When is honey ‘raw’ honey?

April 24, 2023

6 Pump Court

Stuart Jessop has represented the London Borough of Waltham Forest before the First Tier Tribunal (General Regulatory Chamber) in an appeal against the service of an improvement notice under the Food Information Regulations 2014.

The notice was served on an importer and wholesaler of honey. It had labelled, marketed and sold honey as ‘Raw’ and the local authority argued that this was contrary to Article 7(1)(c ) of the relevant EU regulation, the Food Information to Consumers regulation. This Article prohibits the use of a word if it suggests that the product possesses special characteristics when in fact all such products possess them. The Council argued that the characteristics of honey are specified in the Honey Regulations 2015 and that, alternatively, the word ‘raw’ was misleading when applied to honey. The Appellant company argued that the product was different to most others on the market and was of a superior quality, not being tested to more than 40 degrees, and could properly be described as raw.

Judgment was reserved and is expected in a few weeks.