FDA Honey Fraud Report from Dec-2022 : Review of the Country-Level Test Results (Part 2)

This is part 2 of our FDA honey fraud report review. This follow-up blog post reviews the data set. FDA’s ‘sampling assignment’ was to review test methods and measurement output. FDA was NOT intending to gather enough information for a country-level judgement of honey fraud.

Our part 1 blog post covered the new FDA report, all the mentioned attachments, and supplemental materials. The test result data had so many aspects to consider that it is addressed separately in this blog post. The first section will review the sample collection report, the second section will review the supplemental import alerts, and the third section will review the two combined data sets.

As I’ve mentioned, it is ALWAYS wise to know what topics are emphasized by government agencies.

Section One: FY21/22 Sample Collection and Analysis of Imported Honey for Economically Motivated Adulteration

It is human nature to see a headline or a data set and make broad assumptions or quick conclusions. That might be helpful in our day-to-day activities, but when analyzing data, we need to be more methodical or literal.

When considering a new data set, we should think about some questions:

• What is given and what is NOT given?
• What does it say, and what does it NOT say?
• What was the intent of the research project, and what was NOT the intent?

Before making any conclusions let’s review the details:

• The ‘sampling assignment’ was conducted from January 2021 to March 2022, with the final report published in this ‘Constituent Update’ on December 14, 2022.
• This was NOT a response to a specific incident and is NOT a new concern about this product.
• This was an ongoing review of honey adulteration: “The FDA routinely assesses imported honey products to ensure accurate product labeling and otherwise help keep consumers from being deceived.”
• The agency collected and tested 144 samples of imported honey from bulk and retail shipments from 32 countries. “The sampling was designed to identify products that contained less expensive undeclared added sweeteners, such as syrups from cane and corn. The FDA found 14 samples (10%) to be violative [a violation of a law or regulation, and in this case, honey food fraud].”

After reviewing those details, let’s look deeper to see what conclusions we can make:

• This report was 880 words and published on an agency web page. This is efficient for an agency report of findings but very short for an academic research paper. This report was not positioned as a deep, scholarly review. The results were not published in a peer-reviewed, refereed scholarly journal (at least not yet).
• This FDA report provided no detail on the sampling plan, such as if this was a random sample of all imports from a country or if this was from a targeted group or type of source.
• FDA acknowledged that this data applies only to the sample collected for several reasons. “The agency cautions against making inferences or comparisons based solely on the Figure 1 data [presented in the full FDA report] in view of the small sample sizes and the fact that the agency did not design the assignment for such purposes [such as estimating the amount of fraud in a country].”
• While 144 samples might seem like a lot, this is a very small sample size to judge the exports for an entire country (e.g., 144 samples for 32 countries are an average of only 4.5 samples per country).
• Also, it was clearly stated that the ‘sampling assignment’ was NOT conducted to evaluate the country’s propensity for honey fraud.
• Next, understanding the FDA test method is important: “The FDA used Stable Carbon Isotope Ratio Analysis (SCIRA) to analyze the organic composition of each honey sample to determine whether the honey was in compliance.”
• The Discussion section stated, “The results of this assignment reaffirm the need for the agency to  continue to test imported honey for economically motivated adulteration [food fraud, adulterant-substances] under the agency’s risk-based import entry screening program.”

The conclusion, following FDA’s emphasis, is that (1) FDA is testing for honey food fraud and (2) they use Stable Carbon Isotope Ratio Analysis (SCIRA) tests.

• Comment: it would be wise for a food manufacturer to at least occasionally do some SCIRA tests on your honey.

Further, even though the sample sizes were not intended to be representative of a country, it is interesting to see the countries that are on the FDA radar.

• Comment: This list of source economies should be a starting point for a honey importer to be aware of if you buy from those countries.
• Comment: This is a list of countries of FOCUS and NOT necessarily countries of concern. Some countries may have been selected because of high import volume or other factors. TWENTY-ONE of the forty-four countries had NO bad honey fraud tests and NO import alerts.

Section Two: Honey – Import Alert 36-01 “Adulteration of Honey”

FDA has an online and publicly available “List of firms and their products subject to Detention without Physical Examination (DWPE) under this Import Alert (a.k.a. Red List). This data will be reviewed in the table in section three.

Section Three: Data Analysis by Country and Results of the (1) Honey Samples and (2) the Import Alerts

The two data sets were combined to present this in one table. For the honey test data, the result is the percentage of fraudulent products found in a single country. For the import alerts, the result is the percent of all the import alerts from all countries.

Logically, countries that had more import alerts were the focus of more honey adulteration tests.

• Comment: Again, the key is to be aware of the countries where the FDA found the highest number of concerns. These countries will seemingly have a higher level of FDA monitoring and concern.