At this moment, this text, as well as its annexes, cover many pages.

It states as a pre-amble that:

"Honey is a alimentary foodstuff produced by honeybees from flower nectar or the secretions found on or issuing from parts of living plants, which are gathered, transformed, combined with specifically characteristic materials, which they store up and leave to ripen in the honeycomb. This foodstuff may be fluid, thick or crystallised."

It is stipulated further in the text that Man must not by addition, or subtraction change the product.

One should be able to live in a ideal and simple world , where in the rules, it is sufficient to state that " to be sold under the name of honey, it is obliged that honey is actually honey". In this way the law books would be much thinner. Alas, we are far from this situation.

First of all, looking closer at how the Chinese honey conforms with the directive, such as it exists today before its "simplification"(which has been in a state of flux for several years)

1. All Chinese honey is conditioned in bonded barrels( that is to say in barrels designed initially for hydrocarbons, supplied with 2 holes closed by metallic seals, a large one to empty the contents, a smaller one to allow for the passage of air). These barrels are not conform either for "vertical" regulations for honey, nor for the "horizontal" regulations concerning alimentary containers.

For this first reason, Chinese honey should not be allowed to penetrate into the territory of the E.U.( Recall that in France, honey must be stocked in barrels that are totally opening and alimentary .)

2. The directive 74/409, stipulates that honey "must not present any signs of fermentation". If this is the case, it is expressly scheduled for industrial use( as in the manufacture of cakes, spice bread etc…).However, Chinese honey sold in pots presents signs of fermentation( see photographs).

For this second reason, Chinese honey should not be commercialised as table honey.

3. The directive 74/409 states that honey should not contain organic or inorganic materials foreign to the make up of the honey( except, as always according to the same logic, unless classed as "industrial honey"). There is practically always the presence of soil particles in Chinese honey, in important quantities.

For this third reason, these honeys should be forbidden in conditioned form and restricted to industrial use only.

4. Still with the same text, honey should not present any tastes or odours that are foreign to the product.

Practically all Chinese honeys show a level of Iron 2 to 10 times superior to that of "normal" honey as well as a pronounced "metallic" taste.

Equally for this fourth reason, these honeys should be classed only as "industrial honeys".

We discreetly pass over the subject of chemical residues and other pollutants regularly signalled by the laboratories, these being found in a significant proportion of honey lots analysed.

Therefore without referring to the problems of honey adulteration practically reoccurring with these countries, there are already four different reasons, which are amply sufficient to ban the importation, or to limit the merchandise to industrial uses only.

The company NESTLE, very influential with the European authorities, is one of the world’s largest users of honey, either conditioned in pots, or as an ingredient in industrial products.

The rumour(non verified to date), is that it is essentially NESTLE/GREAT BRITAIN who are calling for(or suggest) the "simplification" of the technical measures in of the directive 74/409 such that:

• The maximum level of HMF tolerated is increased to 80mg/kg,
• The obligation to indicate the geographical origin is removed
• And most importantly, the legalisation of the Ultra-filtration process is obtained(see definition § 21),

All these measures being justified by particularly fallacious technical arguments, and which can only, in the long term, result in one consequence: the sale, in all legality, of vulgar industrial syrups under the label of honey.

If the Board of General Directors of the group, in Switzerland, would, in an official and public manner, communicate it’s position on all these points, it would contribute a healthy clarification to the debate.

Whilst there is not, at the moment of custom’s clearance

It will be totally impossible to prevent the tainted merchandise spreading into the commercial system, pure or diluted, under the name of "honey". ITS’

The manner in which our modern societies function appears not to be too clear. Amongst the interlocutors susceptibly concerned by the problem, there are:

1. "THE CUSTOMS" – The Customs Service, specialises in the repression of different trafficking (drugs, arms, dangerous products) and the holding of import/export statistics by name of product. It is not competent nor equipped to verify the conformity of products with regard to European regulations. It has not the authority to return non-conforming merchandise back to its country of origin.
2. "THE FRAUD" - According to the explanations that were supplied to us, the competence of the "General Office of Competition, Consumption, and Repression of Fraud"(D.G.C.C.R.F.), does not come into force until after customs clearance, that is to say once the imported product has officially entered French or European territory. There is therefore, for this administration, no possible method to return non-conforming merchandise back to its country of origin.
3. "MINISTRY OF AGRICULTURE" – If we understood well the explanations which have been supplied, it is the Ministry of Agriculture who is competent (Department of Veterinary Services, General office of Alimentation. ( D.G.A.L.)) and who delivers the "sanitary certificate", the apparently indispensable administrative document enabling the merchandise to pass through the customs. However, the control is only to ensure that sanitary aspects are adhered to, i.e. toxicology, etc…There again, the consequence is that, there is no possible method to return non-conforming merchandise back to its country of origin.
4. "THE COMMERCIAL OPERATORS" – According to the explanations that have been supplied to us, it is for the market:

• to ensure the conformity of the products
• to eliminate the disloyal competition.

If this the case , it is difficult in practice to see how such a situation may evolve.

1. One envisages with difficulty a collection of economic operators( association, union or others), having the competence in controlling the merchandise during its passage through customs clearance.
2. Even if this was the case from a legal point, without the support of the super markets, such an organisation, concerning honey, would carry no weight. In addition, the group, by itself, would be incapable of finding the cash required to cover the running costs.

So, the only method to eradicate this fraud, is intervene and to send back the adulterated merchandise the moment it attempts customs clearance into the European Union. This is the only potential stranglehold available.

It appears that there is no organisation, public or private administratively suited, legally competent, and technically equipped, to intervene.

We are therefore facing a very basic question:

As well, article 14 imposes :

It was therefore logical that on the 22/7/1976 France published the "Décret Miel n° 76/717" (see annex). This decree renders obligatory (Art.6, lines 1/d and 1/e):

Art. 6 line 1/d

Article 6, line 1/e

e) The mention "blend of imported honeys" in the case of blended honeys originating from countries that do not belong to the Community; the mention "blended honey of several origins" in the case of blended honeys originating partly from countries in the Community, and partly from countries that do not belong to the Community.

The rest of article 6 details the diverse legal obligations relating to labelling.

A simple visit to the nearest supermarket, is all that is needed to realise that in reality the market shows no comparison with the regulations in place:

• The geographical origin is usually mentioned for French honeys ;
• For imported honey, except in the very rare cases, the indication of the country of origin in never mentioned ;
• The mention "blend of imported honey" is exceptional.

In fact, in 99% of cases, one finds :

• either "Honey of several origins"( and not "Blend of honeys from several origins")
• either "several origins"
• or simply the initials "O.D.".

for honeys which in practically all cases, are blends of honeys imported from countries outside the E.C. : legally these should be called " blend of imported honeys".

We are therefore in the presence of a compete disregard for the law.

In effect, in the majority of cases , the words "several origins" are taken by the consumer to mean "different floral origins", in other words "blossom" and not as an indication of provenance : blend of honeys from different countries

For several years, nobody has understood why the legal obligation which has such common sense and simplicity, is to this point in time shamelessly disregarded.