FY25 Sample Collection and Analysis of Domestically Produced and Imported Honey for Economically Motivated Adulteration
Economically Motivated Adulteration
As part of the Food and Drug Administration's (FDA) continued effort to combat economically motivated adulteration, the FDA conducted an assignment in fiscal year 2025 (FY25) to collect and test domestically produced and imported honey.
The FDA regularly tests food products to ensure they are safe and accurately labeled. We tested products labeled as honey to see if they contained undeclared added sweeteners.
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Economically motivated adulteration, the regulatory term that the FDA uses for food fraud, is the substitution, addition, or omission of a substance in a product or concealment of a product’s inferiority or damage to increase its apparent value or reduce the cost of its production (i.e., for economic gain). Simply put, it’s an effort to cheat consumers.
The FDA recognizes that the term “honey” commonly refers to the thick, sweet, syrupy substance that bees make from the nectar of plants or their secretions and store in honeycombs (see FDA’s Proper Labeling of Honey and Honey Products: Guidance for Industry). Economically motivated adulteration occurs when products labeled as “honey” contains undeclared sweeteners that are less expensive than honey, such as syrups derived from sugarcane, corn, rice, or sugar beets.
This assignment was preceded by two prior assignments of honey for economically motivated adulteration, one in 2021-22 and one in 2022-23. These two previous assignments focused on imported honey and the current assignment included both domestically produced and imported honey. For the 2021-22 assignment, of the 144 import samples collected and tested, 14 (10%) were found to be violative. For the 2022-23 assignment, of the 107 imported honey samples, 3 (3%) were found to be violative. The two import assignments were not designed for statistical comparison. All violative imported samples detected from the two prior assignments resulted in refusal of entry for these shipments into the U.S. In addition, the FDA increased screening and surveillance sampling or placed the associated firms and products on Import Alert (IA) 99-47.
Testing by the FDA and other countries[1] has shown that honey is susceptible to economically motivated adulteration. The goal of FDA’s FY25 honey assignment was to continue monitoring industry compliance and to take appropriate regulatory actions.
Methodology
The agency collected and tested 54 domestically produced honey samples and 48 imported honey samples in FY25 to determine whether they contained certain undeclared added sweeteners. Each sample was made up of three subsamples, with each subsample containing at least 240 milliliters or 8 oz of honey (about a cup). FDA field personnel collected either bulk or retail samples labeled as “honey.” Retail samples consisted of individual jars or other containers intended for retail sale. Bulk shipment samples were collected typically from barrels or drums, with the use of appropriate collection equipment and procedures. All domestic samples were collected at retail stores or from manufacturers. All import samples (from 20 countries) were collected in import status, which refers to products collected at ports of entry or other locations where they are held prior to being released into U.S. domestic commerce.
The FDA used Stable Carbon Isotope Ratio Analysis (SCIRA) to analyze each honey sample and its protein extract. When the agency found a sample to have carbon isotope ratio values atypical to those of authentic honey, the agency’s subject matter experts reviewed the analytical results to determine whether the sample was violative considering factors such as natural variability in honey composition and analytical uncertainty.
Findings
Of the 102 samples collected and tested, the FDA found 2 domestically produced samples and 2 import samples to be violative. These findings represented a violation rate of 4 percent. While the percentage of violative samples was a slight decrease from the 2021-22 imported honey assignment and was comparable to the 2022-23 assignment, the three assignments were not designed for statistical comparison. View the full, published dataset.
A breakdown of the findings by the declared country of origin is provided in Table 1. The FDA cautions against making inferences of country of origin violation rates based solely on Table 1 results because the FDA did not design the assignment for such comparison.
Table 1. Number of samples collected and found violative by declared country of origin.
| Declared country of origin | Collected samples | Violative samples |
|---|---|---|
| Argentina | 5 | 0 |
| Armenia | 2 | 2 |
| Australia | 1 | 0 |
| Brazil | 1 | 0 |
| Canada | 3 | 0 |
| France | 1 | 0 |
| Germany | 1 | 0 |
| India | 9 | 0 |
| Italy | 4 | 0 |
| Mexico | 4 | 0 |
| New Zealand | 2 | 0 |
| Poland | 2 | 0 |
| Sierra Leone | 1 | 0 |
| Spain | 1 | 0 |
| Türkiye (Turkey) | 3 | 0 |
| Ukraine | 4 | 0 |
| United Kingdom | 1 | 0 |
| United States | 54 | 2 |
| Uruguay | 1 | 0 |
| Vietnam | 1 | 0 |
| Zambia | 1 | 0 |
Follow-Up Actions
When the FDA found a sample to be violative, the agency took appropriate follow-up actions. For domestic violative samples, the FDA is working with the firms on corrective actions, including voluntary recall. For imported violative samples, the FDA stopped the shipments at the border[2]. In addition, the FDA placed the associated firms and honey products on Import Alert (IA) 99-47 to prevent future shipments of these firms’ honey products from entering the U.S. Products listed on the Import Alert are subject to Detention without Physical Examination. For those products to be admitted into the U.S., firms are required to provide evidence to the FDA to overcome the appearance of violation(s).
Discussion
The results of this assignment show that honey continues to be a commodity susceptible to economically motivated adulteration. The results reaffirm the need for vigilance with respect to economically motivated adulteration. While there is not an indication of direct adverse public health consequences in this instance, it is important that consumers can trust the labels, are not deceived, and get fair value for their purchase. Violative samples are subject to compliance actions, consistent with the FDA’s mission to ensure that food is safe, wholesome, and properly labeled. When appropriate, the agency may consider pursuing criminal investigations. The FDA also collaborates with other U.S. regulatory agencies and international counterparts to detect and combat economically motivated adulteration of various commodities, including honey.
Honey can be adulterated with less expensive sweeteners derived from various plant sources including sugarcane, corn, rice, and sugar beets. Different methods are needed to detect undeclared sweeteners from these various sources. The current method used by the FDA detects a subset of undeclared sweeteners. FDA continues to develop additional methods for the detection of additional types of undeclared sweeteners to protect consumers.
When other sweeteners are added to honey, the Federal Food, Drug & Cosmetic (FD&C) Act requires that the resulting product be labeled as a “blend,” and not as “honey,” and have an ingredient statement that properly declares the added sweeteners. Labeling on packaged food in interstate commerce is required to be truthful and not misleading, according to the FD&C Act. This applies to both domestically produced and imported honey products.
Additional Information
- Economically Motivated Adulteration
- FDA Releases FY25 Sampling Results on Economically Motivated Adulteration in Honey
- Guidance for Industry: Proper Labeling of Honey and Honey Products
1. Examples of testing conducted by other countries: CFIA's role in combatting food fraud - inspection.canada.ca, Honey (2015-17) - Food Safety - European Commission, Honey (2021-2022) - Food Safety - European Commission.
2. While a firm can submit reconditioning proposals for shipments that FDA determines are economically adulterated, the firm and the associated products (honey) remain subject to Detention without Physical Examination under Import Alert(s).