Driven by a lifelong fascination with bees and a love for all things natural, Gretchen, an entrepreneur with a passion for wholesome foods, took the plunge into the honey business. She wanted to bring top-notch honey to people who appreciate quality, and she set out with boundless optimism and infectious enthusiasm.
But as she dug deeper into the honey trade, Gretchen ran into the wall that stops many good producers: proving her honey is exactly what the label says. Retail buyers wanted a GFSI-benchmarked certificate such as SQF, and she didn't know how far her operation was from one. Her first step was an SQF gap analysis.
Her story is a useful lens on what a gap analysis actually does, and why honey, of all products, benefits from one. Along the way, this guide covers what a honey business needs to know: the hazards to control, the specifications and tests that prove authenticity, the labeling rules, and the steps from gap analysis to certificate.
- 10%of imported honey FDA tested in 2021–22 had undeclared sweetenersFDA, 2022 [1]
- 46%of honey sampled at EU borders was suspected of added syrupEuropean Commission, 2023 [2]
- 20%maximum moisture for most honey under the Codex standardCodex CXS 12-1981 [3]
- 1 yrminimum age for eating honey, per CDC, because of infant botulismCDC [4]
Key takeaways
- A gap analysis is a pre-audit check-up. It measures your current practices against the SQF Code and hands you a ranked list of gaps to close before the certification audit.
- Honey is one of the most frequently adulterated foods. Authenticity, not microbial growth, is the headline risk, so supplier approval, traceability and testing sit at the center of a honey food safety system.
- Honey has real hazards beyond fraud: moisture and fermentation, overheating (HMF), foreign material, drug and pesticide residues, and botulism spores that make honey unsafe for infants under 12 months.
- Honey labels carry extra rules. Only pure honey can be called “honey,” and imported honey must name every country it came from.
- Edition 10 changes your category. Honey moves from FSC 11 to FSC 18, and Edition 10 audits start no earlier than January 2, 2027.
- The gap analysis is where problems are cheap to fix. A gap found in a practice review costs a corrective action; found in the certification audit, it can cost the certificate.
What Is an SQF Gap Analysis?
Think of it as a dress rehearsal with nothing at stake. It is the cheapest place to learn that a procedure is missing, a record isn't being kept, or a claim on your label can't be backed up. You may also hear it called a gap assessment or a pre-assessment.
| Item | Gap analysis | SQF certification audit |
|---|---|---|
| Purpose | Find and rank the gaps between your system and the code | Decide whether your site is certified |
| Who does it | Your own team, or an outside food safety professional | An auditor from an SQFI-licensed, accredited certification body |
| Scored? | No. You get a punch list | Yes, 0 to 100 with a rating |
| What you get | A prioritized action plan | A certificate (or not), plus non-conformities to close |
| Best timing | Before you build the system, or with time left to fix what it finds | After the system has run long enough to produce records (SQFI recommends at least 90 days) |
| What's at stake | Nothing | The certificate, and the customers who require it |
Why Honey Is a Food Safety and Food Fraud Priority
Gretchen's first pain point was sourcing. With honey coming from different regions and suppliers, keeping quality and authenticity consistent was hard, and the risk of unknowingly buying adulterated honey was real.
That risk isn't hypothetical, and it's the first thing her gap analysis had to address.
From January 2021 to March 2022, FDA tested 144 samples of imported honey from 32 countries and found 14 (10%) contained undeclared sweeteners such as cane or corn syrup.[1] Its newest round, released in April 2026, found about 4% of 102 domestic and imported samples violative, and FDA notes that its test detects only a subset of added sweeteners.[5]
Europe's numbers are starker. In the EU's “From the Hives” action, 147 of 320 honey consignments (46%) sampled at the border were flagged as suspected of containing sugar syrups, including 66 of 89 from China.[2] “Suspected” isn't proof: the results were qualitative, and a later UK government review cautioned against reading them as confirmed fraud.[6] Germany's Max Rubner-Institut puts it plainly: “Honey is one of the most frequently adulterated foods.”[7]
Origin fraud is the other half of the problem. U.S. antidumping duties apply to honey from China and, since 2022, to raw honey from Argentina, Brazil, India and Vietnam, which gives dishonest traders a reason to disguise where honey came from.[9] In 2013 the Justice Department charged companies and individuals who avoided more than $180 million in duties by passing off Chinese honey as product of other countries.[8] Our guide to the top food fraud products and what SQF requires covers the controls that catch it.
Authenticity is the headline, but honey has other hazards a food safety system has to control:
| Hazard | Type | Where it comes from | What controls it |
|---|---|---|---|
| Added sugar syrups | Fraud | Syrup blended into honey, or bees fed syrup during a honey flow | Approved suppliers, authenticity testing, food fraud vulnerability assessment |
| False botanical or country origin | Fraud | Blending or transshipping through a third country; filtering out pollen to hide origin | Traceability to the source, origin records, pollen or origin testing, mass balance checks |
| High moisture and fermentation | Quality / spoilage | Unripe honey; humid storage; water freed as honey crystallizes | Moisture specification, refractometer checks, sealed containers |
| Overheating (high HMF) | Quality | Too much heat or long, warm storage | Time and temperature limits; HMF testing |
| Veterinary drug and pesticide residues | Chemical | Antibiotics and miticides used in hives; crop sprays | Supplier controls, certificates of analysis, residue testing |
| Foreign material | Physical | Wax, bee parts, wood, glass, metal | Strainers and filters, glass and brittle plastics policy, inspection |
| Clostridium botulinum spores | Biological | Spores from the environment | Can't be removed by normal processing; manage through the hazard analysis and label advice for infants |
| Pests | Physical / biological | Bees, wasps and ants drawn to sugar | Pest prevention program, screened openings, good housekeeping |
Honey Hazards and Controls, Step by Step
Most honey packers follow the same basic flow. Each step adds its own hazards, and an auditor will expect a control and a record for each one. The table below is a starting point for a packer that buys or harvests bulk honey and fills retail jars.
- 01Receiving
- 02Bulk storage
- 03Warming
- 04Straining
- 05Blending
- 06Filling
- 07Capping & labeling
- 08Storage & shipping
| Step | Main hazards | Typical controls | Records the auditor will ask for |
|---|---|---|---|
| Receiving bulk honey | Added syrups or false origin; drug and pesticide residues; high moisture; damaged or rusty drums | Approved suppliers only; certificate of analysis (COA) per lot; risk-based authenticity and residue testing; moisture check with a refractometer; drum inspection | Supplier approval file, COAs, receiving log, test results, lot codes |
| Bulk storage | Moisture pickup and fermentation; bees, ants and rodents; contamination from damaged containers | Sealed, food-grade containers; dry storage; pest prevention program; first-in, first-out rotation | Storage inspections, pest control reports, stock rotation |
| Warming / liquefying | Overheating raises HMF and destroys enzymes (a quality and specification failure) | Set time and temperature limits for hot rooms and drum heaters; calibrated thermometers | Time and temperature logs, calibration records |
| Straining / filtering | Foreign material: wax, bee parts, wood, metal, plastic | Screens or filters of a set mesh size, checked for damage before and after each run | Screen or filter integrity checks, maintenance records |
| Blending | Lots or origins mixed without records; cross-contact if you also make infused or creamed products | Blend sheets that link every input lot to the output lot; allergen controls for flavored lines | Batch and blend records |
| Filling | Glass breakage; foreign material in containers; poor line hygiene | Glass and brittle plastics policy; container inspection or air rinse; pre-start line checks | Glass breakage log, pre-start checklists, cleaning records |
| Capping & labeling | Wrong label, false origin or floral claim, missing lot code | Approved label masters; line clearance and label check at start-up and every changeover | Label verification log, lot coding checks |
| Storage & shipping | Heat damage; leaking or damaged jars; lost traceability | Storage conditions; outbound inspection; one-step-forward shipping records | Shipping and customer records, temperature notes |
An example only. Your own hazard analysis decides which steps, if any, are critical control points.
Honey Quality and Authenticity Specs
SQF expects written specifications for the honey you buy and the honey you sell (clause 2.3.2). The Codex Alimentarius honey standard is the usual starting point. It also says honey must not have begun to ferment and must not be heated so much that its composition or quality suffers.[3]
| Parameter | Codex limit | Status | Why it matters |
|---|---|---|---|
| Moisture | ≤ 20% (heather honey ≤ 23%) | Main standard | Wetter honey ferments. FAO notes honey under 18% water stores with little or no fermentation risk.[10] |
| Fructose + glucose | ≥ 60 g/100 g (honeydew ≥ 45) | Main standard | Low values can point to dilution or added sugars |
| Sucrose | ≤ 5 g/100 g (≤ 10 or ≤ 15 for named floral types) | Main standard | High values can point to sugar feeding or added sucrose |
| Water-insoluble solids | ≤ 0.1 g/100 g (pressed honey ≤ 0.5) | Main standard | Shows how well wax and debris were strained out |
| HMF | ≤ 40 mg/kg (tropical origin ≤ 80) | Voluntary annex; mandatory in the EU | Rises with heat and age, so it flags overheating and old stock |
| Diastase activity | ≥ 8 Schade units (low-enzyme honeys ≥ 3) | Voluntary annex; mandatory in the EU | Heat destroys enzymes, so low values flag overheating |
| Free acidity | ≤ 50 meq/kg | Voluntary annex; mandatory in the EU | High acidity can signal fermentation |
Limits from the 2001 revision of the Codex standard. Codex lists the standard as last amended in 2022; confirm current values with your lab before you set specifications.
In the U.S., USDA's grade standards for extracted honey are voluntary, but if you put a grade on the label the honey has to meet it.[11]
| U.S. grade | Maximum moisture | Minimum score (of 100) |
|---|---|---|
| Grade A | 18.6% | 90 points |
| Grade B | 18.6% | 80 points |
| Grade C | 20.0% | 70 points |
Graders score flavor and aroma (50 points), absence of defects (40) and clarity (10).
Authenticity tests and what each one can miss
| Method | What it detects | Limits |
|---|---|---|
| C4 sugar test (stable carbon isotope ratio, AOAC 998.12) | Cane and corn syrups. This is the test FDA uses on imports. | Detects about 7% added syrup and up; can't see rice, beet or wheat syrups[12] |
| LC-IRMS (isotope ratios of individual sugars) | Rice, wheat and beet syrups as well as cane and corn | Can wrongly flag some genuine honeys, such as manuka[6] |
| Syrup-marker tests (LC-HRMS), e.g. AFGP for rice syrup | Chemical markers left by specific syrups | Markers vary by syrup; some syrups carry very little; bee feed can leave traces[6] |
| NMR profiling | Compares the sample with a reference database for authenticity and origin | Only as good as its database; experts disagree on how to use it[12] |
| Pollen analysis (melissopalynology) | Floral source and, indirectly, country of origin | Filtering out pollen defeats it[13] |
| Standard quality tests (moisture, sugars, HMF, diastase) | Fermentation, heat damage, gross adulteration | Won't catch a well-made syrup blend |
No single result proves honey is authentic. Experts weigh several methods together.[6] That fits what SQF's food fraud clause (2.7.2) asks for: a vulnerability assessment and a mitigation plan that combine supplier approval, origin records and risk-based testing at labs accredited to ISO/IEC 17025 or an equivalent standard (2.4.4).
Bee medicines and residue limits
Since January 1, 2017, the three antibiotics approved for honey bees can only be used under a veterinarian's order.[14] Ask suppliers which treatments they use, and make sure their certificates of analysis cover them.
| Drug | Status for honey bees | U.S. tolerance in honey |
|---|---|---|
| Oxytetracycline | Approved; veterinarian's order (VFD or prescription) | 750 ppb (sum of tetracyclines), 21 CFR 556.500 |
| Tylosin | Approved; veterinarian's order | 500 ppb, 21 CFR 556.746 |
| Lincomycin | Approved; veterinarian's order | 750 ppb, 21 CFR 556.360 |
| Chloramphenicol | Not approved; extralabel use prohibited | No tolerance. Any residue makes honey adulterated, and imports are detained under Import Alert 36-04[16] |
Tolerances from 21 CFR Part 556.[15]
Selling into the EU? From June 14, 2026, honey blends sold in the EU must list every country of origin in descending order with its percentage share.[17] Your traceability records need to support those percentages.
What an SQF Gap Analysis Checks in a Honey Operation
When Gretchen worked through her gap analysis, the reviewer looked at every stage of her business, from sourcing and extraction to processing and packaging, against the SQF Food Safety Code.
Here is what that looks like for a honey business, clause by clause, with the gaps that turn up most often.
| Area | SQF clause | What the auditor looks for | Common gap in honey operations |
|---|---|---|---|
| SQF practitioner | 2.1.1.4–2.1.1.5 | A primary and a substitute practitioner, both employed by the site and HACCP-trained | The owner does everything; there's no substitute and no HACCP course on file |
| Specifications & labels | 2.3.2 | Written specs for bulk honey, jars, lids and finished product; labels that are accurate, legal and approved | No moisture or HMF limit; floral or origin claims with nothing to back them up |
| Approved suppliers | 2.3.4 | An approved supplier list; incoming honey verified by COA or testing; risk-based supplier audits | Buying through brokers with no origin records or authenticity results |
| Food legislation | 2.4.1 | Products meet the law where they're made and sold; SQFI and the certification body told within 24 hours of a regulatory event | Labels never checked against FDA's honey guidance; country of origin missing on imported honey |
| Food safety plan | 2.4.3 | A HACCP plan built on Codex's 12 steps by a team that includes the practitioner | A generic template that ignores adulteration, residues and glass |
| Testing | 2.4.4 | Recognized test methods; outside labs accredited to ISO/IEC 17025 or an equivalent standard | Authenticity results from a lab with no relevant accreditation; no testing schedule |
| Verification | 2.5.1–2.5.4 | Validated limits, a verification schedule, root-cause corrective actions and a full internal audit at least once a year | Records are filled in but nobody reviews them; no internal audit |
| Traceability & recall | 2.6.1–2.6.3 | One step back, one step forward; the recall system tested at least once a year | Blending breaks the lot trail; no mock recall |
| Food defense | 2.7.1 | A threat assessment and a food defense plan, reviewed and tested every year | Bulk tanks and drums left unsecured |
| Food fraud | 2.7.2 | A vulnerability assessment covering substitution, mislabeling, dilution and counterfeiting, plus a mitigation plan, reviewed every year | Honey never named as a high-risk raw material |
| Training | 2.9.1–2.9.2 | A training program with records for every role | Seasonal extraction and bottling staff never trained |
| Pest prevention | 11.2.4 | A documented program, a map of devices and trending of sightings | No plan for the bees, wasps and ants that sugar attracts |
| Foreign matter & glass | 11.7.3–11.7.4 | A glass inventory and breakage procedure (glass jars are allowed); sieves and filters monitored | No glass register; strainer screens never checked |
| Water | 11.5 | Potable water for cleaning and processing, with microbiological testing at least once a year | Well water used for cleanup with no test results |
Navy tags are mandatory elements in Edition 9.[18] Edition 10 moves a few numbers (for example, outside-lab accreditation becomes 2.4.4.5) and makes crisis management (2.6.4) mandatory.
Honey Labeling: What U.S. Labels Must Get Right
Honey labels carry more rules than most single-ingredient foods, and SQF auditors check labels against the law where the product is sold. These are the U.S. rules a honey gap analysis should cover.
| Label element | What the rule says |
|---|---|
| Product name | A product that contains only honey must be called “honey.” It needs no ingredient list.[19] |
| Floral source | “Clover honey” or “orange blossom honey” is allowed only when that plant is the chief floral source and you have information to show it.[19] |
| Blends with sweeteners | Can't be called “honey.” Name the blend with the larger ingredient first, for example “Blend of honey and corn syrup.” Honey cut with sugar or syrup and sold as honey is adulterated and misbranded.[19] |
| Flavored honey | Name it for the flavor, for example “raspberry-flavored honey,” with honey and the flavor in the ingredient list.[19] |
| Country of origin (imported honey) | Every country the honey came from must appear on the jar, for example “Product of South Africa and Zambia.” Blending honey from different countries doesn't change its origin, and the rule still applies when bulk imported honey is repacked in the U.S.[22][23] |
| Country of origin (U.S. honey) | Not federally required on 100% U.S. honey, unless the label carries a USDA grade mark. Then “Product of USA” must appear near the mark.[23] |
| Added sugars | Pure honey must show a %Daily Value for added sugars, but not the “Includes Xg Added Sugars” line. A † footnote explaining the sugar in a serving is optional.[20] |
| Small-business exemption | A business with fewer than 100 full-time-equivalent employees that sells fewer than 100,000 units of a product a year can leave the Nutrition Facts panel off that product. It must file a notice with FDA unless it also has fewer than 10 employees, sells fewer than 10,000 units and doesn't import. Any nutrient claim on the label cancels the exemption.[21] |
| “Raw,” “pure” and similar claims | There is no federal definition of “raw” honey and no FDA standard of identity for honey, though some states, such as Utah, define raw honey. Every claim must be truthful and not misleading, so keep the evidence behind it (heating records for a “raw” claim, for example). SQF clause 2.3.2.7 requires labels that are accurate and legal.[24][18] |
| Infant warning | Not required by FDA's warning-statement rules (21 CFR 101.17) or its honey guidance, but some states require it (Mississippi, for example). CDC advises never giving honey to a child younger than 1 year old, so many packers add the statement anyway.[4][25] |
FDA's honey labeling guidance is nonbinding guidance that explains how FDA applies the adulteration and misbranding sections (402 and 403) of the Food, Drug, and Cosmetic Act.
Which SQF Code Covers Honey?
The SQF Code you're audited against depends on what your site actually does. Most honey packers use the Food Manufacturing Code, and Edition 10 changes the category number.[26][18]
| Your operation | Edition 9 FSC | Edition 10 FSC | SQF code | SQFI fee |
|---|---|---|---|---|
| Beekeeping and apiary work | FSC 1 | FSC 1 | Primary Animal Production (Module 5) | $250 |
| Extracting, processing and packing honey, honeycomb, pollen or royal jelly | FSC 11: Honey Processing | FSC 18: Preserved Foods and Food Ingredient Manufacturing | Food Manufacturing (Module 11) | $650 |
| Repacking honey made somewhere else | FSC 11 or FSC 25; your certification body decides | Confirm with your certification body | Food Manufacturing (Module 11) | $650 |
| Warehousing and distributing packed honey | FSC 26 | FSC 26 | Storage and Distribution (Module 12) | $650 |
| Trading honey without handling it | FSC 35: Agents and Brokers (launched 2026) | FSC 35 | Agents and Brokers | $650 |
SQFI registration fees are paid to SQFI every year, separately from audit fees. Two or more codes are capped at $800.[28] The Agents and Brokers code isn't GFSI-benchmarked yet; SQFI expects benchmarking in 2027.
SQF Edition 10 was published in March 2026. Audits against it start no earlier than January 2, 2027, depending on GFSI benchmarking, so audits before then use Edition 9.[27] If your first audit will fall in 2027 or later, build your system to Edition 10: honey moves to FSC 18, crisis management becomes mandatory, the trace system must be tested every year, and you get 40 days instead of 30 to close non-conformities. Our Edition 10 conversion course covers the changes.
Does FDA treat your operation as a farm or a food facility?
| Operation | FDA status |
|---|---|
| Beekeeper extracting and bottling raw honey from their own hives | Farm activity. FDA treats extraction as harvesting and bottling raw honey as packaging a raw agricultural commodity, so no food facility registration is needed.[29] |
| Pasteurizing (heat-treating) honey, even on a farm | Manufacturing/processing, so FDA food facility registration is required (unless all the honey is eaten on the farm or the operation is a retail food establishment).[29] |
| Packer bottling other producers' honey | A food facility: registration plus the CGMPs in 21 CFR Part 117, and a written hazard analysis unless an exemption applies. FDA has said honey may have no hazards that need a preventive control, but that conclusion has to be documented.[30] |
| FSMA 204 traceability rule | Honey isn't on FDA's Food Traceability List. SQF still requires one-up, one-down traceability and a yearly recall test.[31] |
From Gap Analysis to Certificate
A gap analysis is step two of nine. The path from there to a certificate looks like this:
- Confirm your scopeChoose the SQF code and food sector category, then register the site with SQFI.FSC 11 now, FSC 18 under Ed 10
- Run the gap analysisCompare your operation with every clause that applies and rank the gaps by risk.
- Appoint SQF practitionersA primary and a substitute, both employed by the site and HACCP-trained.Clauses 2.1.1.4–2.1.1.5
- Close the gapsWrite the missing programs: specifications, supplier approval, food fraud, food safety plan, glass and pest control.
- Run the systemUse the procedures every day and keep the records that prove it.SQFI recommends 90+ days of records
- Verify and audit yourselfValidate your limits, verify the records, run a full internal audit and hold a management review.Internal audit at least yearly
- Certification auditAn SQFI-licensed certification body audits your documents, records and facility while you're running.
- Close non-conformitiesFix each finding, with a root cause, and send the evidence to your certification body.30 days (40 under Ed 10)
- Stay certifiedRecertify every 12 months; a C rating adds a six-month surveillance audit. Recall, food defense and food fraud reviews repeat yearly.Every 12 months
Two guides help with steps six to eight: validation versus verification explains the difference auditors test for, and how to prepare for an SQF audit shows what a closed finding should look like.[18]
How the certification audit is scored
| Score | Edition 9 rating | Edition 10 rating | What it means |
|---|---|---|---|
| 96–100 | E (Excellent) | Certified | Certificate; recertify in 12 months |
| 86–95 | G (Good) | Certified | Certificate; recertify in 12 months |
| 80–85 | C (Complies) | Certified | Ed 9: certified, plus a surveillance audit at 6 months |
| 70–79 | C (Complies) | Certified with surveillance | Certified, plus a surveillance audit at 6 months |
| 0–69 | F (Fails to comply) | Initial audit: not certified. Recertification or surveillance: Certified with Unannounced Surveillance | Initial audit: no certificate. Edition 10 recertification or surveillance: immediate suspension, the certificate is reissued only after a successful site visit, and an unannounced surveillance audit follows 6 months later |
Edition 9 deducts 1 point per minor and 5 per major non-conformity. A critical non-conformity costs 50 points and automatically fails an initial certification audit. Edition 10 raises deductions on core clauses (2 per minor, 7 per major). Non-conformities must be closed within 30 days (40 days under Edition 10).
How the Gap Analysis Paid Off
The real value of Gretchen's gap analysis was proactive risk management. By reviewing her operation before anything was on the line, she found the weak points that could compromise her honey, then built and carried out corrective action plans to close them.
As those changes took hold, her honey business changed with them. With better processes in place, she could manage her risks, show that her honey was pure and safe, and earn the trust of the buyers she wanted to reach.
Today, looking back, she is grateful for the guidance the gap analysis gave her. With a solid foundation in place, her business keeps growing, delivering pure, delicious honey to people who appreciate the care that goes into every jar.
The lesson for any honey business: a gap found during a practice review costs you a corrective action. The same gap found during the certification audit can cost you the certificate.
Get Ready for Your Gap Analysis
A gap analysis goes faster, and tells you more, when the reviewer can see your real documents. Pull these together before the visit, even if some are incomplete:
- Site plan and process flow diagramFrom receiving to shipping, matching what really happens on the floor.
- Product list and specificationsMoisture, HMF and any floral, origin or “raw” claims for each product.
- Supplier listWith country of origin, approval status and the latest COAs for each supplier.
- Hazard analysis and food safety planEven a rough draft. The gap analysis will show what's missing.
- Label filesCurrent artwork for every SKU, with the evidence behind each claim.
- Lot coding and a trace exercisePick one finished lot and trace it back to its suppliers and forward to customers.
- Pest control recordsContract, trap map and recent service reports, including how you keep bees and ants out.
- Cleaning procedures and recordsWhat gets cleaned, how, how often, and who signs off.
- Glass and brittle plastics registerEvery glass or hard-plastic item near open product, plus a breakage procedure.
- Training recordsWho has HACCP training and who is lined up to be your SQF practitioner.
- Complaint and recall recordsCustomer complaints, how you handled them, and any mock recall results.
- Registration detailsYour FDA food facility registration, if your operation needs one.
Frequently Asked Questions
What is the difference between an SQF gap analysis and an SQF audit?
A gap analysis is an informal review that finds and ranks weaknesses while nothing is at stake. The certification audit is the formal, scored assessment by an SQFI-licensed certification body that decides whether you're certified. The gap analysis is how you get ready for the audit.
Is honey really high risk if bacteria don't grow in it?
Honey's low water activity makes microbial growth unlikely, but that isn't the whole risk picture. Economically motivated adulteration is the main issue, alongside moisture and fermentation, overheating, residues from hive treatments, foreign material, and botulism spores that make honey unsafe for infants under 12 months. A food safety system has to address all of them.
Do small beekeepers and honey packers need SQF certification?
Not by law. But retailers and distributors often require a GFSI-benchmarked certification such as SQF before they'll stock a product, so for grocery or wholesale it is usually the price of entry. Separately, FDA treats a beekeeper who extracts and bottles raw honey from their own hives as a farm, while a packer that bottles other producers' honey is a food facility that must register with FDA.
Which SQF food sector category covers honey?
Under SQF Edition 9, honey extraction, processing and packing is FSC 11, Honey Processing, audited against the Food Manufacturing Code. Edition 10 retires FSC 11 and moves honey into FSC 18, Preserved Foods and Food Ingredient Manufacturing. Beekeeping itself is FSC 1 under the Primary Animal Production Code.
How long does it take to go from gap analysis to certification?
It depends on how many gaps turn up and how fast you close them. SQFI recommends at least 90 days of records before the certification audit, so plan on at least three months of running the finished system. A honey operation starting from scratch should plan for longer. The gap analysis gives you a realistic timeline on day one.
What tests prove honey is authentic?
No single test does. FDA screens imports with a stable carbon isotope test (AOAC 998.12), which catches cane and corn syrups above about 7% but misses rice, beet and wheat syrups. Labs add LC-IRMS, syrup-marker tests and NMR profiling, and pollen analysis points to floral and geographic origin. Experts weigh several results together, which is why SQF expects a risk-based mix of supplier approval, traceability and testing.
What moisture content should honey have?
The Codex honey standard sets a 20% maximum for most honey (23% for heather honey), and USDA Grade A and B honey can't exceed 18.6%. FAO notes that honey below 18% water can be stored with little or no risk of fermentation. Check moisture with a calibrated refractometer at receiving and before packing.
Is raw honey legally defined in the U.S.?
Not at the federal level. FDA has no standard of identity for honey, and neither FDA nor USDA defines raw for labeling, although some states, such as Utah, do. Any raw claim must be truthful and not misleading, so keep records that support it, such as heating temperatures.
Do U.S. honey labels need a warning about infants?
FDA's warning-statement rules and its honey labeling guidance don't require one, but some states, such as Mississippi, do. CDC advises never giving honey to a child younger than 1 year old because of the risk of infant botulism, so many packers add the statement anyway. Check the rules in every state where you sell.
Should a honey business prepare for SQF Edition 9 or Edition 10?
Audits before January 2, 2027 use Edition 9. SQFI published Edition 10 in March 2026, and audits against it start no earlier than January 2, 2027, depending on GFSI benchmarking. If your first audit will be in 2027 or later, build to Edition 10: honey moves to FSC 18, crisis management becomes mandatory, and non-conformities get 40 days to close instead of 30.
Can my certification body do my gap analysis?
No. To protect impartiality, the certification body that audits you can't consult on how to pass or help you fix gaps. Your own team can run the gap analysis using the SQF Code and SQFI's audit checklist for your code.
Ready for SQF certification?
ASI Food Safety, LLC is an SQFI-licensed, ANAB-accredited SQF certification body. Tell us about your honey operation and the certificate your buyers ask for.
Training is offered through ASI Training and Consulting, LLC, separately from our accredited certification body, ASI Food Safety, LLC, to safeguard against conflicts of interest. Using it has no effect on a certification decision. Questions? Email US.Info@kiwa-asi.com or call 1 (800) 477-0778.
Keep reading
- BlogTop 10 Food Fraud Products and What SQF RequiresWhere honey ranks among the most faked foods, and the controls that catch it.
- BlogHow to Prepare for an SQF AuditScoring, common non-conformities and what a closed finding looks like.
- BlogRoot Cause Analysis in SQF AuditsMethods, examples and a 5-step process for SQF non-conformances.
- BlogValidation vs. VerificationThe difference auditors test for, with a worked CCP example.
- PageSQF CertificationCodes, levels, scoring, Edition 10 timing and how to get started.
- TrainingFood Fraud TrainingBuild the vulnerability assessment and mitigation plan SQF asks for.
Sources
- U.S. FDA (2022). FY21/22 Sample Collection and Analysis of Imported Honey for Economically Motivated Adulteration. fda.gov
- European Commission (2023). EU coordinated action “From the Hives” (2021–2022). food.ec.europa.eu
- Codex Alimentarius. Standard for Honey, CXS 12-1981 (Rev. 2001). fao.org
- U.S. Centers for Disease Control and Prevention. Preventing botulism. cdc.gov
- U.S. FDA (2026). FY25 Sample Collection and Analysis of Domestically Produced and Imported Honey for Economically Motivated Adulteration. fda.gov
- Defra and FSA (2025). Review of methods applied in the “From the Hives” survey on honey authenticity. gov.uk
- Max Rubner-Institut, National Reference Centre for Authentic Food. Geographical origin of honey from Eastern Europe. mri.bund.de
- U.S. Department of Justice (2013). Two companies and five individuals charged for roles in illegal honey imports. justice.gov
- U.S. Department of Commerce (2022). Antidumping duty orders on raw honey from Argentina, Brazil, India and Vietnam, 87 FR 35501. govinfo.gov
- Krell, R. (1996). Value-added products from beekeeping, FAO Agricultural Services Bulletin 124, ch. 2. fao.org
- USDA AMS. United States Standards for Grades of Extracted Honey (1985). ams.usda.gov
- Walker, M. J., et al. (2022). Current trends in honey authenticity testing. npj Science of Food 6:11. pmc.ncbi.nlm.nih.gov
- European Commission Joint Research Centre (2023). EU coordinated action to deter fraudulent practices in the honey sector, EUR 31461 EN. publications.jrc.ec.europa.eu
- U.S. FDA. Using medically important antimicrobials in bees: questions and answers. fda.gov
- 21 CFR Part 556, tolerances for residues of new animal drugs in food (556.360, 556.500, 556.746). ecfr.gov
- U.S. FDA. Import Alert 36-04: honey and blended syrup with unsafe drug residues. accessdata.fda.gov
- Directive (EU) 2024/1438 amending the Honey Directive 2001/110/EC. eur-lex.europa.eu
- SQFI. SQF Food Safety Code: Food Manufacturing, Edition 9 (clauses 2.1.1.4–2.9, Module 11; Part A scoring and Step 5). sqfi.com
- U.S. FDA (2018). Proper Labeling of Honey and Honey Products: Guidance for Industry. fda.gov
- U.S. FDA (2019). The Declaration of Added Sugars on Honey, Maple Syrup, Other Single-Ingredient Sugars and Syrups, and Certain Cranberry Products. fda.gov
- 21 CFR 101.9(j)(18), low-volume nutrition labeling exemption. ecfr.gov
- U.S. Customs and Border Protection, ruling N333594 (2023), blended honey from more than one country. rulings.cbp.gov
- USDA AMS (2018). Country of Origin Labeling of Packed Honey, 83 FR 31441. federalregister.gov
- Congressional Research Service (2022). Honey: Standards of identity and labeling, IF12185. everycrsreport.com
- Mississippi State University Extension. Honey inspection and label requirements for retail markets in Mississippi. extension.msstate.edu
- SQFI. SQF Food Sector Categories (Edition 10, March 2026). sqfi.com
- SQFI. Edition 10 FAQ: audits to Edition 10 begin no earlier than January 2, 2027. sqfi.com
- SQFI. Register for SQF Certification (registration rates in effect April 1, 2024). sqfi.com
- U.S. FDA (2018). Questions and Answers Regarding Food Facility Registration, 7th ed., Q B.1.19 and C.4.3. fda.gov
- U.S. FDA (2015). Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food, final rule, 80 FR 55908 (honey discussed at 55991). govinfo.gov
- U.S. FDA. Food Traceability List and FSMA 204 compliance date. fda.gov