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Here is the actual FDA (US Food and Drug Administration) document:
http://www.fda.gov/food/guidancereg...ryinformation/labelingnutrition/ucm389501.htm

A key point to keep in mind is that this is a "guidance" document. This is one of the lead paragraphs ...

Our guidance documents, including this guidance, do not establish legally enforceable responsibilities. Instead, guidance documents describe our current thinking on a topic and should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The use of the word should in agency guidance documents means that something is suggested or recommended, but not required.

http://www.fda.gov/food/guidancereg...ryinformation/labelingnutrition/ucm389501.htm
So this means .... nothing ... unless the FDA takes additional future steps to make this a legally enforceable standard.
 

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So this means .... nothing ... unless the FDA takes additional future steps to make this a legally enforceable standard.
No it does mean something. This is exactly how the process works. Draft guidance, 60-day comment period, final guidance, then entry into the FDA Food Code.

It also says:
Although you can comment on any guidance at any time (see 21 CFR 10.115(g)(5)), to ensure that the agency considers your comment on this draft guidance before it begins work on the final version of the guidance, submit written or electronic comments on the draft guidance within 60 days of publication in the Federal Register of the notice announcing the availability of the draft guidance. Submit written comments to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. Submit electronic comments to http://www.regulations.gov.[SUP]3[/SUP] All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register.

So start commenting.
 

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This is a very hard rule to enforce unless the contamination is gross. The reason is there is only one chemical analysis, that I know of, that is applicable to detect contamination with non honey sweeteners such as high fructose corn sugar or cane sugar. And, that analysis is very high tech.

Any sugar you feed bees is going to be converted to glucose and fructose by the bees. After all, most nectars consist of large amounts of sucrose with only some glucose and fructose. The bees process nectars by adding an enzyme named invertase that splits the sucrose into glucose and fructose. To the bee it makes no difference if the sugar came from a bag or a flower. So, to enforce this regulation FDA has two choices. They either have to find physical evidence that you purchased sucrose, inverted it yourself, or purchased high fructose corn syrup and added either to the honey as you had no other use for the stuff or they have to provide some chemical evidence to show the honey is contaminated. The former is pretty hard to prove unless you can get an employee to testify. Just purchase records are likely not enough.

The only route I know of to gain chemical evidence involves doing carbon isotope analysis. All the carbon dioxide in the air that plants use to make sugars contains about 1% carbon 13 and 99% carbon 12 naturally. During biosynthesis this ratio is changed a small amount. And plants use two different biosynthetic pathways. These two different biosynthetic pathways change the ratio of carbon 12 to carbon 13 by a small amount, but significantly differ in the amount they change that ratio. One is called the C3 pathway and the other the C4 pathway. Most flowering plants use the C3 pathway. Corn and sugar cane use the C4 pathway. Thus, it is fairly straightforward to look at pure cane sugar and pure honey and know that one came from mainly the C4 path (the cane sugar) and the other from the C3 path. Straightforward that is providing you have the proper analytical equipment which few labs have and the proper skills to do the analysis. Few have the skills to do such an analysis even if they have the equipment.

Say you have a mix of pure honey and glucose and fructose derived from cane sugar in a ratio of 95% honey to 5% stuff derived from cane sugar. In such a case the change in the carbon 13 to carbon 12 ratio is simply too small to be evidence. After all, the bees could easy have gathered some nectar from C4 pathway plants. So, the FDA rule is not going to impact contamination due to inadvertent contamination by minor amounts of non nectar sugar. It is only going to catch major contaminations that are done on purpose.

This rule really has been in effect as long as I can remember. All FDA is doing here is formalizing a rule that has long existed. I suspect the main purpose of the rule is to put large honey packers on official notice that FDA intends to watch imported honey more carefully than they have in the past. Personally, I am fine with that. If it is labeled pure honey it should be pure honey within reason.
 
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