The European Commission's report From the hives' (2023) – in exposing the outcome of the works she coordinated with hers Joint Research Center (JRC) and the European Anti-Fraud Office (OLAF) - offers an ambiguous representation of the monitoring carried out between November 2021 and February 2022 on a small sample of honey imported from non-EU countries (1,2). An insight.
1) Miele, EU rules
Production, processing and packaging of honey are subject to the hygienic-sanitary requirements referred to in Hygiene 2 Regulation (EU) No. 853/04. The marketing standard – composition and parameters of purity, commercial categories, specific labeling requirements – are instead defined in Honey Directive No 2001/110/EC, now under revision (3,4). Honey, in essence:
– can be distinguished according to origin (flower, nectar, honeydew honey), (5) and production method (comb honey, drained, centrifuged, pressed, filtered, industrial)
– is mainly composed of sugars (glucose and fructose, about 80%) and other substances (e.g. organic acids, enzymes, solid particles). Traces of pollen possibly left over by bees do not qualify as ingredients
– color, aroma and flavor depend on the botanical species of origin, as does the consistency (fluid, dense or crystallized), a function of the glucose/fructose ratio,
– may not contain any ingredient other than honey or any additives or foreign substances (including sugars)
– it must not have anomalous smells and tastes, fermentation processes in progress, artificially regulated acidity and/or have undergone high-level heat treatments such as to denature all the enzymes naturally present (e.g. diastase).
2) From the hives. Brief monitoring of honey imported from outside the EU
The European Commission, DG SANTE (Directorate General for Health and Food Safety), coordinated a brief monitoring action aimed at assessing the incidence of non-compliance with the 'honey directive' and any food fraud - in particular, through the addition of sugar syrups - only on honey imported from non-EU countries.
Such an action involved the authorities of some Member States, EU Food Fraud Network, Joint Research Center (JRC) and the European Anti-Fraud Office (OLAF). The monitoring action, named ' From the hives', was divided into the following three phases.
2.1) Sampling and controls
Between November XNUMX and February XNUMX , sixteen Member States, plus Norway and Switzerland, carried out random sampling of 2021 consignments of imported honey at EU borders. Of these, 2022 samples (320%) were reported as 'non-compliant' with the requirements of the Honey Directive.
The controls involved 123 honey importers in the EU, 70 of whom were 'reported' for importing 'suspicious' consignments, for hypothetical adulteration with extraneous sugars. 63 of the 98 importers subject to checks, according to the authorities, would have handled at least one shipment of suspect honey.
2.2) Traceability
The participating countries collected information on the destinations of imported honey subject to controls. In turn, the Commission collected data relating to traceability from exporters of third countries and importers into the EU, also making use of the TRACES system.
2.3) Investigations
The authorities of the States involved, with the cooperation of OLAF, then carried out investigations on the stages of procurement, processing, blending and packaging of the various consignments of imported honey.
The investigations however, did not allow to obtain reliable results, beyond the few cases in which it was possible to ascertain the existence of food fraud. As in Bulgaria, where the checks made it possible to verify the addition of sugar syrups to imported honey, or the subtraction of pollen residues to mask the botanical and geographical origin of the honeys.
The unreliability of controls is due to the absence of harmonized tools and analysis methods to identify adulterations due to the addition of extraneous sugars. Analyzes carried out with different methods can therefore lead to contradictory results on identical samples.
3) From the hives. The analytical methods
JRC used several analytical methods to identify honeys suspected of adulteration with sugar syrups:
– Elemental Analyser/Liquid Chromatography – Isotope Ratio Mass Spectrometry (EA/LC-IRMS). Method based on the difference between the 13C/12C carbon isotopes of proteins and sugars. Widely used in the past, EA/LC-IRMS is considered one of the best methods for identifying corn or sugar cane starch syrups and also other sugary syrups (e.g. rice, wheat or sugar beet),
– High-Performance Anion Exchange Chromatography – Pulsed Amperometric Detector (HPAEC-PAD) identifies the presence of polysaccharides with a degree of polymerization (DP) ≥10
– Liquid Chromatography – High Resolution Mass Spectrometry (LC-HRMS) identifies oligosaccharides with DP < 10 and ≥ 6, as well as others marker such as 2-acetylfuran-3-glucopyranoside (AFGP) and difructose anhydride (DFA)
– Proton Nuclear Magnetic Resonance (1H-NMR) Spectroscopy. It allows to identify the mannose, which one marker, as well as profiling the honey on the basis of standards defined by private laboratories.
Criteria used by JRC to identify honeys as 'suspect', applying the aforementioned methods, were:
– exceeding the thresholds defined for the analyzes carried out with the EA/LC-IRMS, o
– oligosaccharides with DP between 6 and 9, identified with C-HRMS, o
– polysaccharides with DP between 10 and 19, identified by HPAEC-PAD, o
– mannose identified by LC-HRMS and confirmed by Nuclear Magnetic Resonance (NMR), or
– DFA or AFGP identified by LC-HRMS.
The combination of these methods can allow to identify, through various marker, the presence of elements generally extraneous to the natural composition of honey. However, none of these methods allows to measure the quantity of these elements and their presence is not always due to adulteration.
4) AAA uniform method of analysis wanted
'The Commission may adopt methods to permit verification of compliance of honey with the provisions of this Directive (…). Until the adoption of such methods, Member States shall, whenever possible, use internationally recognized validated methods such as those approved by Codex Alimentarius to verify compliance with the provisions of this Directive'('Honey Directive' No 2001/110/CE, article 4).
Twenty-two years after the entry into force of the 'Honey Directive' Member States – pending a validated and uniform method of analysis of honey – continue to perform pour-pourri of analyzes not sufficient to identify with certainty the various possible adulterations. And it is on these that the report is based ' From the hives' (2023), whose results are therefore unreliable.
5) Coordinated plan of controls on honey, 2015-2017
Way back in 2015 the European Commission had published a recommendation on the coordinated program of official controls, pursuant to reg. (EC) 882/2004). The coordinated control plan on honey – the only one no longer available on EUR-Lex (6) – stood out from the ambiguous operation ' From the hives', in several respects:
- expressly referred to the Official Controls Regulation (EC) No 882/04, instead of generics'samplings' and 'investigations’,
– the official controls concerned all types of honey, produced in the EU and imported, without discriminating against products on the basis of origin or assuming (falsely) a priori that adulterations only take place in non-EU countries
– all 28 Member States (instead of just 16 countries), plus Switzerland and Norway, were involved. With the aim of analyzing an at least reasonable number of samples (2.310 samples. Objective achieved at 98%, with 2.264 samples). (7)
5.1) Quality of official controls
In 2015-2017 the checks were not limited - as in 2021-2022 - to the search for hypothetical adulterations with 'foreign sugars'. The coordinated plan of official controls carried out in 2021-2022 has in fact considered, in a much wider geographical context of production and marketing, any possible non-compliance. Including those on the botanical and/or geographical origin of honey, imported andMade in EU'. And for this purpose different types of analyzes had been conducted, in addition to LC-IRMS or EA-IRMS:
– sensory, to evaluate honey characteristics that cannot be measured with the available instruments (e.g. anomalous smell, color, taste)
– microscopic, to verify the botanical and geographical origin of the honeys through the pollen residues. In addition to possible traces of filtrations, dilutions, contaminations or other non-conformities
– electrical and diastasis conductivity, which provide marker the quality of the honey and possible indications of adulteration
– determination of the content of various sugars through gas chromatography (GC) or high performance liquid chromatography (HPLC).
The 'suspicious' honeys (1.200 samples, equal to 53% of the total) were sent to the JRC-IRMM (Joint Research Center – Institute for Reference Materials and Measurements) and subjected to further analysis by methods such as EA/LC-IRMS and NMR. As a result of these checks, only 14% of the total honey samples (European and imported) taken were found not to comply with the requirements of the 'Honey Directive'.
5.2) Methods of analysis. JRC support
The results of the analyses performed by the JRC in 2015-2017 were reported in a report currently not accessible on the European Commission website. (8) JRC had, inter alia, considered both the adulterations of honey (European and imported) with the addition of syrup, and indirect adulterations. That is to say the practices of administering sugar syrups to bees during the period of nectariferous flow, in the absence of any justification related to animal health and welfare.
The isotope determination had been considered an 'excellent' method to identify sugars coming from syrups, as also confirmed in a subsequent report. (9) Without neglecting the sensitivity of the method, in relation to the various plants (C4,C3), and the importance of the EA/LC-IRMS method for identifying the syrups of some plant species. The di- and tri-saccharides were then considered among the most important marker to define with this system (not yet validated).
Recommendations back then, by JRC – which is not an official laboratory – were:
– harmonize the analytical methods to be submitted for approval by the International Honey Commission (IHC) or an equivalent body. The 'Harmonized Methods of the International Commission', please note, are the basis of the revision of the standard Codex Alimentarius (10)
– develop a biobank of honeys, sugar syrups and bee feed products, in order to cover the wide variety of honeys currently available on the European market
– insert in the biobank a database of samples, analyzed through a validated EC/LC-IRMS or other equivalent methods to define the purity criteria and establish the natural variability of the different honeys, to be stored in such database centralized reference
– validate the emerging analytical methods, following their verification with the data available in the biobank and evaluations by committees of experts, in view of further developments.
6) Contributions of stakeholders
FEEDM, European Federation of Honey Packers and Distributors, represents many importers and packers of honey in the EU. One of his technical working groups is working on the identification of alternative methods to identify the exogenous sugars present in honey, following adulteration. FEEDM and its working group - acknowledging that the most used analysis methods are not yet harmonised, validated and accredited - have offered to cooperate with the JRC to address the problem it reported as early as 2016. (11)
Hungarian citizen Zoltán Tóth presented a petition to the European Parliament (No 0432/2016), aimed at interrupting the marketing in the EU of honey products manipulated with macro-reticular synthetic resins, which release particles that contaminate honey and can represent a health risk, due to the presence of styrene copolymers and divinylbenzene granules, considered mutagenic and carcinogenic. (12)
The petition of the citizen – who has also requested to finance tests to be carried out at EU borders – seems to have surprised the European Commission. Which, in declaring itself unaware of the reported practice and recalling the execution of the 2015-2017 control plan, limited itself to reporting that only the Member States competent authorities can identify non-compliance following official controls, and possibly report them on the RASFF. (13)
7) Official Control Regulation
Official Controls Regulation (EU) No 2017/625 provides for specific measures for cases of 'suspected non-compliance' on products that fall within its scope, including honey. Among these, we highlight:
– the duty of the competent authorities to carry out official controls to confirm the suspicion or demonstrate its groundlessness (art. 65.1)
– in case of suspicion of food fraud or violation of the applicable rules by an operator, following official controls, the competent authorities can intensify official controls on consignments with the same origin or use (art. 65.4).
The requirements and criteria to apply to sampling methods, the designation of official laboratories for the execution of official controls and the analyzes performed by them are defined in Reg. EU 2017/625 in Chapter IV (art. 34, 37).
8) Provisional conclusions
Sensational messages who followed the publication of the report ' From the hives' – where the European Commission reported to the '47% of non-compliance and adulterations' in imported honey – are baseless. And they unfairly put non-EU imported honey on which food security in the Old Continent depends in a bad light. food security (14)
Uncertain data are based on a number of samples that borders on the ridiculous (320), certainly not representative of a segmented and complex market. These data were taken from a limited number of Member States and analyzed, only in part, with a variety of methods without scientific or official validation. (15)
In all cases, the analyzed honeys were considered as 'suspect'. Without any certain proof of adulteration, apart from the few cases where investigations have shown possible indications of food fraud. In this regard, we note one of these, in Italy, where the accusatory theorem has been denied by the revision analyses.
Dario Dongo
Footnotes
(1) European Commission (2023). EU Coordinated Action 'From the hives' – Sampling, investigations and results. Publications Office of the European Union. https://food.ec.europa.eu/system/files/2023-03/official-controls_food-fraud_2021-2_honey_report_euca.pdf
(2) European Commission (2023). EU Coordinated action to deter certain fraudulent practices in the honey sector. JRC Publications Repository
https://publications.jrc.ec.europa.eu/repository/handle/JRC130227
(3) Directive 2001/110/EC, concerning honey. Consolidated text on Eur-Lex http://data.europa.eu/eli/dir/2001/110/2014-06-23
(4) Dario Dongo, Alesaandra Mei. Honey, fruit juices, jams and marmalades, dehydrated milk. Proposals for the reform of marketing standards in the EU. GIFT (Great Italian Food Trade).
(5) Honeydew honey is mainly obtained from substances secreted by sucking insects (hemiptera) found on living parts of plants or from secretions from living parts of plants. According to the circular July 12, 2007, n. 3, in Italy it is also known and marketable as 'forest honey', only if it has been obtained from woodland essences. If the origin is from herbaceous species, the honey can only be called 'honeydew honey'
(6) See https://food.ec.europa.eu/horizontal-topics/official-controls-and-enforcement/legislation-official-controls/coordinated-control-programmes_en. Document 12.3.15 (C(2015) 1558 final), which should report the results on the coordinated control plan on honey, is missing
(7) European Commission (2016). Coordinated control plan to establish the prevalence of fraudulent practices in the marketing of honey – Outline. https://food.ec.europa.eu/system/files/2016-10/official-controls_food-fraud_honey_control-plan-outline_201512.pdf
(8) European Commission (2016). Scientific support to the implementation of a Coordinated Control Plan with a view to establishing the prevalence of fraudulent practices in the marketing of honey – Results of honey authenticity testing by liquid chromatography-isotope ratio mass spectrometry
(9) European Commission (2020). Determination of 13C/12C ratios of saccharides in honey by liquid chromatography – isotope ratio mass spectrometry. Results of an interlaboratory comparison. https://knowledge4policy.ec.europa.eu/sites/default/files/honey_pt_report_lc-irms_va.pdf
(10) International Honey Commission (2009). Harmonized Methods of the International Honey Commission https://www.ihc-platform.net/ihcmethods2009.pdf
(11) FEEDM. The need of harmonization of analytical methods for honey authenticity. 09.05.23. https://www.feedm.com/download/f.e.e.d.m.-statement-on-harmonisation-of-analytical-methods
(12) European Parliament. Petition no. 0432/2016, presented by Zoltán Tóth, a Hungarian citizen, on the cessation of the sale of honey products manipulated with macro-reticular synthetic resins which constitute a danger to the health of European consumers. https://www.europarl.europa.eu/doceo/document/PETI-CM-605989_EN.pdf 8.6.20
(13) The 'General Food Law ' on closer inspection it provides for the possibility for the European Commission to consult EFSA on emerging food safety risks and other issues within its competence (EU Reg. No. 178/02, art. 29,31,34). How it should have done - and has not done - to verify the validity of the scientific methods for the analysis of the risk linked to cross contamination of foods with 'traces' of allergens. See Dario Dongo. Allergens and RASFF, European blackout. GIFT (Great Italian Food Trade).
(14) DG SANTE of the European Commission, in the report ' From the hives', thus followed up with the appellants fake news on honey from the People's Republic of China, the world's leading producer of bee nectar, and from other BRICS countries. See Dario Dongo. Counterfeit Chinese honey, fake news. GIFT (Great Italian Food Trade).
(15) The same Joint Research Center expressed doubts, at least in part, about the validity of some methods (such as isotopic determination, which JRC had also previously supported)
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
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