Many beekeepers use terms like raw, natural, local, and organic to describe their honey. These words are great for marketing, and show that beekeepers understand that today’s consumer is savvy to honey fraud and contamination concerns. One of these terms is not like the others, however. While any beekeeper using any practice can technically use the terms raw, natural, and local, the term “organic” stands apart. It is a regulated term with federal guidelines and consequences for its misuse.
This regulation has not stopped beekeepers and bee bloggers from misusing the term all over their labels and the internet; many beekeepers and writers throw the term “organic” around as synonymous with “natural,” or even “treatment-free,” ignoring the true definition of the word. It is important for beekeepers and consumers alike to understand what the term really means for beekeeping, as there are many areas where organic practices intersect with beekeeping and honey production: Honey can be labeled as organic, hives can be kept on organic farms, and honey bees can be managed using organic practices and treatments. The term organic and how it relates to beekeeping is often misunderstood in all of these areas.
To understand the term “organic,” we will have to have a little alphabet soup, the UDSA AMS NOP — The United States Department of Agriculture (USDA) has the Agricultural Marketing Service (AMS), which runs the National Organic Program (NOP). The NOP was established by Congress (U.S. Code 7 Chapter 941) as a federal regulatory program that develops and enforces uniform national standards for organically-produced agricultural products sold in the United States.
The organic certification process
If you want to use the word “organic” to describe your bee practices or your honey, then you have to be certified. If you are not certified organic, you must not make any organic claim on the principal display panel or use the USDA Organic Seal anywhere on the package. If you use the term or the seal and you are not certified, you can be fined. People who sell or label a product “organic” when they know it does not meet USDA organic standards can be fined up to $17,952 for each violation.2 While it may just feel like another layer of government oversight, enforcement is important to maintain consumer confidence in the integrity of the USDA Organic Seal. Consumers specifically look for the organic seal because they know that there are meaningful standards behind it. If people misuse the organic term or seal to label products that haven’t been certified, then the term loses its meaning.
Anyone can be certified as USDA organic, regardless of where in the world they are located. The USDA National Organic Program (NOP)3 outlines the certification process.4 The certification process is a public-private partnership. The NOP accredits third-party organizations to certify that farms and businesses meet the national organic standards, and maintains lists of USDA-Authorized Organic Certifying Agents.5 The first step is to contact a certifying agency. Agents can also be found through the NOP database of certified operations6 by searching “honey” in the “Certified Products” field. The agent will help you develop an organic system plan that details how all of your practices will comply with organic requirements. This means you will need to outline details of your animal care, harvest, storage, and transport. You’ll need to keep good records and develop barriers to keep organic products and non-organic products from co-mingling.
The certifying agent will send someone to come and inspect your operation. These comprehensive inspections will look at everything from your preventive health management practices, to the storage areas at your processing facility. The findings will then be compared to your submitted organic system plan. The inspector will also present an assessment of the risk of contamination and analyze potential hazards. If the certifier finds that your operation complies with the rules, the certifying agent will issue an organic certificate that lists the products that can be sold as organic from your operation. You will have to be inspected at least once a year to maintain your certification, and you’ll have to update your plan as you change any practices. If you produce less than $5000 worth of organic product, you are exempt from the formal certification process, but you still must follow the requirements to have your product considered organic.
Requirements for organic honey
There are no federally accepted organic guidelines specifically for honey bees, but there are guidelines for other livestock and draft guidelines for honey bees. Therefore, the Agricultural Marketing Service of the USDA has issued a written statement affirming that your beekeeping operation may be certified as organic if a certifier determines that your operation follows the guidelines for other livestock and the draft guidelines for bees. The guidelines for organic livestock are in the Electronic Code of Federal Regulations (Title 7 Subtitle B Chapter I Subchapter M Part 205 Subpart C Sections 205.236 to 205.240 USDA organic regulations for the scope of livestock production7). These sections outline requirements related to the origin of the livestock, livestock feed, health care practice standards, living conditions, and pasture standards. These requirements cover things like use of feed additives as well as ensuring that sufficient food is continuously available.
In 2010 the National Organic Standards Board (NOSB) developed a draft apiculture practice standard that includes parameters specific to beekeeping and honey production.8 While USDA organic regulations have not yet been formally amended to accept these standards, certifiers can still use these draft recommendations. The Apiculture practice standard outlines requirements for the origin of bees, the construction of equipment, and the land where the bees are kept. Below is a summary of some of the key requirements. For a full list, see https://www.ams.usda.gov/sites/default/files/media/NOP%20Livestock%20Final%20Rec%20Apiculture.pdf.
Transitioning bees and equipment: It takes at least a year to transition your apiary to ensure that the bees and the equipment/comb are fully under organic management. At the beginning of the one-year transition, foundation wax must all be replaced and new comb must be produced by bees under organic management. The foundation can be organic wax, plastic foundation dipped in organic or conventional wax, or organic or conventional wax. Once the apiary is organic, however, all the foundation must be made out of or dipped in organic wax. Queens do not have to be from organic sources, but the bees do if you are replacing more than 25% of your colonies, and you do not collect honey from them for at least 60 days.
Location: Beekeepers also have to include maps of their apiary locations to demonstrate that the bees will be foraging on land that fits organic standards. These maps have to outline a “Forage Zone” and a “Surveillance Zone.” The forage zone is the area within a 1.8 mile (3 km) radius that provides the bees with water, nectar, pollen, and propolis. The surveillance zone is a 2.2 mile radius (3.4 km) beyond the forage zone that may not contain high risk activities. High risk activities include …