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Re: FDA ruling it the works?

I would not count on it, They are bureaucrats,, reminds me of the Governor singing that little song about loving to side step! In the movie best little ***** house in Texas
 

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Re: FDA ruling it the works?

Looks like lip service to me. There is bound to be some sugar or corn syrup in most honey even if it isn't done on purpose. Seems to me there should be a PPM threshold.
Labeling guidelines do not cover chemical contamination, if that is what you mean by "PPM".

It looks like a good guidance to me. Why wouldn’t we want to know if you are purchasing "flavored honey" or a "blend of corn syrup and honey"? I also don’t see any reason why the guidance would not be made final, eventually.

Anyway, it says the draft is open for comments. So everyone who has an opinion on the subject had better be making comments. This isn’t one of those White House petitions or a Facebook "Like" campaigns. Now is the time to speak up.
 

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Discussion Starter #4
Re: FDA ruling it the works?

Now is the time to speak up.
It is past the deadline. What goes on a food label has lots to do with the amount that is present before it has to appear on the label. Sugar and corn syrup is bound to be in a lot of honey because of the practice of feeding bees. A certain amount would be acceptable before it has to be labeled.
 

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Re: FDA ruling it the works?

No, its not! :no:

The FDA document was published in the Federal Register 4/9/2014. The official comment period extends 60 days forward from that date!

https://www.federalregister.gov/art...ling-of-honey-and-honey-products-availability

Exactly. Everyone on BeeSource keeps whining and complaining about honey labeling, or lack thereof. Government is trying to do something so now is the time to step up and be heard. People can be pessimistic about the situation all they want, but this is how the system works.

Write a comment letter and send it in.
 

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Re: FDA ruling it the works?

Exactly. Everyone on BeeSource keeps whining and complaining about honey labeling, or lack thereof. Government is trying to do something so now is the time to step up and be heard. People can be pessimistic about the situation all they want, but this is how the system works.

Write a comment letter and send it in.


Here's the contact info. I'm sending a letter tonight!

Submit electronic comments on the draft guidance to http://www.regulations.gov.

Submit written comments to:
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852.
 

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Re: FDA ruling it the works?

Here's the contact info. I'm sending a letter tonight!
You could draft one letter for several people to sign if you could get enough people on Beesource to agree......

Oh wait....:rolleyes:
 

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Discussion Starter #9
Re: FDA ruling it the works?

but this is how the system works.
If the comment came from Mrs. Obama the comment would find it way to an important person. If the comment comes from Brian Cardinal it is unlikely it will get past the teenager who may read it. Bureaucracy already knows it is a bureaucracy.
If the FDA wanted to limit adulterated honey coming in to this country they would put a number on what is adulterated. They have no problem putting numbers on industry to clearly define what is adulterated and what is not. If it is one thing I learned about the FDA they are black and white, no sign of grey.
 

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Re: FDA ruling it the works?

Nabber86 said:
Exactly. Everyone on BeeSource keeps whining and complaining about honey labeling, or lack thereof. Government is trying to do something so now is the time to step up and be heard. People can be pessimistic about the situation all they want, but this is how the system works.

Write a comment letter and send it in.
Amen to that.
 

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Re: FDA ruling it the works?

If the comment came from Mrs. Obama the comment would find it way to an important person. If the comment comes from Brian Cardinal it is unlikely it will get past the teenager who may read it. Bureaucracy already knows it is a bureaucracy.
If the FDA wanted to limit adulterated honey coming in to this country they would put a number on what is adulterated. They have no problem putting numbers on industry to clearly define what is adulterated and what is not. If it is one thing I learned about the FDA they are black and white, no sign of grey.
B..b..but, they wont listen to me, so I am not going to comment. Waaah, Waaah, Waaah! :cry:

As usual, you don’t understand what the FDA guidance is, or how it works. It has absolutely nothing to do with the levels of other ingredients in honey; it just says that it must be labeled correctly. If someone in China wants to export a mix of HFCS and honey, the guidance says that it can’t be labeled as "honey"; and the 2 ingredients must appear on the label, in order of content. If you want to bottle “Cherry Blossom Honey” and it happens to be light red and contains cherry extract for flavor, the label will have to say something like “A product containing honey, food coloring, and natural flavors”.

Why is this not a good thing? It is not the FDA’s job (right now) to specify or analyze for levels of other ingredients. Once the guidance is in place, then they can go after people who do not follow the guidance. But then it becomes an enforcement action, which is a completely different thing.

It is a process , it takes time, and this is the first step.
 

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Discussion Starter #12
Re: FDA ruling it the works?

If someone in China wants to export a mix of HFCS and honey, the guidance says that it can’t be labeled as "honey"; and the 2 ingredients must appear on the label, in order of content.
B..b..b but if an American beekeeper has .01 grams of corn syrup in a 55 gal drum of honey because the bees moved it to the supers he would have to label both ingredients. Right? You have to have a number or you cannot enforce anything.
 

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Re: FDA ruling it the works?

B..b..b but if an American beekeeper has .01 grams of corn syrup in a 55 gal drum of honey because the bees moved it to the supers he would have to label both ingredients. Right? You have to have a number or you cannot enforce anything.
As I mentioned earlier, they are not at the enforcement stage right now and they don’t need any numbers to start the labeling guidance process.

The definition of how honey purity is defined or tested for is a completely different subject and is not on the table for now.

None of this stops you from sending on a comment lettter. Are you going to send in your comments, or just sit there and whine?
 

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Re: FDA ruling it the works?

You could draft one letter for several people to sign if you could get enough people on Beesource to agree......

Oh wait....:rolleyes:

OK. Letter sent!

I think everyone should write a different version of their own letter. Keep it short. For those who just want to copy and paste something or want a place to start, here you go:


Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852.

Re: Proper Labeling of Honey and Honey Products

I am writing in support of the current draft of Proper Labeling of Honey and Honey Products. As a beekeeper I am concerned with the blatant misuse of the term “Honey” and would like to see these stricter guidelines in place. As a consumer I am concerned that I don’t know when I am buying 100% honey or just something that looks like honey or only has it as an ingredient.

Thank you for your consideration in this matter.
 

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Re: FDA ruling it the works?

BEE carful what you wish for. They come out with a rule requiring all Honey be offically tested and they put all the little guys out of business... Don't expect the government to do it correctly and protect the little guy....
 

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Discussion Starter #17
Re: FDA ruling it the works?

The definition of how honey purity is defined or tested for is a completely different subject and is not on the table for now.
Which means the guidlines are meaningless.
It is guidance only... not mandatory.
Which means the guidlines are meaningless. Not worth the cost of writing on the paper. Government waste.
 

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Re: FDA ruling it the works?

It is guidance only... not mandatory. Put what you want on the lable. No change.
You guys couldn’t be more wrong. The final guidance gets written into law. That’s why you see nutrition and ingredients labeling on all manufactured food products. Do you think those labels appearing on products in the grocery store are there because the government "guided" them?

I see people are confused by the term “guidance”. Let me explain it this way, there are thousands upon thousands of government “Guidance Documents”. The guidance documents per say are not law. Now here is the tricky part, so pay attention. When they write the law, they reference the guidance document(s). So the law will read something like this, “Honey and honey products will be packaged and labeled in accordance with the Proper Labeling of Honey and Honey Products Guidance. That makes it legally enforceable. Why do they do it this way? BECAUSE IT IS EASIER TO AMEND, REVISE, AND UPDATE THE GUIDANCE THAN IT IS TO RE-WRITE THE ENTIRE xxxxx LAW.

Guidances are continually updated as new information is learned. Get it?
 

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Re: FDA ruling it the works?

If the comment came from Mrs. Obama the comment would find it way to an important person. If the comment comes from Brian Cardinal it is unlikely it will get past the teenager who may read it.
It may get more notice than you think. After all they, unlike us, are unfamiliar with BC's opinions.
 

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Re: FDA ruling it the works?

So Ace, are you going to write a comment letter?




cg3 - I just realized your signature tag and had to google it. Good one!:lpf:
 
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