IA #36-01 - 11/19/08 REVISED, "Adulteration of Honey"
***The revision of this Alert dated 11/19/2008 updates text, AOAC Official
Method references, servicing laboratory information, and DFS contact phone
numbers. Changes are designated by asterisks (***).
TYPE OF ALERT: GUIDANCE
NOTE: This import alert contains guidance to FDA field personnel only. It does
not establish any requirements, or create any rights or obligations on
FDA or regulated entities.
PRODUCT: Honey
PRODUCT CODE: 36C[][][]
PAC FOR
COLLECTION: 21004
PROBLEM: Adulteration
PAF FOR
COLLECTION: EDE (Economic deception)
COUNTRY: All
MANUFACTURER: N/A
MANUFACTURER
ID #: N/A
CHARGE: "The article is subject to refusal under 801(a)(3)
in that it appears that corn or cane sugar has been
substituted in whole or in part for the product honey"
[Adulteration, Section 402(b)(2)].
or
"The article is subject to refusal under 801(a)(3)
in that it appears that damage or inferiority has been
concealed" [Adulteration, Section 402(b)(3)].
or
"The article is subject to refusal under 801(a)(3)
in that it appears that corn or cane sugar has been
added to or mixed with the product, honey, so as to
increase its bulk or weight, or reduce its strength,
or make it appear to be of greater value than it is"
[Adulteration, Section 402(b)(4).
RECOMMENDING
OFFICE: Division of Import Operations & Policy, HFC-170
Division of Field Science, HFC-140
REASON FOR
ALERT: During the ***mid 1990's, detentions of imported honey
from Brazil, Mexico, and the Soviet Union occurred due to
adulteration with corn or cane sugars.***
These detentions were based on analytical results received
from Geochron Laboratories. This fast analytical technique
measures the C-13/C-12 isotope ratio of the sugars in the
sample.
FDA laboratories do not have the instrumental capability
to analyze honey according to the Official Methods of
Analysis of AOAC International, ***AOAC Official Method
991.41,*** which requires an isotope ration mass
spectrometer.
GUIDANCE: Surveillance of imported honey from all countries is
indicated.
Districts requiring this analysis should contact one
of the following laboratories:
1) Geochron Laboratories
Division of Krueger Enterprises, Inc.
***45 Manning Road
Billerica, Massachusetts 01821
Tel: (978) 667-7080
Fax: (978) 667-6999***
2) Coastal Science Laboratories, Inc.
6000 Mountain Shadows Drive
Austin, Texas 78735
Tel & Fax: (512) 288-5533
3) Center for Applied Isotope Studies
University of Georgia
CAIS Building
120 Riverbend Road
Athens, Georgia 30605
Tel: (706) 542-1395
Fax: (706) 542-6106
Arrangements should be made by phone with the laboratory
***in advance.*** Approximately two ounces of sample
should be shipped within 3 to 10 days.***
The findings of partial substitution of cane or corn
sweeteners in honey should be referred by fax to CFSAN,
***Product Adulteration Branch*** before detention is
considered. The presence of cane or corn sweetener in
the adulteration of honey can be selectively detected by
using the internal standard stable carbon radioisotope
ratio method. Reference for the appropriate analytical
technique is published in the Official Methods of
Analysis of AOAC International, ***AOAC Official Method
991.41,*** C-4 Plant Sugars in Honey.
Both stable carbon isotope ratios for the honey and protein
therein (internal standard method) must be obtained.
An appropriate alternate method may be used to determine
cane or corn sweetener in honey if the method is adequately
documented by a validation study to estimate precision,
accuracy, and sensitivity for the specific analyses.
Equivalency to the official method must be demonstrated in
the submission of analytical data.
For questions or issues concerning science, science policy,
sample collections, analysis, preparation, or analytical
methodology, contact the Division of Field Science at
***(301) 827-7605.***
FOI: No purging required
Prepared by: Jack Geltman, DIOP, 11/3/1997
Revised by: Judy Baron, DIOP, 10/20/2008
Date Loaded
Into FIARS: November 19, 2008
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