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  • Writer's pictureIan Fletcher

The Blundered Mānuka Honey Definition


While the decision from the Ministry for Primary Industries’ (MPI) to stand fast on their mānuka honey definition has drawn howls of protest from Northland, there appears to be very little noise from other areas of beekeeping – that’s a big mistake writes Ian Fletcher as the current standard risks exploiting smaller producers, misleading consumers and failing Māori.

Ian Fletcher. “MPI have managed to win a nasty trifecta: making serious errors of science, of policy, and of politics” with the latest mānuka honey reassessment.

MPI’s decision not to propose changes to the existing mānuka honey export definition is more than a mistake; it is a blunder. It leaves MPI’s reputation in tatters in many parts of the beekeeping and honey industry, and looks to have gratuitously favoured big operators over small, at a time when the industry is under serious economic pressure.

Before saying why I think that, I should note that I don’t usually write on beekeeping – I don’t keep bees or deal in honey, and I generally think it’s better to write about things I know. But so many people have expressed reactions to this decision, and I think it so ineptly handled, that I’ve decided to tackle it directly.

As regular readers will have detected, I’m no fan of MPI. This time, I think they’ve managed to win a nasty trifecta: making serious errors of science, of policy, and of politics. All at once. Maybe they have more talent than I thought. Let’s consider each in turn, and then look at the bigger picture.

Science – Fail

On science, the MPI report (and the accompanying review report) makes clear that the evidence they had available was incomplete and not really fit for purpose. But rather than go and get better evidence (as their political commitments and policy responsibilities would have required), they drew the comfortable conclusion that inadequate evidence was itself enough to draw a meaningful conclusion. This is confirmation bias (looking to prove what you already believe). It compounds the existing bias in the data used when the definition was first developed, as that was based then on the provider’s assessment of samples, so it confirms the beliefs of the ‘original’ sample providers. And the existing definition was in part a result not of any science, but of negotiation between MPI and NZ Beekeeping Inc (who had brought legal proceedings that looked likely to succeed).

Secondly, on the question of blending, the conclusion is that blending to create qualifying mānuka honey was “statistically unlikely”. Wrong tool for the job here: this is not a statistical question, as blending events are not independent of each other (like coin tosses or dice throws). Rather, blending is and economic question: it is commonplace as honey is put together for the market, so the real question is about blending for the purpose of creating a product that gains value as a result of the definition, but at the expense of either consumers (who pay more than they should) or suppliers (who receive less than they should). There is widespread belief that both these outcomes are occurring. That’s a charge that deserves a serious look, not superficial dismissal.

Policy – Fail

On policy, MPI has taken a fragmented approach: the whole industry needs to be regulated as a coherent supply chain, so as to ensure that it comes through the current downturn without unnecessary damage. This is especially important as there are positive spillovers for the rest of the economy and environment that need to be protected: the pollination service that managed bees provide, and the ready-made biosecurity network that skilled beekeepers provide. Both are at more risk than they need. Tackling the mānuka definition in the absence of a coherent policy towards the whole industry is damaging. MPI may say grandly that the market will provide; they may not have noticed that the rest of the world has moved towards using regulation to support and nurture important industries, i.e those that offer environmental and economic benefits.

Politics – Fail

And on politics, MPI made promises they haven’t kept. Two issues are important: regional differences in the way honey is performing against the definition (especially in Northland), and blending. In agreeing to look at these issues, MPI implicitly promised to take them seriously, and to at least consult. It looks like neither has been taken seriously, and rather than consult, a fait accompli has been presented. Māori groups involved in beekeeping in Northland may feel especially let down: claims about te Tiriti partnership look to me to have been just brushed aside. This cavalier approach will alienate many, and undermine confidence further. Doing it in the run-up to an election looks tin-eared and plain dumb.

Doing Actual Harm – Pass

So, overall? A missed opportunity to demonstrate a more coherent approach, integrating science and policy to show understanding and support for an industry that is struggling, having to change rapidly, and yet plays an important wider role in the environment and economy.

Is actual harm being done? I think so: firstly, consumers. There has long been a belief that the reason plans to have a domestic (ie within New Zealand) definition of mānuka honey were abandoned was because the multifloral category would not fit within the Fair Trading Act rules on misleading consumers. Sticking with this definition means that belief is neither confirmed, nor firmly refuted, nor effectively fixed by amendment to the definition. That will sap confidence over time, potentially in export markets. And if consumers are being misled, that in unconscionable.

Secondly, producers. If larger producers are able to buy good honey at low-ish prices, blend that down to just meet the definition and sell at a profit then the smaller producers suffer. Does that matter? Yes: we need smaller producers to maintain skills, industry resilience, provide pollination, and to underpin a response to the inevitable biosecurity emergencies of the future. An industry dominated exclusively by large producers will be de-skilled, excessively focused on mānuka, and may be so highly geared (ie have borrowed against assets) to be financially vulnerable when interest rates rise (as it seems they do). And this sort of exploitation of smaller producers is an abuse of market power, and should be looked at by the Commerce Commission.

Finally, regional producers, including Māori in Northland and elsewhere. Treating these groups with contempt (which is how it looks, whatever the science) is just plain wrong. But there is another point: these groups may be right, and there may well be significant regional differences in mānuka plants and how the resulting honey develops. We live in a long, thin country and latitude matters. Just saying the data wasn’t enough is no reason to stop looking.

Two out of 10, MPI, and that’s being generous. Do the exercise again, properly. And treat people decently. They deserve it.

Ian Fletcher is a former head of New Zealand’s security agency, the GCSB, chief executive of the UK Patents Office, free trade negotiator with the European Commission and biosecurity expert for the Queensland government. These days he is a commercial flower grower in the Wairarapa and consultant to the apiculture industry with NZ Beekeeping Inc.


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