The Ministry for Primary Industries (MPI) has developed an ‘Interim Labelling Guide for Manuka Honey’, in an attempt to provide some direction to an industry suffering from a lack of consensus over the definition of manuka honey and its labelling.
Currently, there is not an industry wide standard for identifying manuka honey or any agreement over what statements are appropriate to make on labels and packaging. This has resulted in a number of companies using a variety of terms and claims which are confusing to customers.
In an effort to ensure that manuka products are authentic and not misleading to customers, the guidelines offer the first step in a bid to distinguish genuine manuka products from the counterfeits. It does this by providing greater clarity as to the characteristics of manuka honey and the types of claims that can be made.
The guidelines are based on the Food Act 1981, the Animal Products Act 1999, the Fair Trading Act 1986 and the Australia New Zealand Food Standards Code (Food Standards Code). All food sold in Australia and New Zealand must comply with the Food Standards Code which contains labelling and compositional requirements.
MPI has stated that the interim labelling guide is a two staged process. The first stage focuses primarily on addressing labelling issues, including health and therapeutic claims made in association with manuka honey as well as providing a list of natural characteristics of manuka honey.
Characteristics of manuka honey identified in the guidelines include, specified colour and conductivity ranges, the presence of natural manuka pollen, methylglyoxal (MG) and dihydroxyacetone (DHA), as well as an expected flavour (mineral, slightly bitter) and aromatic properties. These characteristics serve as indicators to consumers, manufacturers and regulators as to what should be present in honey that is labelled as manuka.
The second stage of this process will be for MPI to develop a robust definition of the characteristics unique to manuka honey based on comprehensive scientific research. MPI plans to review the interim labelling guide in July 2015, by which time it hopes to have validated research data that can be incorporated into the guidelines to strengthen the existing parameters.
The guidelines outline the requirements of Standard 1.2.7 ‘Nutrition, Health and Related Claims’, which was introduced in 2013 in order to regulate nutrition content claims and health claims in advertising and labelling of food products.
Of particular importance, is that this Standard prohibits therapeutic claims being made on any food products. These are claims that refer to the prevention, diagnosis, cure or alleviation of a disease, disorder or condition. Claims directly related to antibacterial activity such as ‘non-peroxide activity’, ‘total activity’, ‘peroxide activity’, ‘total peroxide activity’ and ‘activity’ are therefore no longer permitted. This is due to the lack of evidence suggesting that the anti-bacterial properties are effective when honey is consumed orally.
Standard 1.2.7 also contains requirements for making nutrition and health claims. This states that nutrition claims are permitted if the following conditions are met:
- Nutrient profiling scoring criterion are met (NB. Honey does not meet the nutrient profiling criterion because of its high sugar content and therefore currently no health claims can be made under this Standard);
- Meets the conditions of an applicable pre-approved health claim set out in Standard 1.2.7;
- Meets the requirements of a self-substantiated health claim set out in Standard 1.2.7.
Other labelling requirements of the Food Standards Code include that the statement is truthful and accurate, the statement can be substantiated and it is not misleading or deceptive.
There is a transitional period of three years where businesses must comply with either Standard 1.2.7 or the transitional Standard 1.1A.2, until the Standard comes into effect from 18 January 2016.
The guidelines also discuss how there are a number of different grading systems in use for manuka honey. This includes the well-known Unique Manuka Factor (UMF) which is a quality standard used to identify manuka honey through the use of a licensed trade mark. This is a voluntary, audited quality standard administered by the UMF Honey Association of New Zealand which has been gathering support for more than 15 years.
MPI has stated that they intend to work with other grading systems to ensure that these are measurable and transparent, with consistently identifiable characteristics based on scientific evidence.
The credibility of the industry relies on traders adhering to the new standards and ensuring that manuka honey is correctly identified and labelled. Businesses are responsible for ensuring that all labelling requirements are met, including that the labels are accurate, that there are reasonable grounds for making the statements and that any such statements comply with the legislative requirements.