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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 fulltraceability 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 thesepesticides to be present in the
honey and they may pose a risk to human health. This Regulation
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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.
