Tell the FDA honey does not have "Added Sugars”

American Honey Producers Association NEEDS YOUR HELP -

Tell the FDA honey does not have "Added Sugars”

As you are likely aware by now, the FDA released a rule last year changing nutrition guidance on packaged products, including honey.  They have since released more detailed guidance (attached here for your review, if needed).  

As it stands, the FDA, beginning in 2018, will require packaged honey to include on the nutrition label both “Total Sugars” and “Added Sugars”.  However, they do not distinguish between the two and so 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”.  

To say this will confuse consumers is an understatement.  What is “Added Sugars”?  The FDA means added to your diet.  What do you think consumers will think that means?  We think consumers will think it means sugars have been added to the honey that are NOT naturally occurring in the honey.  And thanks to the National Honey Board, we have studies to prove it.  Studies we have presented to the FDA, but they have ignored.  

Now is the time to let FDA know your thoughts.  The guidance is subject to a comment period and agency review before being finalized.  

Please take 5 or 10 minutes before March 6th to write to the FDA now and ask them to exempt honey from the “Added Sugars” labeling requirement!

Instructions:

Click on this link and submit your thoughts:   https://www.regulations.gov/comment?D=FDA-2016-D-4414-0002
What to include:
You can be as brief or elaborate as you want, but include:
Who you are
Where in the country you are located
What you do? Beekeeper, commercial honey producer, packer etc.  
How long you have been in the business
A statement that you believe putting “Added Sugars” on the packaged honey label will confuse consumers and harm the market for honey
Any other points you think would be helpful, including from the below list of “Key Messages”
Key Messages:

The honey industry supports and applauds the FDA for its continued commitment to informing consumer food choices through the nutrition facts label.
Made by bees from the nectar of flowers, honey adds a hint of sweetness with a distinct flavor to beverages and recipes.
We recognize that honey is a source of sugar added to foods; however, there is nothing added to pure honey itself.
Listing the sugar content in honey as “Added Sugars” on the nutrition facts label implies adulteration of honey in its natural form.  
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.
Consumers will be misled to believe that honey is sweetened by adding an external sugar source rather than the naturally occurring sugars inherent in honey.
There is a risk of consumer confusion if the nutrition facts label notes “Added Sugars” but a separate area on the label notes “naturally occurring sugar.” By definition, something added cannot also be naturally occurring.  Our research shows that this will cause consumer confusion that hinders their ability to make informed food choices.
We realize that honey is added to foods in preparation or manufacturing and in that case it is clearly an added sugar in those foods and would therefore be labeled as “Added Sugars” on the Nutrition Facts label.  However, pure honey, itself, does not contain added sugars.
We share the desire for clear, understandable nutrition information to aid consumer choice.
Our desire, as is the FDA’s, is to inform consumer food choices to promote public health without confusion or misbranding around pure honey
To that end, we are asking that the FDA consider listing the naturally occurring sugar content of 100% pure honey as a “Total Sugar” and not “Added Sugars.”
Download:   Draft Guidance for Industry Questions and Answers on The Nutrition and Supplement Facts Labels Related to the Compliance Date, Added Sugars

https://ahpanet.site-ym.com/resource/resmgr/ahpa_documents/Draft_Guidance_For_Industry-.pdf