Label Regulations Headaches For New Beekeepers
(*This was originally written for a meeting which was for the Ottawa Beekeepers meeting which didn’t happen so it’s been laying around for the past 2 years.)
Note: First off I want to clarify that anything written here is my perception of the regulations from reading the regulations and from email conversations with staff at the OMFRA. Although I feel they are correct, it’s always best to direct any questions for clarification to the OMFRA staff.
We are new beekeepers in our 6th year of beekeeping, and we have been doing our best reading and rereading the regulations, trying our best to interpret the government code they call honey label regulations. As many of your may have read already, it’s not all so clear to us all, but we do our best to try and understand it all.
So to give you a little background on why I have had to become somewhat knowledgeable about label regulations, we had a visit from an OMFRA inspector accompanied by a local health inspector from our region. They had received a complaint from a neighbor that we were extracting honey in the roadway to other properties. All of which was false as we do like the majority of beekeepers and extract indoors to lessen the hassle of dealing with all the neighboring bees, wasps, hornets, bumblebees, houseflies, etc. I am sure you all know exactly the issues that pesky insects create during extraction. So both ladies wanted to walk through our extraction process and see firsthand how and where we extracted. After seeing everything they were happy with what they saw and dismissed the complaint.
But as usual with government inspectors, that wasn’t the end of it all. They then wanted to do a thorough inspection and wanted to turn to the honey containers and the labels. Firstly they inspected the container and the sizes and they meet the regulations. Then they looked at the labels of each variety of items and looked for many aspects that the regulations covered. The OMFRA inspector found several issues to start out. But instead of listing out all the issues, I’ll try to write this in a form that explains more so the proper way of creating labels as I now understand it.
Firstly, you want to inform yourself with the Ontario Regulations 119/11 which covers the label requirements. If you intend to sell in farmers markets, craft sales, corner stores or grocery stores, these regulations will apply. Anything sold off your property MUST follow the Ontario regulations. Anything sold on your property is considered by several terms like “farm sales”, or “gate sales”. This is walk up customer traffic, and this is the only time you don’t have to follow label requirements. There is mention in the regulations of proper labelling for transporting honey, but I don’t want to get into that.
If you’re only selling only in Ontario, you have to follow the Ontario Regulations 119/11. If you intend to sell outside Ontario, then you run into many other issues, government departments, and new regulations. Selling outside Ontario requires you to register with the CFIA, and now you no longer follow the Ontario regulations, but now fall under the federal regulations. For the most part very similar to the Ontario regulations but with a few other changes and additions. You also have to follow the Consumer Packaging and Labelling Act. More work and more reading. Not something I intend to get into here.
So let’s get into the labels themselves with respect to selling only in Ontario. So you have picked out your jars of regulation sizes and have them filled with your amazing honey. Now you have a couple choices as it comes to labels. You can buy premade labels from a company like Dominion & Grimm which come with a Microsoft Word template to edit and put your details, and print directly onto the premade labels. Or you can do it yourself or hire someone to design labels from scratch and have them printed. That’s up to you, but each have to follow the regulations.
Below is an example of our first attempt at labels for liquid honey purchased from Dominion & Grimm.
At first look for new beekeepers, the label might look fine. But there are several problems that were with this label.
- The use of “Ontario #1”. Looks good, but Ontario regulators don’t permit the use of the number sign “#’. Regulations require it to actually be “No.” Or in full, “Ontario No. 1”.
- Following the grade, you must have the color. Regulations require both English and French. So for honey color of white, your line should look like “Ontario No. 1 White/Blanc”.
- Using the word “honey” must also be followed in French. “Honey/miel”. If you’re using a long descriptive name, the French translation must also appear.
Those were just a few issues found on our liquid honey labels. Other labels for other products had some of the same issues.
In short, here’s some of the label regulations you MUST follow:
- Company Name
- Contents with the container (English/French)
- Grade followed by color in both languages
- Net Wt.
- (All above must be seen on the front of the container by federal label regulations)
- Produced and Packaged address and contact info
- Nutritional Facts label
- Product of Ontario (for product collected and sold in Ontario)
- (Above 3 can appear on the sides or back of the container)
One issue that our OMFRA inspector brought up with us was that the “Produced/Packed” address listed on the labels had to be our mailing address. I had an issue with this as our mailing address was a post office box at the post office about 20km away. I discussed this with her office staff further and as with any product in the grocery stores, the physical address of where you extract and bottle your honey is what goes on your label. If you have more than one location, you have to clearly mark the location of where the contents were handled. This is because of health issues or hazards that could pop up, and inspectors need to easily identify your processing location if further inspections are required. An example would be like if someone like Maple Leaf meats has Listeria, inspectors want to quickly go to the identified processing and packing plants to do inspecting and stop and further spread or illness. It’s not for government to spy on you but for them to stop any issues that could come up.
So the above is what is required for liquid honey products. Now when you get into selling creamed honey products, all the above regulations also apply to creamed honey. Only difference is that you have to identify your grade and color in liquid form before you convert it to creamed honey.
Now if you’re into doing specialty honey like infused honey of different flavors, or flavored creamed honey, this is where I found the regulations confusing. They OMFRA staff had told me that once you add anything to honey to change color, flavor, etc., it is no longer honey, but a honey substitute. My issue was that in my mind a honey substitute would be artificial sweeteners, corn syrup, sugar, sugar water, or any other product used in place of honey. Substitute by definition means to remove and replace with another product. To me, the use of substitute was improperly used and still today I feel the same way. But according to OMFRA staff, the use of the word substitute didn’t follow the dictionary meaning or what I thought it meant. They decided to create their own interpretation of the word substitute and total confuse the rest of us.
The regulations also mention that any information provided on your label or container cannot be misleading. As you can see in the previous label above, it has the caption “Pure Ontario Honey”. This works well with your liquid or creamed honey. But with infused or flavored honey, you cannot use the word “Pure” as you now have altered the honey making it no longer “Pure”.
As you can see in the above image of a common honey container sold by Dominion & Grimm, it has some questionable issues. Mainly it uses the word “Canadian”. But in the Ontario regulations we generally use “Ontario” over “Canada” or “Canadian”. So I inquired with OMFRA staff to make sure using these containers wasn’t going against their regulations. In my reply, I was told that even the though the word “Canadian” is used, it is not considered misleading and therefore is OK to use. But if the used in terms of honey grade, I don’t think the use is acceptable. In this case it’s just a descriptive word.
If using the above containers, you will have to find somewhere to add the required info needed by the regulations. The lids offer a whited out area to apply a label. Though it’s a rather small area, you have to make due with it. Thankfully the nutritional facts are already printed in the tub design.
After a lot of reading, research and emails back and forth with OMFRA staff, we finally came up with a new brand as well as new labels.
So I only write this to inform you that the regulations don’t always seem what they are and if you have any questions, it’s best to contact the OMFRA directly to clear up any questions. It’s best to get your labels right before you spend a fortune on new labels and to be told you can’t use them because you had something incorrect.
If you want to ask and questions with regards to labels and regulations or have someone inspect your labels and have them give you the ok that they meet the OMFRA requirements, contact them directly through their website. They have been professional, informative and very quick to reply.
Valley Beekeeping Supplies
19H Moores Beach Rd