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Special Edition - Honey Adulteration
An emerging global fraud - China stands accused - The complete report
PART N°1


The English translation of the document, "Le scandale de la falsification de miel", follows.

This work was done, free of charge, by one of our members and not by a translation service. So, if it is not absolutely perfect, please be indulgent. You can always consult the original French document if something is not completely clear.


1. INTRODUCTION

From the beginning of this century, there have only been a few known cases where commercialised honey was not pure and natural.

In Germany, between the two world wars, to help offset poverty, the regulations officially allowed under another name, the commercialisation of an industrially produced honey substitute. The situation was clear: there was no attempt to disguise the product as the label was clearly marked "artificial honey".

There rests something somewhere of this in the collective memory. Despite the European directive 74/409, designations such as: Beekeeper’s honey or Bee honey etc. are frequently found, east of the Rhine.

Such terminology is redundant, as the use of the word "honey" is illegal when applied to products that are not 100% the result of honeybees collecting activities on plants.

During the years of occupation in France, as in other countries at war, there were unscrupulous people that "stretched" or "made" so called "honey" by various means.

From the 1950s until the middle of the 1980s, throughout the whole world, commercialised honey was pure. Exceptionally and at anecdotal level, in the middle of the1970s, several importers signalled the passage of a few doubtful lots, coming from the USSR in particular, but this was never proved.

N.B.: There are some exceptions, for example, North African countries. Taking into account the poverty and the continual demand, sugar syrups that are labelled in a less than clear manner are frequently found in this region. It appears that evens, the consumers are not fooled and such activity is "part of the game".

The diverse regulations, Global (codex), European (directive 74/409) or those that relate to individual countries are generally relatively clear and explicit:

Honey: it is a product harvested by bees from plants (and as such it possesses the plants characteristics); it is 100% natural and nothing should be extracted or added to it.

Overall, this situation has been respected. Even more, from an economical point of view, there did not exist at this period of time, products or the technology that enabled large-scale fraud to take. It is for this reason that until the middle of the 1980’s, whether wholesale or in pots for the consumer, the regulations controlling the meaning of honey were satisfactory.


2. 1984/1985 – A NEW EXPORTING COUNTRY

It was at this moment in time that China, previously absent from the export market, was able practically from one day to the next, using the practice of price dumping to become the World’s primary honey exporter (after removing re-exportations, » 50% of world

Exports of honey in barrels are in the hands of the Chinese).

Immediately the Chinese honey resulted in a certain number of questions being posed by specialised laboratories in the west. In effect, certain aspects of this product presented particularities that caused suspicion

1. Under the microscope, the pollen spectrum appeared systematically "charged" with numbers inactive yeast.

A "normal" honey in this state should have systematically presented the physical signs of advanced fermentation, whereas, in the case of the Chinese honey the yeast were "dead".

2. Still under the microscope, the honey appeared "dirty" with numerous traces of earth, as if soil had been incorporated into the product.

In these countries, there is no pumping, decantation or filtering during the process of extraction, which is done by hand, in hygiene conditions that are inconceivable in Europe. This leads to inevitable thoughts of an extraction taking place in the open air or in a building with an earth floor. Honey that is spilt is collected without any precaution. The particles of earth, too fine to be held back by the tubular filters of the conditioners, are then found in the pots of honey destined for the consumer.

3. Occasionally anomalies are found as, for example, abnormal index levels of diastase:

4. The systematic presence of iron oxide in considerable quantities: an average of 40 mg/kg with peaks of 100 to 200 mg.

According to research done by the laboratories of the DGCCRF in Talence, and under the reserve of complementary work, it was not the barrels that were responsible for this contamination. Rather causes further back in the production system. The Chinese depots?

5. On another register: frequent evidence of chemical residues, the most common being CDF (Chlordimeform), thought to be used extensively and directly in the hive interior as a veterinary treatment.

6. Last but not least, this product arrived (and continues to arrive, alas) in non-food grade bonded barrels. In the worst cases, certain importers have had the surprise to receive their honey in containers, which have apparently contained mineral oils.


3. THE EVOLUTION OF QUALITY CONTROL

The first proof that honey falsification using exogenic sugars had already been uncovered in the U.S.A. during the 1980’s, thanks to a method put in place by White and Doner in 1978(see references).

Basis of the analytic analysis:

In effect, certain pure honeys (often monofloral such as acacia, for example) have a value of d 13C higher than –23.5‰. In fact another type of honey, falsified in the laboratory up to a level of 12% with added sugars was able to pass the normal test of d 13C.

It was due to this situation that research continued resulting in 1989 with the publication of the "Jonathan White and Kenneth Winters method"(see references).

As well as measuring the d 13C of sugars, they measured the proportion of C13 in a protein fraction from honey resulting in way in the creation of an internal standard.

In this manner, a difference between the d 13C value for protein and d 13C value for sugar found in honey of -1‰ or more, indicates adulteration.

If it is wished to the debate in more detail, the % of C4 sugar may be determined by using the following mathematical formula:

%Sugar C4 = {[ d ¹³Cprot. -d ¹³C honey] / [d ¹³Cprot. – (-9.7)]} x 100

Taking into account the natural variability of honey, the Direction Génerale de la Répression des Fraudes (D.G.C.C.R.F.) consider that adulteration has taken place if the result of the above formula is equal or above 7%( said to be "non conformable"). Between 5% and7%, the suspicion is very high and a "grey zone" is spoken of. It is this allowed margin of error that permits an atypical honey to be classified as conforming to required standards. In fact, in the majority of cases, the results of honeys situated in the "grey zone" give witness to the quantity of honey that has been adulterated, but at low doses of added sugar. This may be due to the original fraud being "diluted"(sometimes in total ignorance) by the conditioner, who will have mixed honeys of several geographical origin, with only one of the lots being adulterated by the exporter (see the table of results).

It is only when the result of the mathematical formula is below 5% that is deemed certain that a truly natural honey is being dealt with.

This technique has become the official method for the Association of Official Analytical Chemists, registered in 1991under the n° 991-41. It is used throughout the world, and for the moment the most fallible and economic.


4. THE MOST EFFICIENT METHODS OF QUALITY CONTROL ARE NOT BEING USED BY THE MARKET

In Europe, several operators continue to the present day to use the technique C13/Honey without the proteins (that is to say the 1978 method of WHITE and DONER). The laboratories very quickly recognised that they were against technicians that were wily and skilled. Effectively, with each alert, their clients who imposed their new conditions of quality informed the Chinese suppliers. In this manner, when it became an obligation to supply hone y at levels of –23,5 ‰ or lower, it was a great surprise to discover results uniformly between –23,5‰ and–24‰. That of course gives rise to suspicions. All passed as if the Chinese were becoming more sophisticated in their fraudulent methods, as if they had entered a chase with the quality control laboratories. In fact, at the beginning of the Chinese exportations, the large majority of the results were around -25 and -26‰… hence progressively the adoption of the more complete AOAC method for the more scrupulous operators. (See the tables kindly supplied by the laboratories Eurofins).

To conclude, the fraudsters and the controllers are now engaged in a mad race, with only a handful of specialists mastering the situation. Faced with this situation, most European economic operators (conditioners or importers), utilise the control technique that suits their purpose, that is the least efficient: the Hybrid Method, popularised in England by EUROPA SCIENTIFIC (see sec.7).


5. THE LEGAL ASPECT

The work of the importers and the conditioners is not simple.

In Europe, the legal guidelines, that is to say the directive 74/409 European Union from the Council of European Countries of 22nd.July 1974 relates to the harmonisation of legislation concerning honey in all member countries. (See annex)

At this time the controls depended upon:

  1. on melisssopalynologic analysis techniques which have not made much progress since that time ;
  2. on diverse measurements, humidity, HMF, conductivity, diastase index, etc…
  3. and on the analysis of sugars which, initially was done by: paper, thin layer or gas chromatography.

The first two have long been obsolete, only the GPC (gas phase chromatography) is still applicable. It is being progressively replaced by HPLC (high performance liquid chromatography). This process is much more "economic" since it is faster in producing results but is also far less precise (more than a 5% margin of error).

Since then, the methods of adulteration detection have called upon apparatus and techniques, which did not exist in 1974 (neither did the recipes or the sugar additives of the fraudster). Moreover, at least until recently, all the analytical techniques have been developed and put in place in North America. There is due to this situation, two totally contradictory analytical jurisdictions.

Only the approved regulations and methods are opposable before a tribunal (that is to say regarding honey in Europe, the Directive 74/409 and its’ annexes). Consequently, the operators governed by these rules and these rules alone are able to fraud in total security. They are able to find a legal level (national or European) that proves them right. Fraud is legalised since the economic and industrial world evolves more rapidly than the regulations.

Radically different, postulates the position that, even when not yet officially recognised, it is always the most modern and accurate scientific method that should have ultimate legal precedence.


6. REGARDING MELLISSOPALYNOLOGIC ANALYSIS

Palynology (the study of pollen as practiced amongst others, in archaeology and paleobotany) was born over a century ago (1). Mellissopalynology, developed in the year’s 1950/1970(in particular by Dr. LOUVEAUX) has nothing other than the application of palynology in honey studies. It is a basic analytical method, practiced in 95% of commercial transactions. It costs between 150 and 300 Frs., according to the laboratory and the required degree of precision.

This examination takes place under a microscope.

Starting with an existing and known reference, it allows:

  1. to say if the pollen spectrum is "normal" for a natural honey;
  2. the determination of geographical origin. It is by far the simplest way once the analyst has references (as long as they are 100% absolute and true);
  3. to say if the product merits or not the name of a monofloral honey, this being simple but largely subject to interpretation (hence a use of law becomes problematic: interpretation is difficult to support in law).

As one sees, one is far from the precision of a chemical examination with the evaluation of a chromatographic peak or the help of a mathematical formula. One does not become a really competent mellissopalynologist until after several years of daily practice. As well, one is not competent unless one has the habit of studying. A technician working on European honeys will be only mediocre when working with honeys from Australia or New Zealand and visa versa. Before, there was at least in France, several researchers, especially with INRA, who were specialists in this sort of examination. Today, there remains to our knowledge, only:

It happens of course that private company technicians participate in programs of research with public institutions. However, in these conditions, the company that employs them is proprietor or co-proprietor of the work. However only the helpful results will be published. The results that would possibly cause problems economically to the employer rest of course inaccessible to the public and confidential (it is a situation that we know well, having dealt with phyto-sanitary companies during the tests on new products, or treatments in the open air regarding toxicity problems and bees).

Hence one has passed from nearly 10 independent mellissopalynologists in the 1960’s, to less than 5 today.

Of course, one must be aware in another setting and logic, the paper of J.D.KERKVLIET et AL, recently published in APIDOLOGIE, concerning "Le diagnostic en microscopie de la falsification du miel par du sucre de canne et des produit à base de sucre de canne". It discusses in a novel, original and promising way the use of. Even so, for the moment one is only at the level of fundamental research, and therefore there is no practical application as yet.

(Note: due to the presence of honey recovered in the tombs of the pharaohs, it has to a large extent been possible to reconstruct the type of vegetation present at that time.)


7. THE MARKET AND THE WAY IT FUNCTIONS

Faced with an increasingly unclear legal situation and the impunity of the fraudsters, a certain number of operators have " gone in the wrong direction". They have "imposed" upon their Chinese suppliers the required conditions of quality including of course the directive 74/409 plus a " "hybridisation" between

This comes about in the following way:

One is able to see the pertinence of this method by looking at the table kindly supplied by EUROFINS of statistics of their own analyses over several years.

STATISTICS ON HONEY ANALYSED BY THE LABORATORY EUROFINS IN ACCORDANCE THE AOAC METHOD

Honey samples where d 13C (honey) is < -23.50

Number of samples

435

Number of samples – non-conforming

76

Percentage

17%

From 435 samples, 76 i.e. 17% produced a result lower than -23.50 proving to be non-conform

If one had applied the hybrid method described before, these 17% of honeys would have been considered conformable.

Honey samples where d 13C (honey) is between -23.50 and -21.50

Number of samples

151

Number of samples – non-conforming

95

Percentage

63%

From 151 samples situated between -23.50 and -21.50, 63% are considered non-conform after the protein test (internal standard).

Only these honeys would have been classed as non- conforming according to the hybrid method described before.

Honey samples where d 13C (honey) is less negative than –21.50

Number of samples

41

Number of samples- conform

1

Percentage

2%

In contrast, even if it is anecdotal, it is convenient to note that only 1 honey out of 41, i.e. 2% having been declared non-conform according to the hybrid method would in fact have been conformable.

It can easily be seen, from these results, that the hybrid method is a handy method to ratify the conformity of corrupted honey thereby enabling it to be supplied at a low price.

This hybrid method which, has not been the object of any publication to our knowledge, has a history. We have few details, but it may be reconstituted approximately in the following way:

Note Today, Eurofins charge AOAC analysis at the price of 560Frs. (Ex.vat.) (JOM package)

In Germany, the hybrid method 400 FFrs., AOAC method 600 FFrs.

As one can see the price has fallen considerably due to competition, and therefore there is nothing to justify the continued use of a notoriously inefficient method.

The continued use of an inefficient method serves only one purpose: to allow the importers to easily find the necessary volumes at a very low price,

One should know that:

  1. The principal English and German are perfectly conscious that the hybrid method "does not hold water in the scientific world".
  2. In England the Trading Standard Offices, decentralised establishments with officers of control, use the AOAC method in the investigation of honey. This does not stop Europa Scientific from selling a n inefficient method…as long as there is no risk of poisoning, this country has little traditional strictness in the field of food-stuff control when applied to private businesses. This worry regarding hygiene is not always absent! The mention "unfit for consumption by babies less than 12 months" has become habitual on pots of honey in this country. This is to stop the stomach upsets of infants, who have always accepted very well bottles sweetened with honey BUT certainly find it more difficult to digest the Chinese molasses. (This labelling result from a voluntary code of practice put in place by the British conditioners. Motivated by the fear of bacterial spores. Even so they have considered that this situation was not needed for baby foods since the fabrication processes gave guaranteed protection. Recall that the risk of bacterial contamination is thought to be nil with real honey even if it has not been heated).
  3. Other countries of the European Union do not appear to be overall concerned by the problem of analysis. One exception: France. During 1991, the DGCCRF pointed out, besides numerous "classic" anomalies, the adulterations by adding exogenic sugars… did not appear in general to trouble the courts (since the cases were not taken up!), as the fines were inferior to the profits made by the fraud.
  • The fore-mentioned description supposes, of course, a perfect set-up. In reality, of course, it is a little different, and, it is not rare that things run in the following way:

In the case, (apparently relatively frequently) where the merchandise has absolutely no correspondence with the sample, what happens?

The only solution is therefore to mix the "product" with a sufficient quantity of pure and veritable honey, to enable it to pass the threshold of detection if analysed.

Hence, when one finds 20 to 30% of non-conformity in the cheapest priced honeys in the supermarket shelves, it is in fact only the tip of the iceberg. In reality the level of fraud is greater, but, in the absence of controls and customs confiscation at point of entry of the non-conforming honey, the system, as it organised, cannot produce anything other than: fraud, cheating, traffic and trickery in the chain of affairs.

This situation is confirmed in the conclusion of the information note no.1802 of the DGCCRF dated the 9/4/1997:

"A non-negligible quantity of honey already adulterated penetrates the French market and the operators do not always put in place the necessary methods for their detection. Taking into account the often important quantities of imported honey from suspect origins, the operators should show more prudence and only accept to pay for such products under the reserve of verified conformity by analytical methods ad hoc (RMN/SMRI…) carried out by laboratories that exist in France and are then presented with this certification.

In fact, the search for competitively priced products sometimes drives certain importers to acquire falsified honey (presence of starches and ashes…). It is therefore necessary to maintain high standards of vigilance in this sector (for example, honey deemed to be used in " industry" is able to enter in to the conditioners’ market supplying" table honey."

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