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.
