My own definition of some of my honey for which I have complete control over the production and harvesting is, as I said above, "(my) own, unadulterated, non-heat-treated, (and) unfiltered."
I wouldn't sell it as "raw" or even describe it verbally or in any way try to pass it off under that descriptor. But I think it's a bit blinkered and pedantic to tell oneself that because there is no
legal definition for raw honey, that makes it impossible to be a raw product. Raw food products are always ones that are unprocessed in any way other than cleaning of impurities that are not part of the nutritional value of the food.
In this, I think I'm saying the same as
@rdartington, but in a less concise way.