Address on Jar label. How specific?

[MuswellMetro]

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

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"

the link goes to sec 23 and 23 (ii) says prepacked for direct sale it does not only include not prepacked, why do you think it only applies to not repacked? The statutory instrument 23 (1) says




23-(1)
This regulation applies to—
(a)food which is—
(i)not prepacked, or
(ii)prepacked for direct sale,

 

[itma]

the link goes to sec 23 and 23 (ii) says prepacked for direct sale it does not only include not prepacked, why do you think it only applies to not repacked? The statutory instrument 23 (1) says




23-(1)
This regulation applies to—
(a)food which is—
(i)not prepacked, or
(ii)prepacked for direct sale,

1/ Because it was almost 1am when I posted ...
2/ The section heading makes clear that it refers to "Food which is not prepacked and similar food, and fancy confectionery products"
and thus
3/ in that context, believing that "prepacked for direct sale" foods are rather similar to "prepacked" foods and NOT "similar" to "food which is not prepacked" (ie loose), I believe that the regulation is probably intended to be read as "this applies to food which is not (i)prepackaged or (ii)prepackaged for direct sale - as that would be logical -- the Reg applies to "loose" (unpackaged) foods.
This is so you could just have a sign saying 'Potatoes' beside your open sack, without giving lot numbers, best before, etc.

This is one of those examples where some people say "you can leave that bit off your label" and I say "safer to put whatever any official might believe to be required" and ignore dubious exemptions.


HOWEVER that whole argument is moot, because the '96 Regs are out of date, trumped by Regulation (EU) No 1169/2011 in force since last December.
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:304:0018:0063:en:PDF

Which establishes the basic principle that "Any food intended for supply to the final consumer or to mass caterers shall be accompanied by food information in accordance with this Regulation."
It is currently causing problems for restauranteurs who must now indicate allergy info in their menus!
We escape allergy and ingredient labelling because honey is a single ingredient foodstuff.
Nutritional labelling is the minefield. The question therein is whether or not honey is "processed". Annex V of the Reg says

FOODS WHICH ARE EXEMPTED FROM THE REQUIREMENT OF THE MANDATORY NUTRITION DECLARATION
1. Unprocessed products that comprise a single ingredient or category of ingredients;
2. Processed products which the only processing they have been subjected to is maturing and that comprise a single ingredient or category of ingredients;3 ...

So we might have to have Nutritional stuff if the honey is "processed". The EU Reg helpfully uses the definition of "processed" from another EU Reg, 852/2004, but that's not that helpful for beekeepers 'extracting' honey

(m) "processing" means any action that substantially alters the initial product, including heating, smoking, curing, maturing, drying, marinating, extraction, extrusion or a combination of those processes;
"unprocessed products" means foodstuffs that have not undergone processing, and includes products that have been divided, parted, severed, sliced, boned, minced, skinned, ground, cut, cleaned, trimmed, husked, milled, chilled, frozen, deep-frozen or thawed;

It looks from that as though soft set honey (extracted, warmed, mixed and then chilled) might possibly be considered "processed".
However, I am relying on the very last provision in Annex V to escape Nutrition labelling

19. Food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer.

Now, before someone claims I'm looking for a "dubious exemption", where can I find the definitions of "local" and of "small quantities" ...

 

[RogueDrone]

get the "Man from the Ministry" council to come and do an association talk they are very friendly people and only want to help .

Colin

 

[allotment-bee]

So, with my bees being kept at an out apiary, do I use the postcode from there or my home where we jar it?

 

[wessexmario]

So, with my bees being kept at an out apiary, do I use the postcode from there or my home where we jar it?

The labelling requirement is that the food producer/manufacturer (legal person) can be contacted.

If your apiary has a postbox, then by all means use that.

 

[Swarm]

get the "Man from the Ministry" council to come and do an association talk they are very friendly people and only want to help .

Colin

It's no use, that advice has already been ignored.

 

[Thymallus]

The labelling requirement is that the food producer/manufacturer (legal person) can be contacted.

If you sell direct to the public you do not even need to put your contact details on the label. That little gem comes from the man at trading standards.

I do however, agree with ITMA. It is just as easy to put all the correct information on the label rather than go with "what's the minimum I need".

 

[jenkinsbrynmair]

If you sell direct to the public you do not even need to put your contact details on the label. That little gem comes from the man at trading standards.

It's also what it says in the honey regulations - but why get one's knickers in a twist over it - far simpler to put it all on the label than spend days trying to find loopholes and exemptions

 

[Thymallus]

Exactly what I said.

 

[jenkinsbrynmair]

 

[Queens59]

When we moved last May I needed new labels, and contacted the local Trading Standards who sent 3 pages of very badly photocopied papers. I couldn't read it so phoned them again and got an actual person! They said all I needed on the front label were...The Honey Name eg: Harry's Honey, Weight in Gr. and Lb. and Best before date.

Address & contact details, Country of Origin and anything else on the back - but as someone else said each area may have different rules...

 

[wessexmario]

The honey labelling legislation only requires weight in metric, imperial weight is optional.
A lot (batch) number starting with an "L" is also mandatory

The rules are set by UK legislation, there's no variation of honey labelling by area.
Some of the legal statutes are enacted separately for each of our 4 UK countries, but the effect of the legislation is the same across the UK.

It's best to refer to the original legislation, rather than rely on other's incorrect interpretations of it.
It can all be found here: www.legislation.gov.uk

 

[jenkinsbrynmair]

A lot (batch) number starting with an "L" is also mandatory

No it's not, and the 'L' is not necessary if it is obvious the number is a lot/batch number, it also depends on whether you are a 'from the door' seller or not and the format of your 'Best Before' date

It's best to refer to the original legislation, rather than rely on other's incorrect interpretations of it.

but you need to understand how to read it

 

[wessexmario]

but you need to understand how to read it

hoisted by my own petard

ok, lot number isn't mandatory, but without one you can't sell through a third party before the consumer (eg a shop).
I'd suggest better to have one on the label then as it'll cover all eventualities.

 

[jenkinsbrynmair]

Just going to order a new batch of labels now - this time instead of having to fill in best before dates and lot numbers It'll just have BBE - see base, then I can just stick the date on the base with a handgun labeller - if you put the full date ie 01/01/2021 or wehatever, you don't need a batch number (the assumption being you can trace back the batch as it was bottled on 01/01 - however many years back from 2020 dependent of how long you give them (I give five years)

 

[Thymallus]

- however many years back from 2020 dependent of how long you give them (I give five years)

I used to give them 5 years for best before but had a customer return a jar that was 4 years old where the top of the honey had started to ferment. She had obviously left the top loose, it absorbed water, diluted the honey and so the yeasts started. It was a set honey and top inch was now liquid and bubbling and not nice. As it still had a year to go on its best before date I gave her a refund and free replacement jar. Being a Yorkshire man it still hurts!
I now only give a 1 year best before from the date of bottling. It protects me from customers stupidity.
You live and learn.