Food Business Registration - exemptions for honey?

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drdrday 

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So, I currently just sell honey from my own front door. As I'm selling direct to the consumer I don't need to register as a food business.
But, this year I have quite a lot of honey so started to think about putting some in my local farm shop, maybe going to a farmer's market, or selling honey gift boxes on Etsy. Even if I don't sell too much through these sorts of outlets this year I wanted to be prepared for next year.
My understanding has always been that if I sold directly to customers I didn't need to be registered as a food business, but in order to sell through shops I should be registered. In addition, although from a legal viewpoint I don't need to be registered to sell directly myself at a farmer's market, I have heard that a lot of markets want you to be registered, even for honey - although to be honest I haven't got in touch with my local markets yet to find out what they say.

Anyway, I got in touch with my local council yesterday to register as a food business, so that I'd have the option of selling my honey through the local shops, but they pointed me at this document (EC Biosafety Hygiene FAQs - question 9), suggesting that this exemption for honey should apply to what I want to do. It basically says that as long as I'm supplying honey directly to a local shop, and in small quantities, I don't need to be registered as a food business.

From reading this forum I know that each local authority seems to have their own interpretations of the rules that apply. Does this fit with what anyone else has been told? Unfortunately they haven't been too helpful in clearly stating 'you don't need to register', just said they 'think this exemption might apply'. Obviously I'd feel happier if I had a clear yes/no from them that I can refer people to in future if I ever get any queries, so I'll see if I can get it a little more directly stated. I'm also assuming that in the absence of anything else at the moment, they're continuing to apply the European Commission rules, even though we've left.
 

Wilco 

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If in doubt register. It's free to do and the paperwork is straightforward. Being a registered FBO is all about what it looks like on paper rather than real life.
 

drdrday 

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If in doubt register. It's free to do and the paperwork is straightforward. Being a registered FBO is all about what it looks like on paper rather than real life.
That was exactly my thinking, and why I applied to register - it would be easy enough to do and belt and braces to cover me for whatever. However, rather than replying to my application they're just suggesting that I don't need to do it, which I'd be okay with as long as they specifically stated in writing that I don't need to do it.
 

Wilco 

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That was exactly my thinking, and why I applied to register - it would be easy enough to do and belt and braces to cover me for whatever. However, rather than replying to my application they're just suggesting that I don't need to do it, which I'd be okay with as long as they specifically stated in writing that I don't need to do it.
I'd just reply saying you'd prefer to for peace of mind- it'll also give you options in future. They may not want to do the assessment but at least it'll make them think you're keen on food hygiene.
 

spiderplantman 

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We only have 6 hives, but I registered thinking it better to than to not. Local council department phoned me a couple of days later and thanked me for registering so that they could put me on the map, but they considered small honey producers too low-risk and small-fry to worry about in terms of hygiene inspections and sign-off etc. They said it wasn't mandatory, but they recommended taking the level 2 hygiene certificate, which you can do 100% online and cost me £15, which to be honest I'd recommend everyone do anyway as it teaches best practices. They also asked me to take basic precautions when harvesting (e.g. clean environments, proper handling of frames etc) and selling (e.g. if selling to a customer holding a new baby, just give them a quick polite caution about babies and honey etc.).
And that was it. All done, no need for further nuisance. Of course, your local council may vary.
 

PeaBee 

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Honey is a low risk food and is unlikely to cause illness no matter how poor the conditions its is produced in so councils will be far more interested in the local kebab shops. However registering is straightforward as is doing a food hygiene course and following haccp principles all of which shows you are a responsible food producer even at a micro scale and gives you and your product even more credibility with customers
 

drdrday 

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I already have my food safety level 2 and I'd prepared a HACCP document last year, so I've emailed them back to say I'd rather register to be on the safe side. I'll see what they come back with.

I was just curious because I hadn't heard of this exemption before and wondered if anyone else had been told they didn't need to register because of it.
 

Gower Beekeeper 

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I was approached by Swansea City & County Council who wanted to visit me. Did my level 2 (it is helpful to do this) and prepared a HACCP document. The visit was painless; the lady had only done one other beekeeper and so was on a learning curve herself. Got a five star assessment which I can show to anyone who asks. I then got a letter saying that I should have an accurate weighing scale ie a commercial one. She didn't get the idea that the jars are made so that they can be easily filled to the correct weight. I am sure most of my jars have more than 12oz specified on the label.
 

WoodenBeam 

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Got a five star aI then got a letter saying that I should have an accurate weighing scale ie a commercial one. She didn't get the idea that the jars are made so that they can be easily filled to the correct weight. I am sure most of my jars have more than 12oz specified on the label.
I don’t think your argument regarding jar filling capacity will stand up. You can easily get around this though (I believe). Take a jar of your Honey to a butchers for example & get them to weigh it on their commercial scales, then use this jar as your calibrated weight example when checking on your own scales. Hope that makes sense.
 

Gower Beekeeper 

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I don’t think your argument regarding jar filling capacity will stand up. You can easily get around this though (I believe). Take a jar of your Honey to a butchers for example & get them to weigh it on their commercial scales, then use this jar as your calibrated weight example when checking on your own scales. Hope that makes sense.
Great idea. Perhaps I will weigh some empty jars to see how much they vary.
 

PeaBee 

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We had a similar request about scales some time ago from the council. All it required was a reasonable set of domestic kitchen scales that we took to trading standards. They checked the calibration and stuck a sticker on. I suppose as we sell our products by weight and not volume we should in theory quality check the odd one. In practice the scales get used to check cut comb and I trust the jars.
 

hemo 

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For my small scales I have a 100g weight to calibrate them with, I use it for every batch I jar up.
 

Newbeeneil 

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For my small scales I have a 100g weight to calibrate them with, I use it for every batch I jar up.
I also have a set of weights (bought on line) that I check my kitchen scales with regularly and although I'm sure Trading standards would frown on the quality I'm sure they are accurate within a gm or two*. They do however let me know if my scales are losing accuracy.

* 99% of all my jars are overfilled by 1-3% anyway.

 

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