Raw honey

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doesn't really matter what the one judge in a single tribunal said - it's still not a test case.
IMO 'raw' is a ridiculous term clung on to by ridiculous people with deep insecurities about their product.
 
Or you can take the opposite view that the term Raw is recognised by discerning customers who distinguish the product from the mass produced, heat treated, blended stuff that purports to be 'honey' sold in some high quality retail environments and which tastes nothing like the real stuff.

From the lack of a clear ruling it would appear that there is little risk to the hobby beekeeper from labelling their honey as such - although, if you are selling it in tonnes through retail outlets there may be a small risk - the cost of some new labels if some nit picking pedant or interfering busy body decides that you are unfairly marketing your superior, locally produced, raw honey and decides to involve trading standards. TS are never going to go to Court - most likely will just ask you to change your labels - whether they can enforce that, without court proceedings is doubtful.

Of course, you may have to face the hand wringing wrath of those beekeepers who feel the sanctity of the word honey should be preserved for eternity without differentiation of its origin.

Just saying ... :)
 
doesn't really matter what the one judge in a single tribunal said - it's still not a test case.
IMO 'raw' is a ridiculous term clung on to by ridiculous people with deep insecurities about their product.

A lot of hope being invested in the judge using the word 'may' in the remark '....it may be that clearer guidance or regulation would assist consumers and producers'. Judges are careful with words and he could have used different words (must, paramount importance, urgency etc) if he'd wanted to encourage a rapid change.
 
For those at the BBKA who complain about honey fraud, you would hope this paragraph from the judge would spark some investigation/interest from Trading Standards:

The evidence of Mr Payne, and the ACTSO guidance, gave me a strong impression of an institutional reluctance to engage with developments in manufacturing technology and practices, and to address whether they may put honey in breach of the separate requirement that enzymes should not be "significantly deactivated". At the very least, the ACTSO guidance and its defence reveals a lack of understanding about pasteurisation / flash-heating conducted by industry and its effects on products.

However, first the BBKA need to get their own house in order. Significant to the case was training materials produced by the British Beekeeper's Association which, in a section on preparation, instructs beekeepers to do the following after putting honey into jars:

Bottle into pre warmed jars
Heat to 60-62°C for ¾ to 1 hour in water bath after securing lids to remove final crystals and pasteurise


Then, in a later section on spoilage:

Yeasts are everywhere where honey is, it is impossible to remove them but pasteurisation kills them.
Commercially: raise the temperature to 71°C then cool rapidly
Non-commercially: raise the temperature to 60° for one hour


When this has been brought up on this forum before nobody admitted they did any of the above. Yet it is easy to see how the judge could have got the impression this was a wide spread practise even amongst amateur beekeepers.

The BBKA need to review the material they are putting out.

The judge brought up the example of raw milk, but strangely didn't explore why this labelling was necessary. A consumer expects a product labelled as 'milk' to be pasteurised. That is why there needs to be a 'raw milk' label.

Does the average consumer expect honey that is labelled as solely 'honey' to be pasteurised? I would argue not. This is presumably what the ACTSO guidance says too. We have this quote from the guidance:

These products should be referred to as Pasteurised Honey (Annex Vi of EU Regulations 1169/2011) in order to distinguish it from un- pasteurised honey, to prevent the consumer being misled (Annex VI and Article 7 of EU Regulation 1169/201 1)

In case you are wondering, Annex Vi of EU Regulations 1169/2011:

The name of the food shall include or be accompanied by particulars as to the physical condition of the food or the specific treatment which it has undergone (for example, powdered, refrozen, freeze-dried, quick-frozen, concentrated, smoked) in all cases where omission of such information could mislead the purchaser.
 
Non of my set goes above 42c during melting for jarring up, the higher glucose honies tend to need 42c but the fructose need only 35- 38c.
 
Non of my set goes above 42c during melting for jarring up, the higher glucose honies tend to need 42c but the fructose need only 35- 38c.
I always struggle to decide the best temperature for my cabinet; 42C for a shorter time or eg 38C for longer. Obviously the honey takes a while to reach those temperatures too. 🤔
42C could still be considered "higher than natural", though a bee in flight can be quite warm.
 
Non of my set goes above 42c during melting for jarring up
Which would fail the temperature threshold for raw honey according to Black Mountain Honey's 2022 petition:

Allow honey produced in a certain way to be sold as "raw honey"
The UK Government should allow honey to be sold as "raw honey" when it is unpasteurised and not heated above 40c.


That got 307 signatures, so there is hardly a big clamour for this.

Lawrence/BMH writes: The term 'raw' is a well recognised and understood by the consumer and I believe it would be sensible to allow people trading in honey to label their honey "raw" to distinguish products produced in this way from other honey.

Yet is well understood? If honey is not heated above 40C then it can't be pasteurised, so any references to pasteurisation are unnecessary and confusing.

Incidentally, the honey regs specify a maximum of 45C to aid pressing honey. What temperature is allowed for raw heather honey?

His own definition doesn't include any mention of filtering, yet unfiltered is a widely expected requirement of 'raw honey'. Perhaps writely he assumes all UK/EU honey should already be unfiltered according to the honey regs. If honey has been filtered so that pollen is being removed it should be labelled as 'filtered honey'.

Odysea claim their honey is raw because it is only sourced from one beekeeper. Their honey comes from all over Greece, so I doubt that one beekeeper is personally taking off every super. The honey from different regions is blended together, I think it is really questionable that this can be called raw.

I see Lawrence has started using again the word raw on his website. He uses it on the Borage honey he has bought in. That doesn't match Odysea's definition.

It would be ridiculous to call soft-set/creamed honey as raw, but I see online people do sell raw soft-set. Creamed: the honey has had the cr@p beaten out of it. Soft-set: been subjected to a series of controlled temperatures plus seeding with fine crystals.

As far as I can see, if you absolutely must put a definition on raw honey, the only sensible definition is to say raw honey has not been artificially heated at all.
 
As far as I can see, if you absolutely must put a definition on raw honey, the only sensible definition is to say raw honey has not been artificially heated at all.
So you call it unheated honey.
 
He knew about hmf and storage time: paragraph 8 "a maximum level of hydroxymethylfurfural (HMF), a chemical formed over time and much more quickly if the honey is heated"

What he possibly doesn't know is (I think I have this correct) there is a surplus of honey on the market at the moment so the cheapest honey has most likely been stored for years.

No mention at all of counterfeit honey. We also don't have pollen analysis of the honeys.
He would only "know" what was presented in evidence.
 
Was that a bald instruction? Or a more nuanced conversation? Did you learn anything about their thinking?
He checks our labeling on his yearly inspections. Approx 2 years ago he commented that he was happy with our labels, and then brought up his (and his departments) dislike of using "raw" in the description of the honey, saying that they are encouraging local beeks not to use the word. Apparently they were in discusion with other councils trading standards to prohibit the use of "raw" in the honey labels.. his comment was... if you class your honey as raw, you may be suggesting that other honeys have been "processed" in some way. When I was recently reported for adding sugar to my honey part of the complaint was that I had "reprocessed" the honey by adding sugars to it.
 
This debate about raw is a beekeeping irrelavance ..it's only amongst beekeepers that it is perpertuated - the public don't give a hoot about the legality, or not, as the case may be. They just see a term/description which means something to them and recognise the product for what it is. Quality honey that is neither blended nor unduly processed ... if you decry raw then, be warned, another word or phrase could replace it - be careful what you wish for,

The HLR is clearly not sufficiently definitive, as demonstrated by the Court case where the judge left an open goal. My view - those that want to describe their product as raw should be permitted to get on with it without the continual jibes and criticism from those who prefer not to. There are good marketing and public perception reasons to seek to differentiate the untreated, unprocessed honey which most of us purport to sell from industrially processed, pasteurised and fine filtered stuff you will find sold in some places. Until such time as a clear ruling is made (and that's not going to be any time soon) I can't see why some beekeepers are objecting ... if they fear that it's a slur on their product which is just labelled honey - if it matters that much - change your labels rather than seeking to make others conform to your perception of what the label should say.

It's a storm in a honey jar ...
 

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