Honey adulteration testing: what you must prove

The authenticity rows the standard actually names

Clause 2.8.3 of the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011 carries four authenticity parameters:

• C4 sugar, maximum 7.0 percent by mass, the cane and corn route.
• 2-Acetylfuran-3-Glucopyranoside, listed as Marker for Rice Syrup, required to be Absent, with a minimum required performance level of 1 mg/kg.
• Foreign oligosaccharides, maximum 0.7 percent peak area.
• Three isotope rows: delta 13C Max, the maximum difference between all measured 13C values, 2.1 per mil; delta 13C fructose minus glucose, plus or minus 1.0 per mil; delta 13C protein minus honey, plus or minus 1.0 per mil.

FSSAI’s Manual of Methods of Analysis of Foods, Honey and Other Bee Hive Products numbers the methods. The rice syrup marker is FSSAI 04B.015:2024. C4 sugar, all three isotope rows and foreign oligosaccharides are one method, FSSAI 04B.016:2024, run by EA/LC-IRMS. A laboratory pricing those as four line items is pricing one instrument run. The manual carries sixteen honey methods, 04B.001 to 04B.016.

SMR is mandatory, TMR is not, and FSSAI said so

Two rice syrup markers circulate and brands routinely ask for the wrong one. The standard names 2-AFGP, the specific marker for rice syrup, written SMR. It does not name the trace marker, TMR, and that was a decision rather than an oversight. FSSAI’s press release of 3 December 2020 states that a more sensitive specific marker test had already been made mandatory, that scientific experts therefore felt TMR was not necessary, and that TMR has not been made mandatory as a test method. A report headed TMR has no Indian limit to pass or fail against, so ask for 2-AFGP by method number. The surveillance predates the controversy: FSSAI first issued instructions on checking honey adulteration with golden syrup, invert sugar syrup and rice syrup on 23 December 2019.

NMR is a buyer requirement, not Indian law

NMR profiling is not a parameter in clause 2.8.3, and no NMR procedure appears in that manual. FSSAI’s reasoning is on the record in the same release: NMR is database driven, no database then existed for Indian honey, the cost and skill requirement are high, and so the scientific panel opined that NMR is not required at this juncture. It adds that almost no food regulator had then mandated NMR for honey, and that FSSAI regards the prescribed EA-LC-IRMS method as being as sensitive for fruit origin sugars.

So if an EU or US buyer asks for NMR, that is a contract term and a cost of winning the account, not a compliance obligation. One caveat: we could not verify from an Export Inspection Council or APEDA notification whether NMR is compulsory on Indian honey export consignments today. Reports from November 2019 record the government asking the council to make it mandatory, but we found no circular confirming the position.

What the 2020 report changed, and what it did not

CSE published its honey testing results on 2 December 2020, covering 13 brands sampled between August and November 2020 from Delhi retail and online. An Indian laboratory ran C4 and C3 sugars, foreign oligosaccharides and the specific rice syrup marker against the FSSAI parameters, which CSE describes as operationalised in 2020, while a German laboratory ran TMR and NMR profiling. CSE’s own report records that TMR and NMR are not part of the current FSSAI standards.

So those parameters were already in force before the report, not added because of it. What the report showed was the gap between the Indian panel and the German one, and FSSAI answered the next day by defending the panel rather than extending it. The entry has been amended since, and FSSAI’s notification list records the Fifth Amendment Regulations, 2021 of 15 November 2021 as covering honey, though we could not confirm from the gazette which rows it inserted.

A supplier declaration is not evidence

A supplier declaration describes intent. A test report on the batch you packed describes the batch, and the link from a pack code back to a lot is the subject of batch code traceability.

A certificate of analysis that survives scrutiny carries the batch number as printed on the pack, the quantity it represents, the sampling and test dates, every clause 2.8.3 parameter with result, unit and limit side by side, the FSSAI method number for each, the limit of quantification wherever a result reads absent, the laboratory’s accreditation scope, and an authorised signatory. Section 43 of the Act lets the Food Authority notify laboratories accredited by NABL or another agency, so check the scope covers honey and these methods, not food in general. The trap is the word absent: the standard sets a 1 mg/kg performance level for the rice syrup marker, so not detected without a limit of quantification proves nothing.

Substandard, misbranded and unsafe are three outcomes

• Sub-standard, section 3(1)(zx), is food that does not meet the specified standards but not so as to render it unsafe. Section 51 may extend to Rs 5 lakh. Honey over 20 percent moisture, or over 80 mg/kg HMF, lands here.
• Misbranded, section 3(1)(zf), covers food promoted with false, misleading or deceptive claims on the label or in advertisement, or sold by a name belonging to another food. Section 52 may extend to Rs 3 lakh, and section 52(2) lets the Adjudicating Officer direct corrective action or destruction. Monofloral with no pollen count lands here.
• Unsafe, section 3(1)(zz), is food whose nature, substance or quality is so affected as to render it injurious to health, through twelve listed routes including substitution of an inferior or cheaper substance. Section 59 is criminal: clause (i) now reads imprisonment up to three months and a fine up to Rs 3 lakh, substituted by the Jan Vishwas (Amendment of Provisions) Act, 2023, with tiers rising to six years for grievous injury and a minimum of seven years where death results.

Syrup substitution reads onto the unsafe route, but that definition requires the quality to be so affected as to render the food injurious to health, so a syrup cut honey is more often run as sub-standard or misbranded, or under section 50 for food not of the nature or substance or quality demanded. Penalties go to an Adjudicating Officer not below the rank of Additional District Magistrate under section 68, with appeal to the Food Safety Appellate Tribunal under section 70, while offences punishable with imprisonment exceeding three years go to a Special Court where one exists. Misleading advertisement is its own head under section 53, up to Rs 10 lakh.