What you can do. Comment on the FDA Website by March 6th.
- Go to https://www.regulations.gov/document?D=FDA-2016-D-4414-0002
- Click on ‘Comment now!’ (upper right of page)
- Write your own note concerning how confusing this regulation is or paste in our suggestion below.
I join with the Honey and Pollination Center, Robert Mondavi Institute, UC Davis, the Pollinator Stewardship Council, and the American Honey Producers Association, to express concern of the FDA requirement for packaged honey to include a nutrition label listing both “Total Sugars” and “Added Sugars.”
This requirement does not distinguish between the two sugar types. Therefore, labels will need to include the same amount of grams of sugar under each category e.g. “17 grams of Total Sugar” and “17 grams of Added Sugars.”
Not only is this confusing for consumers, it is also incorrect. There are no added sugars in pure honey. Honey is a totally natural product.
As stated in 21 US Code §342 (b)(4), “A food shall be deemed to be adulterated… if any substance has been added thereto or mixed or packed therewith so as to…make it appear better or of greater value than it is.”
If consumers are informed through the Nutrition Facts label that honey contains “Added Sugars” then consumers may be led to believe that honey is adulterated, by the regulatory definition, with sugars added to develop or enhance its sweetness.