On February 28, 2018, FDA issued final guidance on Proper Labeling of Honey and Honey Products. The Guidance is promulgated under FDCA sections 402(b) and 403(i), which prohibit the misbranding and adulteration of food products.
The Guidance advises that food labels for pure honey must be named “honey,” but that the name may include the correct chief plant source of the honey, e.g., “Orange Blossom Honey.” Pure hone products do not require a separate ingredient statement.
If a product contains honey and another ingredient, the product cannot be labeled only as “honey.” Instead, it must properly describe the basic nature of the product. For example, honey with corn syrup added could be labeled as a “blend of corn syrup and honey.” If a product contains honey and raspberry flavoring, it could be labeled “raspberry-flavored honey.” Such combinations would require an ingredient statement that lists each ingredient. Products labeled as “honey” that contain other ingredients would be considered at least misbranded under FDCA section 403(i). If the added ingredient was less valuable than honey (e.g., corn syrup), it would also be considered an adulterated product under FDCA section 402(b).