United States FDA Final Guidance - "Added Sugars" Declaration on Honey Labels
Honey exporters will be interested in the United States FDA final guidance on the declaration of added sugars on honey, one of the changes brought in under the new Nutrition Facts label final rule. The new rule was originally going to be enforced from July 2018 (July 2019 for smaller companies) – but FDA has pushed back the compliance date to July 2021, to allow further time to consider industry feedback and produce final guidance on how the new rule will play out for single-ingredient sugars. The rule requires a mandatory declaration of weight and a percentage daily value of “added sugar” - not just for sugars and sweeteners added to processed foods, but also to single ingredient sugars such as a jar of honey. Initial draft guidance elicited much criticism from concerned producers of single ingredient sugars such as honey and maple syrup, and in response FDA advised in September 2018 they would address these concerns.
FDA states that the aim of having to list “added sugars” (rather than just total sugars) was to help American consumers to choose foods with less sugar added, to reduce the burden of diabetes, obesity and heart disease. Honey and maple syrup, when added to a processed food, would be considered to be “added sugars”. This does not mean that honey or maple syrup contain sugars added to them, however FDA’s definition of “added sugars” includes both sugars added during food processing, and sugars “packaged as such” specifically including honey and maple syrup. This is potentially confusing to consumers, who may interpret “added sugars” on honey labels to mean the addition of corn syrup, or contamination of honey from sugar supplements fed to bee colonies as a management tool. A solution to the confusion has been proffered – see below.
FDA’s Daily Recommended Value for “added sugars” is 50 gm for adults and children 4 years and older, including for pregnant women (half this amount for children 1-3 years). A single serving of honey (1 Tbsp) contains around one third of the DRV for adults.
The outcome of FDA’s deliberations has been to introduce a new regulation which states that Nutrition Facts labels for single-ingredient sugar, honey, agave or syrup will not need to bear the declaration “includes X g Added Sugars”. However, the percentage DRV must still be declared in the %DV column on the Nutrition Facts label. And here’s where it gets even more different: manufacturers will be permitted to voluntarily also use a new symbol which functions like an asterisk next to the %DV value, to lead consumers to a footnote describing the gram amount of added sugars in one serving, and its contribution to the percentage DV for added sugars in the diet.
Honey exporters should be pleased to know that there is sufficient time to digest this news as FDA state that they will exercise enforcement discretion until 1 July 2021 for complying with new Nutrition Facts label requirements; FDA’s new guidance states that honey manufacturers who do not meet all of the new Nutrition Facts label requirements will not be subject to FDA enforcement actions until that date. Manufacturers who already use the new Nutrition Facts label format (but who have not yet declared “added sugars”) now have sufficient time to choose whether they wish to educate their consumers by using the new symbol and footnote, before declaring “added sugars” on their honey labels. For example labels see here.