Time Sensitive: Submit Comments on Draft Food Labeling Guidelines Impacting Honey Labeling

Why should you care about this?  If you sell honey you will need to ensure your honey is labeled properly after the deadlines in 2018 or 2019. Your commentary on FDA food labeling can influence labeling requirements if submitted prior to March 6th 2017.


  1. Please review the FDA’s draft food labeling guidelines relating to added sugars and submit your comments by March 6th, 2017 here-> https://www.regulations.gov/document?D=FDA-2016-D-4414-0002 
  2. Submit comments: click the “Comment Now”  blue button in top right corner of browser window at the link provided.

Need more info before you submit comments?

Below are some basics of the proposed regulation, and, you can read UC Davis Apiary Lab’s position  on the matter here , which offers some suggested language for your comment. UC Davis also  highlights some exemptions for small businesses (although the PSBA editor was unable to locate this exemption detail in the original documents- it may be there, just couldn’t find it).

The below bullets are excerpts and highlights from the FDA Q&A and Labeling Guidance documents. While, PSBA encourages you to read them yourself, they are lengthy, so we’ve pulled out some highlights for you if you like to get into the details.

CFR 21 Food and Drug Administration Subchapter B Food for Human Consumption

FDA Labeling Guidance information here and here


  • On May 20, 2016, the FDA announced the new Nutrition Facts label for packaged foods to reflect new scientific information, including the link between diet and chronic diseases such as obesity and heart disease. The new label will make it easier for consumers to make better informed food choices. FDA published the final rules in the Federal Register on May 27, 2016.  The two final rules published On May 27, 2016  related to the Nutrition and Supplement Facts labels:
  1. One final rule is entitled “Food Labeling: Revision of the Nutrition and Supplement Facts Labels” (81 FR 33742, “the Nutrition Facts label final rule”) and
  2. The other final rule is entitled “Food Labeling: Serving Sizes of Foods That Can Reasonably Be Consumed At One Eating Occasion; Dual-Column Labeling; Updating, Modifying, and Establishing Certain Reference Amounts Customarily Consumed
  • New labeling will be required on or after July 26, 2018 (and July 26, 2019 for manufacturers with less than $10 million in annual food sales). Certain foods must bear a nutrition label that meets new nutrition labeling requirements in 21 CFR 101.9 and 21 CFR 101.36
  • New labeling must declare the gram (g) amount of “added sugars” in a serving of a product, establishing a Daily Reference Value (DRV) for added sugars, and requiring the percent Daily Value (DV) declaration for added sugars. (See guidance documents for complete requirements)
  • Honey is being declared an added sugar and thus subject to the new labeling requirements:  The definition of added sugars includes sugars that are either added during the processing of foods, or are packaged as such, and include sugars (free, mono- and disaccharides), sugars from syrups *and honey*, and sugars from concentrated fruit or vegetable juices that are in excess of what would be expected from the same volume of 100 percent fruit or vegetable juice of the same type. The definition excludes fruit or vegetable juice concentrated from 100 percent fruit juice that is sold to consumers (e.g. frozen 100 percent fruit juice concentrate) as well as some sugars found in fruit and vegetable juices, jellies, jams, preserves, and fruit spreads.  For industry and those interested in the more technical version of the definition, please consult page 33980 of the Nutrition Facts Label Final Rule.