade to a paid subscription now to lock in the existing price while it’s still available.
Cover image: An AI image maker imagines honey bottling
Feed Safety Webinar
If you’re like me you don’t know as much about animal feed safety as you might want to. With more frequent human outbreaks being attributed to Salmonella-contaminated pets and pet food and an increasing focus on chemical contaminants in the food chain, I’m keen to learn more.
That’s why I’ve engaged the expertise of an animal feed safety expert to break it down for us in an hour-long webinar in March. I can’t wait.
Save the date: Thursday 13th March, 21:00 UTC (Los Angeles 2pm, London 9 pm, Johannesburg 11pm, Hong Kong 5 am Friday, Sydney 8 am Friday). Joining instructions will be in next week’s newsletter.
Honey Fraud Fight
Honey is a top performer when it comes to food fraud – and not in a good way. In fact, in 2024 it was among the top three food commodities with the most food fraud reports from government sources, media and peer-reviewed publications. The other two were seafood and dairy (source).
Honey is vulnerable because it is highly valued and its liquid form makes it easy to dilute and adulterate. Because it sells for a high price food fraud can be highly profitable.
Fraud shows up in honey in many ways:
direct adulteration by the addition of sweeteners such as sugar syrup, corn syrup, invert syrup, fructose
direct adulteration by the addition of colourants
indirect adulteration - this occurs when bees are fed on sugar water* rather than obtaining their food from flowers
'unripe' honey* production methods; the honey is harvested from the hive while it still has a very high water content and is then artificially dried
dilution with water
false claims about botanical sources, with acacia honey an emerging problem in Europe in 2022 (note, some problems with botanical source claims are due to genuine errors on the part of the beekeeper rather than deliberate fraud)
false claims about geographical origins
misrepresentation of organic status
addition of honey fragrance, pieces of beeswax and bee bodies to make fraudulent honey appear authentic (more likely for artisan and 'farmhouse' honey)
honey may also be affected by undeclared or illegal levels of antibiotic and pesticide residues
Manuka honey can be adulterated with one or more of the chemical markers that are used to authenticate manuka, such as dihydroxyacetone (DHA) and methylglyoxal (MGO).
* Bee feeding and high-moisture honey harvesting are legitimate practices (i.e. not fraud) in some jurisdictions, dependent on buyer specifications and claims made about the honeys.
(This list was originally published in my food fraud risk information database, hosted on Trello).
Surprising results
Consumers may find it surprising that honey fraud appears to be more prevalent in products sourced from informal markets and lesser-known brands, compared to supermarket brands. Recent examples include surveys conducted in Chile and Brazil.
News from the trenches
Yesterday I read an account about honey fraud from a food safety professional in North America. They work for a company that purchases overseas-sourced honey in bulk and bottles it for customers in North America.
Their company is well aware of the possibility of fraud in honey, so they create composite samples of every incoming load and send them to a lab in Germany for two different adulteration tests. They occasionally encounter shipments with authenticity concerns and reject them.
Unfortunately, the person said they are almost certain that the rejected loads are not sent back overseas but are sold on to other less conscientious – or perhaps less wary – customers in North America.
Sadly, their company lost an important customer to a competitor who could supply ‘honey’ at much lower prices than they could. When they tested the competitor’s ‘honey’ it failed adulteration tests across multiple batches.
Testing controversies continue
In 2021 and 2022, the European Commission investigated honey fraud in a coordinated action known as ‘From the Hives’. The action included authenticity testing of 320 consignments of honey imported to Europe. The consignments were chosen according to risk – that is, the sampling was targeted, not random, and included shipments from 20 countries.
Of the samples from the United Kingdom, all 13 failed the authenticity tests and were declared ‘suspicious’.
That’s a suspected fraud rate of 100%!
Within the European Union, the operation prompted the creation of new rules for honey traceability and honey origin information for consumers, colloquially known as ‘The Breakfast Directive’.
Within the United Kingdom, the results provoked consternation, with the National Food Crime Unit questioning the validity of the test methods in a 2024 report.
Earlier this month, the United Kingdom’s Department for Environment, Food & Rural Affairs (DEFRA), published the results of an official review of the methods used in ‘From the Hives’. The review was conducted by two working groups formed by DEFRA and the Food Standards Agency (FSA).
Here's what they said about the methods used in ‘From the Hives’:
The groups expressed frustration that limits of detection (LoD) and limits of quantification (LoQ) had not been supplied for certain tests used in the honey survey.
They expressed concern that some of the tests are not supported by sufficient published data, including tests that consider the presence of difructose anhydride (DFA), oligosaccharides and mannose to be markers of adulteration because these chemicals can be naturally present in authentic honey.
They questioned the use of Elemental Analyser/Liquid Chromatography Isotope Ratio Mass Spectrometry (EA/LC- IRMS) Analysis for Manuka honey, because Carbon 13 isotopes can deplete in the proteinaceous fraction of honeys high in methylglyoxal such as Manuka, and because the database used to create the EA/LC- IRMS method is believed not to contain Manuka honey.
Other concerns about EA/LC- IRMS included questions about how much natural biological variation can be accounted for in a database formed from only 451 authentic honeys, and about biases potentially present in between-lab and in-lab calibrations.
They supported the use of rice marker syrup (2-acetylfuran-3-glucopyranoside (AFGP)) detection by LC-HRMS as a way to flag potentially inauthentic honeys. However, they said that because some rice syrups are low in AFGP and some are high, and because trace amounts could be present through cross-contamination, a detection of AFGP, unaccompanied by a limit of detection, is essentially meaningless.
Bee feeding practices add even more uncertainty
Bee feeding – in which bees are provided with artificial nectar to main hive health – further complicates testing, said DEFRA’s working group. This is because bee feed, which can be chemically identical to the sugar syrups used as adulterants in honey, can carry over and persist in the hive for perhaps up to 8 weeks, although published evidence for the duration of carryover does not exist.
On the subject of bee feeding, the group said the presence of sugar syrup below 5 to 10 percent in honey is more likely to be due to carryover from bee feeding than a result of economically motivated adulteration.
Takeaways for food professionals
Honey is extremely vulnerable to food fraud and there are frequent reports of fraud in honey.
Food authenticity testing is complicated.
Many of the most sophisticated food authenticity tests compare the test sample to a database of reference samples. If the reference database is not robust, the test is less accurate.
Certain chemical markers can indicate that honey may have been adulterated with added sugar syrups, but any suspicions need to be confirmed by further testing and trace-backs because some markers can be naturally present in small quantities in authentic honey.
The practice of bee feeding, which is allowed for honey production in some jurisdictions, can confound authenticity tests that detect sugar syrups in honey, as bee feed can be chemically identical to syrups added to honey for fraud, and can carry over into honey if the harvest occurs close to bee feeding time.
Main source
Department for Environment, Food & Rural Affairs (2025). Review of methods applied in the ‘From the Hives’ survey on honey authenticity. [online] GOV.UK. Available at: https://www.gov.uk/government/publications/from-the-hives-honey-authenticity-survey-methodological-review/review-of-methods-applied-in-the-from-the-hives-survey-on-honey-authenticity [Accessed 24 Feb. 2025].
The DEFRA review also includes a comprehensive list of peer-reviewed papers about various markers for detecting honey adulteration – one for the honey analysis nerds!
🍏 More like this: Honey Fraud in Europe | Issue 81 🍏
This month’s special supplement for paying subscribers is a complete guide to colour coding in food businesses. Click the preview box below to see it.
Food Safety News and Resources
My food safety news and resources posts have no fluff, no filler, no ads, no promos, no junk, just expertly hand-curated food safety news from around the globe, brought to you each week. This week: a sad collection of all-too-predictable food safety recalls, plus a head-scratcher of a video about Boar’s Head’s response to their deadly outbreak and two free webinars.
Click the preview below to read.
Quick update on the new regulatory landscape in the USA
Unless you’ve been living under a rock you will know that government agencies in the US are undergoing major upheavals right now.
The Make America Healthy Again (MAHA) platform, which aims to cut through red tape and improve nutrition and ingredient safety for American consumers, is trying to increase the number of banned food additives - essentially more regulation - while simultaneously firing staff who were hired to review the safety of chemical additives, all within a broader policy environment that is generally considered to be anti-regulation. Confusing!
The new(ish) head of human foods at the FDA, Jim Jones, who was hired in 2023 to help reorganise and streamline the food program, resigned last week after staff he had recruited to focus on food chemical safety were fired “indiscriminately”, saying this would make it “fruitless” for him to continue in the role.
Under Jones, a range of chemical additives and chemical contaminants were subjected to safety reviews, including BPA, PFAS, phthalates, titanium dioxide, heavy metals and FD&C Red No. 3.
Intriguingly, Jones’ replacement is expected to be an attorney and partner at a global corporate law firm, someone called Kyle Diamantas, who is both a personal friend of Donald Trump and has many contacts at senior levels in Big Food, reports Helena Bottemiller Evich of Food Fix.
Meanwhile at the USDA, there have reportedly been “accidental” firings of bird flu experts, whom CBS News says the department is now trying to rehire.
What does all this mean for food professionals?
For now, it’s a waiting game. Robert F. Kennedy Jr., the newly appointed Secretary of Health and Human Services in the Trump administration, has expressed some decidedly unscientific opinions about raw milk and seed oils, but his overall policy towards improving health through better nutrition and reducing additives in food has been well-received.
In the longer term I expect many US food businesses will need to reformulate to accommodate new additive bans, and implement more robust mitigation systems for hard-to-avoid food contaminants of environmental origin like lead, cadmium, arsenic and PFAS chemicals. But for now, nothing appears decided yet.
I am very interested to see how everyday US consumers respond when their favourite foods are reformulated with different, or fewer synthetic food additives. How will they adjust to foods that are less brightly coloured, and with shorter shelf lives than they are accustomed to?
It’s one thing for American voters to agree with RFK in theory, another to discover your favourite breakfast cereals and candies suddenly look and taste different.
Next week: The future of food regulation in Europe
Below for paying subscribers: Food fraud news and incident reports
📌 Food Fraud News 📌
Seafood shock follow-up (USA)
In response to shockingly high levels of fraudulent claims about seafood provenance allegedly occurring
Keep reading with a 7-day free trial
Subscribe to The Rotten Apple to keep reading this post and get 7 days of free access to the full post archives.