ACHIEVING EU ACCREDITATION FOR HONEY EXPORT
Gilles Ratia - Apiservices

This page summarises information contained in Gilles Ratia's presentation to the Bees for Development Honey Trade Workshop held in Dublin, Ireland in August 2005.

(right) EU honey imports in tonnes during 2003.

Images © Gilles Ratia
 

You can also download and view Gilles Ratia's complete PowerPoint presentation here

TO PROTECT CONSUMERS THE EU HAS CREATED RESTRICTIONS FOR HONEY IMPORTS

Due to concerns about food safety, residue monitoring plans are required from third-world countries for imports into the EU of all animals and products of animal origin. This is laid down in Council Directive 96/23/EC of 29 April 1996 on measures to monitor certain substances and residues thereof in live animals and animal products (OJ L 125, 23/5/1996). Honey is considered to be an animal product.

THE EU STANDARD FOR HONEY EXPORT: EU Honey Directive

Honey definition: Honey is the natural sweet substance produced by honey bees from the nectar of plants or from secretions of living parts of plants or excretions of plant sucking insects on the living parts of plants, which honey bees collect, transform by combining with specific substances of their own, deposit, dehydrate, store and leave in the honey comb to ripen and mature.

Obligatory specification:

• Moisture content: Not more than 20%

• Fructose & Glucose content: Not less than 60g/100g

• Sucrose content: Not more than 5g/100g

• Water insoluble solids content: Not more than 0.1g/100g

• Electrical Conductivity: Not more than 0.8 mS/cm

Contaminants:

• Heavy metals, Pesticides, Carbanates, Pyrethroids, Organochlorine and organophosphorus: Not currently defined

• Sulphonomides: Not more than 10ppb

• Antibiotics: Not more than 15ppb

The control of residues in honey is important to control the traces of any contamination that the bees may have picked up. Three main groups of products are targeted for examination:

• Banned veterinary substances (such as chloramphenicol)

• Authorised veterinary substances (but found in excess of their authorised limits, such as antibiotics and insecticides)

• Environmental pollutants (such as pesticides or heavy metals)

Additional Composition and Quality Factors: Intended for voluntary application by commercial partners and not for application by government

• Free acidity: Not more than 50 milli-equivalents acid per 1000g

• Diastase activity: Not less than 8 Schade Units

• HMF: Not more than 80mg/kg

The core requirement for importing honey into the EU is for the country in question to have a residue monitoring plan, approved by the EU.

This plan is intended to assess the ability of the official services of the exporting country to ensure the safety of the honey with regard to residues of chemical substances in it.

SUMMARY OF INFORMATION TO BE SUBMITTED CONCERNING A RESIDUE MONITORING PLAN FOR HONEY

1. GENERAL INFORMATION

• 1.1: Legislation concerning the use of substances of Annex I
  (Directive 96/23/EC - Article 7§1)

• 1.2: Infrastructure of the official services; information on co-ordination of the activities of central and regional departments (Directive 96/23/EC - Article 7§2 and article 4).

• 1.3: List of Official Laboratories (Directive 96/23/EC - Article 7§3).

• 1.4: Level of competence of the National Reference Laboratorie(s), as well as routine Laboratories, particularly as regards the implementation of Quality
  Assurance, or good laboratory practices.

• 1.5: National tolerance limits (MRLs) for authorised substances and environmental contaminants (Directive 96/23/EC - Article 7§4).

• 1.6: Official sampling procedures in the field, including information on how samples are secured after collection (using flow charts).

• 1.7: Description of measures taken by the competent authorities where residues are detected (Directive 96/23/EC - Article 7§7-8)

2. BACKGROUND INFORMATION ON PRODUCTION

• 2.1: Total figures of production.

• 2.2: Type of production of 2.1. (intensive, extensive, wild or mixed systems).

• 2.3: Production planned to be exported to the EU. (Decision 97/747/EC).

3. SCOPE OF THE RESIDUE PLAN

• 3.1: Groups of residues covered (as listed in Directive 96/23/EC - Annex I); Breakdown of substances monitored (Directive 96/23/EC - Article 7§5).

• 3.2: Details of analysis methods - screening/routine and confirmation, with action levels and detection limits (Directive 96/23/EC - Article 7§5).

4. FREQUENCIES AND LEVELS OF THE CONTROLS

• 4.1. Number of samples to be taken for each sub-group of substances (Dec 97/747/EC). For third countries, the figures could only refer to exports to EU; in
  that case, guarantees for appropriate segregation and control must be given (Directive 96/23/EC - Article 7§6).

5. TARGETING CRITERIA

• 5.1. Results from previous years.

• 5.2. Changes based on analysis of the residue plan of the previous years (whereas such plans exists), particularly as regards problem areas identified (Directive 96/23/EC - Article 8§2).

  Download Gilles Ratia's PowerPoint presentation (1.19mb .pps file)