What's in your honey?
Universally, honey is believed to be a natural product. Regulations across the world say as much. The Codex Alimentarius Commission is a global body set up jointly by the UN’s Food and Agriculture Organization (FAO) and the World Health Organization (WHO) to develop food standards for international trade; it defines honey as “the natural sweet substance produced by honeybees 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 the bees collect, transform by combining with specific substances of their own, deposit, dehydrate, store and leave in the honeycomb to ripen and mature”.
This definition of honey is now threatened. In several countries, the beekeeping industry uses antibiotics to control outbreaks of diseases in honeybees, and as growth promoters to increase production. And these antibiotics are finding their way into that spoonful which reaches the house-holder’s table. So what is the world doing about it?
Codex: Honey is an internationally traded commodity. Codex has set down standards for the quality of the honey which is traded. But it has nothing to say on the presence of antibiotics in honey.
European Union: EU regulates honey under the Council Directive 2001/110/EC. The standard for antibiotics in food (referred to as Maximum Residue Limits or MRLs) is listed in Regulation (EU) No 37/2010—it stipulates that each antibiotic must have an MRL before it can be used on a food-producing species. But there are no MRLs for antibiotics in honey, which means EU does not allow the use of antibiotics for treatment of honeybees.
But EU member states do import honey. For regulating residues of antibiotics in this imported honey, the bloc has set what are called RPAs, or ‘Reference Points for Action’. RPAs are residue concentrations which are technically feasible to detect by food control laboratories. When antibiotics are detected by a laboratory, the member state is obliged to reject the consignment. Till date, RPAs have been established in honey for substances such as chloramphenicol and nitrofurans. EU has also set a provisional MRL of 25 parts per billion (ppb) for oxytetracycline in honey.
USA: In the US, MRLs for antibiotics in food are set by the US Food and Drug Administration (USFDA), and listed in Title 21, Part 556 (21 CFR 556). There are no limits for antibiotics in honey.
What does this mean? Are all kinds of antibiotics, in any amount, permitted in honey? Or are antibiotics ‘unauthorised’ substances in honey and therefore, ‘illegal’?
Regulators in the EU and the US opine that they are ‘unauthorised’ and therefore ‘illegal’, unless there is a standard regulating their levels. This is the reason why EU banned Indian honey from entering its shores—it was found contaminated with high amounts of antibiotics.
Which brings us to the honey consumed within India. Does it have any safety standards? Are there any regulations governing the presence of antibiotics in honey?
In India, honey is currently regulated under three legislations:
- The voluntary Bureau of Indian Standards (BIS) norm for extracted honey under IS4941:1994. Brands wishing to obtain the ISI mark will have to follow it.
- Honey Grading and Marking rules, 2008 under the Agricultural Produce (Grading and Marking) Act, 1937 (AGMARK), implemented by the Union Ministry of Agriculture.
All three define honey as a “natural product” and lay down standards for its composition and quality (like sucrose content, total reducing sugars and moisture content)—but there are no standards for antibiotics in honey.
Does this mean that antibiotics in honey are ‘unauthorised’ and therefore, ‘illegal’, in India as well?
Indian regulators believe if there are no standards, they can’t regulate. But this perception undergoes a sea change when it comes to honey for export. Indian regulators take great care to ensure the honey exported from the country is safe. For this, an elaborate system of monitoring (called Residue Monitoring Plan or RMP) has been put in place, and the Exports Inspection Council (EIC), under the Union Ministry of Commerce and Industries, has been entrusted with the task of checking exports.
EIC standards: The EIC has set antibiotic standards for honey which is exported. This is referred to as ‘Level of Action (LOA)’—the limit beyond which a sample is deemed non-compliant and rejected for exports. These LOAs have been set for some antibiotics (see table: ‘Doomed by definition’).
None of this, however, applies to honey sold in the domestic market. There are hardly any reports on antibiotic contamination of honey consumed within the country. India also imports honey, but there is no standard to check its quality either. Having come up against this regulatory black hole, CSE’s Pollution Monitoring Laboratory (PML) decided to probe just how much antibiotic-laden is the honey sold in the domestic market. By testing some of the best known and most commonly ingested brands. A report.