What traceability for honey in the EU?

Is pollen an “ingredient” or a “component” of honey? Since late 2011, the European institutions have been working on answering that question. Even though the difference may seem small, the decision will actually determine the whole labelling rules regarding GM-honey which the European Commission has been thinking upon throughout March 2013.

“In September 2011 the European Court of Justice (ECJ) made a decision regarding the affair Bablock VS FreiStaat Bayern in which the honey produced on a Bavarian farm was reportedly found to contain genetically modified pollen from a nearby experimental plot growing the EC-authorised genetically modified maize”. Reported by Euractiv, that case actually raised questions about the way we determine GM-honey or natural honey.

In order to label FreiStaat Bayern product a GM-honey, the ECJ choose to consider that the pollen is an ingredient of honey, which means the pollen directly contribute to give the product its final qualities. In late 2012 however, several legal experts questioned the ECJ decision, putting forward that only a very small amount of pollen was found in honey and that it should not be called an “ingredient” but a “component”.

Such a play on words might seem trivial to some of us but it is not. If pollen was to be labelled a component, honey packaging would not have to mention the presence of GMO in the product. But if pollen was to be considered an ingredient, the European Union legislation would require mentioning the proportion of GMO of that ingredient.

In other word, the debate about pollen legally being an ingredient or component for honey is crucial in Europe. It will determine a significant part of European honey brand image and this of course make the producers very concerned. The final decision about GM-honey is also very likely to trigger major regulation shifts in the European honey sector.

Most of the honey that is consumed in Europe is actually imported. The European Union also allowed retailers to sell mixes of different types of honey. Some of those may therefore be produce within the EU borders, whereas some others come from outside. This has of course made traceability fairly difficult to establish in the european honey industry so far.

In March 2013, the discussion in Brussels over the honey industry will therefore have lasting consequences. The Commission will have to choose between promoting a greater transparency for this sector or maintaining the status quo ante. Only a couple of weeks after the horsemeat crisis, there is no doubt that debates will be influence by people’s need for prudence whatever the final regulation will be.