Honey Labeling Requirements: Origin, Grades, and Warnings

Honey labeling requirements come from the Food and Drug Administration, and a compliant jar sold in the United States needs six things: the word “Honey” as the statement of identity on the front panel, the net weight, the name and address of the manufacturer, packer, or distributor, an ingredient list if anything has been added, country-of-origin marking if the honey is imported, and a nutrition facts panel unless the producer qualifies for a small-business exemption. Getting any of these wrong makes the product misbranded under federal law and exposes it to warning letters, recalls, border refusals, or seizure.

The FDA defines honey as “the thick, sweet, syrupy substance that bees make from the nectar of plants or their secretions and store in honeycombs.”¹ The agency has declined to adopt a formal standard of identity for honey, relying instead on its guidance document and its authority over adulterated or misbranded food under sections 402 and 403 of the Federal Food, Drug, and Cosmetic Act.² Anything sold as “honey” cannot contain undeclared sweeteners. If corn, rice, cane, or beet syrup has been mixed in, the product must be labeled as a blend and carry an ingredient statement listing what was added.

The Product Name on the Front Panel

Every packaged honey needs a statement of identity on the principal display panel, which is the side of the label a shopper sees first. For pure honey, that statement is simply “Honey.” Under 21 CFR 101.3 the name must appear in bold type, in a size “reasonably related to the most prominent printed matter” on the panel, and in lines generally parallel to the base of the package.³ The rule does not impose a fixed ratio, but a tiny “Honey” beside a giant brand logo would fail the test.

A floral source can be worked into the name. “Clover Honey” and “Orange Blossom Honey” are permitted as long as the named flower is the chief floral source, and the producer is responsible for making sure the claim is truthful.⁴ There is no required testing protocol, but you should be able to document how you determined the source if the FDA asks.

Net Weight

The quantity of honey in the container has to be declared on the principal display panel. Because honey is a semisolid, the declaration must be given by weight in avoirdupois pounds and ounces.⁵ A typical format is “Net Wt. 16 oz (1 lb).” A metric equivalent such as “454 g” is optional under federal rules, though some producers add it for export purposes.

Placement is regulated. The net quantity statement has to sit in the bottom 30 percent of the principal display panel, in lines parallel to the base of the package. Small packages with a display panel of five square inches or less are exempt from the bottom-30-percent rule as long as they meet the other formatting requirements.⁶ Minimum type size scales with the size of the panel, so larger jars need larger text.

Who Made It, Packed It, or Distributes It

The label must identify the responsible business by full legal name and physical address. The street address can be dropped if the business is listed in a current city or telephone directory; the city, state, and ZIP code still have to appear.⁷

If the name on the label is not the actual manufacturer, a qualifier is required. “Manufactured for,” “Distributed by,” or “Packed for” all work. Leaving off the qualifier makes the product misbranded under 21 U.S.C. § 343.⁷ Co-packing arrangements trip on this often: when a beekeeper produces the honey, another facility jars it, and a third company sells it under a brand, the parties have to agree whose name goes on the label and which qualifier applies.

Ingredients and Allergens

Pure honey is a single-ingredient food, and the product name “Honey” on the front panel serves as the ingredient disclosure. A separate ingredient list is not required.⁸ The moment you add cinnamon, vanilla, another sweetener, or anything else, you need a full ingredient list with each component named in descending order by weight. Added flavorings must be declared under the specific rules in 21 CFR 101.22.

The single-ingredient status also keeps pure honey out of the major food allergen disclosure regime. Honey itself is not one of the nine major allergens recognized under the FASTER Act (milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, sesame). Add any ingredient that is or contains one of those allergens and it has to be declared like on any other packaged food.

Country of Origin for Imported Honey

All imported food entering the United States must be marked with the English name of its country of origin in a conspicuous and legible manner under 19 CFR Part 134.⁹ For any honey that carries a USDA grade mark or inspection statement, there is a second layer: the country or countries of origin must be printed legibly in close proximity to and at comparable size with the grade mark, preceded by “Product of” or similar wording.¹⁰

When honey from multiple countries is blended, industry practice is to list every contributing country. Customs can reject shipments that obscure the true origin, and honey is one of the most commonly adulterated food imports, so origin marking gets close scrutiny at the border.¹¹

“Raw,” “Organic,” and USDA Grades

“Raw” has no federal definition when applied to honey. The FDA has not established criteria for the term, so sellers use it inconsistently. The only backstop is the general prohibition on false or misleading labeling in 21 U.S.C. § 343.¹² A producer using “raw” should have a consistent internal standard and be prepared to explain it.

“Organic” is regulated. Honey labeled organic must meet USDA organic certification requirements through an accredited certifying agent and comply with the national organic standards.¹³ Certification for honey is difficult in practice because beekeepers have to show that bees forage in areas free of prohibited pesticides and synthetic chemicals within a realistic flight radius.

USDA grading is voluntary. Standards for extracted honey run from Grade A through Grade C with anything below Grade C classified as Substandard, based on factors like moisture, clarity, flavor, and defects.¹⁴ No producer has to grade their honey, but using a USDA grade mark on the label triggers the country-of-origin proximity rule described above, and some wholesale buyers require graded honey as a condition of purchase.

Nutrition Facts and Small Business Exemptions

Nutrition labeling under 21 CFR 101.9 requires a standard nutrition facts panel with a defined serving size, calorie count, and nutrient breakdown, formatted according to the FDA’s rules for font size, line spacing, and ordering. Two exemptions can spare a small honey operation the cost of nutritional analysis and panel design:

Under 21 CFR 101.9(j)(18), a business with fewer than 100 full-time equivalent employees that sells fewer than 100,000 units of a product annually can file for an exemption from nutrition labeling. The exemption claim has to be filed with the FDA before the period it covers.¹⁵
Under 21 CFR 101.9(j)(1), a seller with annual gross sales of no more than $500,000, or food sales to consumers of no more than $50,000, does not need to file anything with the FDA to be exempt.¹⁶

Both exemptions disappear as soon as the label, other labeling, or advertising includes any nutrient content claim, health claim, or other nutrition information. Putting “sugar free” or “low calorie” on the jar forces a full nutrition facts panel regardless of size.¹⁶ Even informal health messaging in advertising can trigger the requirement, which catches more producers than expected.

The Infant Botulism Advisory

Federal law does not require a botulism warning on honey. Nearly every commercial producer includes one anyway, advising against feeding honey to infants under one year of age because honey can contain Clostridium botulinum spores that a baby’s digestive system cannot handle safely. Many retailers refuse to stock honey without the advisory, so it operates as a practical requirement driven by liability rather than by regulation. The warning is typically placed near the nutrition panel or ingredient area.

What Happens If the Label Is Wrong

A label that misses any of the required elements makes the product misbranded under 21 U.S.C. § 343, which covers false labeling, missing manufacturer information, misleading containers, and absent required disclosures.¹² The FDA’s enforcement options include warning letters, import refusals, product seizures, injunctions, and in serious cases criminal investigations.

Imported honey draws especially close scrutiny. In the FDA’s most recent testing assignment, violative imported samples were refused at the border and the responsible firms were placed on Import Alert 99-47, which subjects all future shipments to detention without physical examination.¹ Getting off an import alert requires the firm to submit evidence overcoming the appearance of a violation, a process that can take months and effectively shuts down the product in the meantime. For domestic producers, the FDA usually works toward voluntary recall and corrective action, but the agency can escalate to seizure or injunction if a producer does not cooperate.¹¹

1
Food and Drug Administration. FY25 Sample Collection and Analysis of Domestically Produced and Imported Honey for Economically Motivated Adulteration
2
Federal Register. United States Standard of Identity for Honey
3
eCFR. 21 CFR 101.3 – Identity Labeling of Food in Packaged Form
4
Federal Register. Proper Labeling of Honey and Honey Products; Guidance for Industry; Availability
5
eCFR. 21 CFR 101.7 – Declaration of Net Quantity of Contents
6
GovInfo. 21 CFR 101.105 – Declaration of Net Quantity of Contents When Exempt
7
eCFR. 21 CFR 101.5 – Food; Name and Place of Business of Manufacturer, Packer, or Distributor
8
eCFR. 21 CFR 101.4 – Food; Designation of Ingredients
9
eCFR. 19 CFR Part 134 – Country of Origin Marking
10
USDA Agricultural Marketing Service. Packed Honey – Country of Origin Labeling
11
Food and Drug Administration. FY21/22 Sample Collection and Analysis of Imported Honey for Economically Motivated Adulteration
12
Office of the Law Revision Counsel. 21 USC 343 – Misbranded Food
13
USDA Agricultural Marketing Service. Labeling Organic Products
14
USDA Agricultural Marketing Service. United States Standards for Grades of Extracted Honey
15
eCFR. 21 CFR 101.9 – Nutrition Labeling of Food
16
Food and Drug Administration. Small Business Nutrition Labeling Exemption Guidance