The Non-Compliance Conundrum

You might have seen it, unlabelled honey at the roadside stall or on the local Facebook market place. Some might be legitimately harvested, extracted and packaged, but there are a range of food safety rules to comply with and not all sellers have. What are the actual risks of this form of production and marketing activity to the wider apiculture industry though and should it be tolerated?

“Bootleg” honey – something the apiculture industry need worry about?

A proliferation of honey in New Zealand is proving difficult to sell – and it’s not just the commercial beekeepers and packers having trouble. Smaller producers must also look for a market in which to sell their honey. With hobbyist beekeeping popularity surging in recent years, the market place for the small seller is getting more competitive too.

Ashburton couple Darren and Mandi Webb are two beekeepers feeling the pinch in the market place. Their honey, labelled Mandi’s New Zealand Postcode Honey, is harvested from their 50 hives and marketed locally. However, they are growing increasingly frustrated by a range of other honeys in the Canterbury area being offered for sale that appear to be non-compliant.

“I have to pay fees, other beekeepers have to pay fees, and we must recoup them somehow,” explains Darren Webb.

“Then you have others who come along, unregistered, and sell it cheap as chips. It makes it hard on those who are honest.”

This season the Webbs’ honey was extracted and packed at a friend’s registered facility and, before next season, they plan to register their own property.

While some beekeepers, such as the Webbs, may feel aggrieved at the number of unlawful sellers, others around the industry say it’s a difficult situation to police, with no logical solution and that the industry should be careful about inviting greater than necessary scrutiny.

What are the rules anyway?

Rules around food safety are set in place by the Food Act 2014 and apply to anyone trading food in New Zealand. Administration of food safety issues in undertaken and thus “policed” by government body New Zealand Food Safety, a business unit of the Ministry for Primary Industries (MPI).

Comb, such as this, or liquid honey: it's all looking for a market and it's not all fully compliant with food safety regulations.

Any person trading honey, irrespective of the amount, should lawfully obey the Food Act. Trading covers a wide range of activities, including selling food for cash, bartering food, and giving food away to promote a business.

Most food businesses need to register with their council, however those selling direct to consumer can skip this process. Regardless of if a seller has this registration though, all honey to be traded must be extracted and packed in a premises registered through either MPI or as a National Programme Level 1 (NP1) under the Food Act. NP1 registrations go through local councils.

Following legal extraction and packing, honey intended for trading must also meet the labelling requirements of the Food Standards Code.

All in all, it can not only be an expensive process, but impractical for many beekeepers.

Doing it from home

Of course, not all beekeepers want the outlay of NP1 registration, which can be more than $500 for even the most basic home-based facility.

Many beekeeping clubs around New Zealand have small, portable honey spinners for hire so members can extract honey at home, while countless other beekeepers will have their own equipment for the same purpose.

The Wellington Beekeepers Association is one such club and president James Withington says he “strongly suspects” beekeepers in the area are trading in honey spun out in unapproved locations. He says it comes down to practicalities and it is too difficult for hobbyist beekeepers to access registered facilities in their area.

“It’s problematic in Wellington, due to the lack of available honey extraction locations, with the nearest honey house being either in the Wairarapa or Manawatu. Furthering the problem is often their requirement for a minimum number of honey boxes to be processed, often beyond that of the hobbyist beekeeper,” Withington says.

“I think most hobbyists in the Wellington region extract at home, whether they barter, gift or potentially sell.”

That is inevitably the case all over New Zealand and so some groups of beekeepers are banding together to help provide registered facilities to smaller honey producers.

Beekeepers Hawke’s Bay are one club that has taken the bull by the horns when it comes to providing a honey processing facility, with their extraction plant capable of putting through 60 boxes of honey a day and available for use by members.

Beekeepers Hawke's Bay president Graham Heaven in the club's fully-compliant honey house. Despite the facility, there are still non-compliant honey sellers in the region though.

Even with access to a facility such as their club’s, there is temptation for users to take honey off site to package it, which then sees it fall outside the Food Act, says club president Graham Heaven.

“We have talked about how to get around it, but we are not too sure. It is a bit of a tender spot for beekeepers. If anyone is doing that it’s practical, but not by the letter of the law. Sooner or later, it is going to be picked up on.”

Auckland Beekeepers Club members fall on both sides of the issue, club president Steve Leslie says. There is a group who have banded together to register a facility and sell their honey completely by the book, whereas he suspects others are happy to sell non-compliant honey.

“It’s essentially a risk-based calculation,” Leslie says of the industry’s attitude to non-compliant honey.

“How much control do we want to put in, based on the amount of risk? The nominal controls are there, food control plans and the like. The actual risk of problems arising from private sales of honey that have not been extracted or packaged according to the rules is extremely low. We are lucky that honey is a safe product by its nature.”

No easy solution?

The issue of unlawfully traded honey is not a new one for the industry says Paul Martin, the sitting non-commercial beekeeping representative of the Apiculture New Zealand board, who says it has been discussed around the board table.

“With any food there is always risk and that needs to be managed, however, the flip side is you have to watch what you wish for in terms of bureaucracy,” Martin cautions.

“If we say ‘no we want to be controlled more’, well you just know the rules that will come out of Wellington or the local council may have a whole heap of unintended consequences.”

Regardless of compliance or not with other areas of honey safety, it is absolutely important that all beekeepers are complying with rules around the management of potential tutin contamination of honey, Martin says.

While a proliferation of unlawful honey sales is an issue the industry is seemingly acutely aware of, there is no obvious alternative to the status quo being offered up to more effectively police non-compliance, or make compliance more practical.

As it stands, compliant beekeepers, such as Darren and Mandi Webb, might be feeling some hurt as they compete in the market place against non-compliant traders though. Another problem caused by the issue of a large supply of honey competing for buyers. An issue, it seems, not limited to the big producers.

Do you have thoughts or opinions on this issue? Email editor@apiadvocate.co.nz

Food Safety Info

New Zealand Food Safety is contactable via email foodactinfo@mpi.govt.nz or ph 0800 00 83 33.

NP1 info: www.mpi.govt.nz/national-programmes

Managing tutin: www.mpi.govt.nz/managing-tutin-contamination-in-honey/

A “Guide to New Zealand Honey Labelling”: www.mpi.govt.nz/food-safety-toolkit

Exporting honey: www.mpi.govt.nz/exporting-food

Donating honey: www.mpi.govt.nz/fundraising-and-community-events


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