Address on Jar label. How specific?

[Grif]

I am thinking of a design for my own honey jar labels. I have seen other labels that are very specific about the address of the supplier, right down to name of house and street number of house and post code. How specific does it need to be? I can see that if you live at a nice sounding rural address then it might be part of the marketing, but with a drab sounding urban address it might not sound so good ? But how specific should the address be by law? Can you just put a postcode? Or just a website or email address?

 

[Thymallus]

Depends where you intend to sell your jars. From the garden gate or farmers markets the wording Honey and a weight are sufficient, no address needed.
Other sales, the address of the seller needs to be traceable, so a name and a postcode should suffice as a minimum. Plus all the other stuff with letter heights ect.

 

[itma]

Depends where you intend to sell your jars. From the garden gate or farmers markets the wording Honey and a weight are sufficient, no address needed.
Other sales, the address of the seller needs to be traceable, so a name and a postcode should suffice as a minimum. Plus all the other stuff with letter heights ect.

I don't believe that is true any more, if it ever was. (I believe it was one of the errors on the BBKA fact sheet on labelling.)

For example you now MUST specify the country of origin. Always.
This is from the new Honey (England) Regulations 2015 http://www.legislation.gov.uk/uksi/2015/1348/pdfs/uksi_20151348_en.pdf

PART 4
Additional labelling requirements
Additional labelling requirements
17.—(1) No person may trade in honey unless the country of origin where the honey has been harvested is indicated on the label except that, if the honey originates in more than one member State or third country, the countries of origin may be replaced with one of the following indications as appropriate—
“blend of EU honeys”;
“blend of non-EU honeys”;
“blend of EU and non-EU honeys”.

There are new Euro requirements, which I don't believe anyone has properly got their head around yet. We don't need an ingredient listing because we only have one official ingredient, honey. And that isn't a listed allergen, so we miss that part too. However, I think the requirement (or not) for nutritional info isn't clear yet.
And the official "name of the food" (visible in the same view as the weight and durability indication) may now be required to be in a specific type size instead of being merely 'legible'. There have been well-understood requirements for specific type size for the (metric) weight - the size varies with the weight of product. Any (optional) imperial weight must not be more prominent than the metric weight.


One thing I'd advise against is any use of the 'e' symbol found on most commercial food product labels. It ties you into statistical limits for how close to the labelled weight you must be. Much simpler to just claim a minimum weight - there is at least that much, and the overweight doesn't legally matter - it certainly does with that 'e' mark.
https://en.wikipedia.org/wiki/Estimated_sign

 

[Erichalfbee]

I have a pretty label on the back of the jar and a standard address label with all the legal info on the front
Address is house name and post code

 

[Thymallus]

I don't believe that is true any more, if it ever was. (I believe it was one of the errors on the BBKA fact sheet on labelling.)

Rydale councils environmental health officers and Hambledon and districts have both (within the last 6 months) told me it you sell direct from a market stall or from home that is all you need on your label to satisfy the current legislation.
Different councils may have different interpretation. Funnily enough non mentioned the CofO detail, although we discussing preserves/jams and Honey at the same time.

 

[itma]

Rydale councils environmental health officers and Hambledon and districts have both (within the last 6 months) told me it you sell direct from a market stall or from home that is all you need on your label to satisfy the current legislation.

I'd be obliged if anyone would please provide a link to the actual Law regarding that (claimed) exception for "Direct Sales".
I have looked for one and never found it.

However, the FSA's Guidance on the 2003 Honey Regs - in the section titled "Prepacked for Direct Sale" does explain that there MIGHT be an arguable case that the country of origin might not be needed for such sales.
Importantly, it says nothing about any other relaxation for "Prepacked Direct Sales".
The BBKA (and possibly those that believed their 'fact sheet') mistakenly (IMHO until proved otherwise) applied that relaxation to other requirements.

And even that possible relaxation (on Country of Origin requirement) has been unambiguously removed by the new Honey Regs (as quoted above) which are now in full force.

 

[beebot]

Has any amateur beekeeper ever been taken to court over these regulations/requirements?

 

[Thymallus]

I'd be obliged if anyone would please provide a link to the actual Law regarding that (claimed) exception for "Direct Sales".
I have looked for one and never found it.

Ring your local Environmental health dept and ask them. That is what I do and it's what they are there for.
Takes minutes and is better than relying on the infallibility of forum "advice", including mine.
I was actually quite annoyed about this minimum labeling as were trying to keep a "dodgy" preserves person off some of the markets we do. We thought, wrongly, that their labeling would not meet current requirements. Alas, according to two local authorities it did....although it would be frowned upon.

 

[Hachi]

Mine just has house number and postcode. Thats it. I put a stamped envelope in the post that looked like ths:

XX / XXX XXX

It came back two days later therefore I have demonstrated trace-ability if its required.

 

[wessexmario]

House name/number and postcode are nearly always unique so road name or town isn't then required.
Producer's/seller's name is required by the legislation.
http://www.food.gov.uk/.../honeyguidance.pdf

Showing the postal town, while not required, can be good marketing as it makes the product 'local'.

 

[Hivemaker.]

Showing the postal town, while not required, can be good marketing as it makes the product 'local'.

I think that is a good idea, doing this to make the product local.

 

[MuswellMetro]

I don't believe that is true any more, if it ever was. (I believe it was one of the errors on the BBKA fact sheet on labelling.)

http://www.food.gov.uk/sites/default/files/multimedia/pdfs/honeyguidance.pdf

see page 16, i don't have time to check if this is still in force or has been changed by later regulations but the direct sales exemption comes from the The Food Labelling Regulations 1996 though part 4 of the 2015 regulation would mean produce of the uk is now needed and for a region The product name of a relevant honey may be supplemented by information relating to its regional, territorial or topographical origin so is it produce of Wales, UK or similar regional label such as Welsh honey but always including the produce of UK

http://www.legislation.gov.uk/uksi/1996/1499/regulation/23/made is the copy from statutory instrument and guidance notes attached to the SI below

4.6 Prepacked for direct sale
Reg 23 FLR
The term “prepacked for direct sale” is defined in the FLR as a food that is
prepacked by a retailer for sale by him or her on the premises where the food
is packed, or from a vehicle or stall used by him or her.
Products which fall within this category will be subject to certain exemptions
by virtue of Regulation 23 of the FLR. This applies to honey harvested at
home and sold at the home, farmgate or in market stalls. Regulation 4(1) of
the Honey Regulations requires certain additional labelling information such
as an origin declaration to be given on specified honey products. It does
provide that this is without prejudice to the generality of Part II of the Food
Labelling Regulations 1996, which means that the general provisions in that
part of the 1996 Regulations continue to apply. Part II of the 1996
Regulations through the application of regulation 23 provides that certain
products which are prepacked for direct sale are exempt from the majority of
the labelling requirements specified in Regulation 5 of the FLR, with certain
specified exceptions. Since country of origin labelling is part of Regulation 5
(by way of Regulation 5(f) which is implemented via the 1998 amendment to
the FLR), it is the Agency’s opinion that honey prepacked for direct sale may
be exempt from the origin labelling requirements of the Honey Regulations. It
should be noted though that this exemption would only apply for honey that is
prepacked for direct sale. Honey sold other than prepacked for direct sale
must be labelled with its country of origin in accordance with the Honey
Regulations.

it was discussed on the forum many years ago when i was still a young and innocent boy or so it feels

http://www.beekeepingforum.co.uk/archive/index.php/t-20169.html

i am not an info geek but was just taking BBKA module 2 and as a physicist allways go back to basics on research/legislation and trust no ones own research conclusions without checking

 

[itma]

... the direct sales exemption comes from the The Food Labelling Regulations 1996 ...

http://www.legislation.gov.uk/uksi/1996/1499/regulation/23/made is the copy from statutory instrument and guidance notes attached to the SI below

The page linked specifically refers not to direct sales but to "food that is not pre-packed".
Which means sold "loose", not already in a container. http://www.publications.parliament.uk/pa/cm200405/cmselect/cmenvfru/469/46908.htm

The definition of "prepacked" in the 1996 Regulations means that non-prepacked food includes food sold loose from a supermarket's delicatessen counter, loose fruit and vegetables and loose baked goods.

Now, I don't know about you, but all the honey I've ever sold has been in some sort of container, and put in there before the customer came along -- which makes it 'pre-packed', and therefore NOT subject to that particular Regulation.

Other than when sold from a tap, I can't see how honey could be sold "not pre-packed" to take advantage of those looser labelling requirements.




As already explained, the arguable exemption from country of origin labelling, for Pre-packed Direct Sales, described in the Guidance Notes to the 2003 Regs (quoted above) has now been unambiguously closed off by the 2015 Regs saying "No person may trade in honey unless the country of origin where the honey has been harvested is indicated on the label"

 

[ugcheleuce]

What does the BBKA say?

How specific does [the label] need to be?

I'm surprised that the two pages on this topic on the BBKA web site are "restricted access". Apparently the BBKA has no desire to maintain or promote proper labelling standards in the UK, except as a secret handshake among its own members.

http://www.-------------/search.php?keywords=label

 

[alldigging]

http://www.bees-online.co.uk/downloads/UKHONEY_LABELLING_REGULATIONS.pdf


To be found you need a minimum of (house number) and (postcode).

eg:

219 M40 3RS

Whether that registers with people as address details or not is something else.

 

[wessexmario]

http://www.bees-online.co.uk/downloads/UKHONEY_LABELLING_REGULATIONS.pdf


To be found you need a minimum of (house number) and (postcode).

eg:

219 M40 3RS

Whether that registers with people as address details or not is something else.

If there is a comma after the house number, then it does make it clearer:

219, M40 3RS


When using the town name, then I've often seen this format which looks and reads ok:

J.Smith
Mylocaltown
219, M40 3RS

 

[Swarm]

Now, I don't know about you, but all the honey I've ever sold has been in some sort of container, and put in there before the customer came along -- which makes it 'pre-packed', and therefore NOT subject to that particular Regulation.

Other than when sold from a tap, I can't see how honey could be sold "not pre-packed" to take advantage of those looser labelling requirements.

Not according to the two speakers we had at our association who were there to discuss new regulations.
Their definition of prepacked would be something like a box of 24 jars delivered to an outlet.

There is no trap or minefield waiting for some poor beekeeper to fall into, they are helpful people so rather than speculate endlessly on a forum, far better to have a chat with your local authority.

 

[Thymallus]

Not according to the two speakers we had at our association who were there to discuss new regulations.
Their definition of prepacked would be something like a box of 24 jars delivered to an outlet.

There is no trap or minefield waiting for some poor beekeeper to fall into, they are helpful people so rather than speculate endlessly on a forum, far better to have a chat with your local authority.

Absolutely. You can bang on ad infintum about what we think the current legislation means. Far better to take the authoritative definition. It's what I do and you are spot on they are there to help not hinder you.

 

[itma]

Here's what the Food Standards Agency thinks
http://www.food.gov.uk/sites/defaul...s/publication/allergy-labelling-prepacked.pdf

What does ‘prepacked’ mean?
‘Prepacked’ refers to any food put into packaging before being placed on sale, when all the following things apply:
●● the food is either fully or partly enclosed by the packaging
●● the food cannot be altered without opening or changing the packaging
●● the product is ready for sale to the public or to a catering establishment

And to me that description indisputably covers honey in a jar.
If you fancy trying to argue that your honey isn't prepacked into a jar, you carry on. Its your choice.



There is a fair amount of idiotic mis-interpretation of the requirements, both by local enforcement officers and internet pundits.

However, most of the misinformation is of the form of "you don't need to do this even though that Law seems to say you must because there's a special exemption that applies as long as you say black is white."

If you just put on what the current Law says you must, you are covered. Everywhere.
Don't rely on one local interpretation of what you can "get away with".
Cover yourself by meeting ALL the requirements.
Its not hard. Really.

 

[Thymallus]

Here's what the Food Standards Agency thinks
http://www.food.gov.uk/sites/defaul...s/publication/allergy-labelling-prepacked.pdf


And to me that description indisputably covers honey in a jar.
If you fancy trying to argue that your honey isn't prepacked into a jar, you carry on. Its your choice.
.

It's why I always take professional advice in these matters and never listen to amateur forum advice.