Research Paper

The U.S. Department of Agriculture (USDA) defines honey as “a sweet, syrupy substance produced by honey bees from the nectar of plants or from secretions of living parts of plants or excretions of plant-sucking insects on the living part of plants, which the bees collect, transform by combining with specified substances of their own, deposit, dehydrate, store, and leave in the honeycombs to ripen and mature.” Honey has specific regulations based on where it is produced, but in the United States it is one of the foodstuffs governed both by the Food and Drug Administration (FDA) and the USDA. The FDA restricts products marketing themselves as honey of any kind of floral origin to only those without additives. If a product has added sugar, flavor or chemical substitute, it cannot be called honey exclusively. It must identify the other substances both in the product name and in the ingredient list. The USDA has more stringent requirements, mandating that honey products identify the “type(s), source(s), floral source(s), preparation(s), color(s), grade(s), and agricultural practice(s) of the honey desired,” along with the results of a variety of authenticity tests in the commercial description of the product. If the product does not have a USDA classification as listed (based on a list of twenty-six different possible features that combine to make up the three-hundred-and-twenty recognized varieties of honey) or does not pass the required analysis, it cannot be considered honey. 

Honey adulteration is the process of diluting or replacing natural honey with added water or sugar, or chemical replications made to simulate honey. Honey adulteration occurs through the addition of sugar syrups, such as cane syrup, to honey as a diluent. On occasion, honey adulteration is the combination of cane syrup with artificial honey flavorings being marketed as natural honey. Some honey adulteration occurs in the process of beekeeping, when farmers feed bees sugar water and syrup to de-incentivize the hives from swarming to find a more consistent food source [Swarming: the process of bee hive(s) moving collectively at the behest of the queen or in defiance of a “weak” queen to establish a hive near florals.] In the European Union (EU), legislation governing honey seeks to reduce the amount of sugar in honey to maintain “purity standards.” However, the USDA requires that all honey be free of additives in order to be classified as honey. This is achievable because honey is a natural preservative, and will not spoil or cause illness when stored properly and consumed raw. Any modifications to honey are considered adulteration in the United States and must be disclosed in the label and in the product name.

The United States imports the majority (38.7%) of its honey from India. India is the fourth largest exporter of honey. The FDA tested 144 samples of honey in 2022 from their primary import countries, 28 samples from India, and found that 10% were adulterated. However, independent analysis of honey through the use of advanced Nuclear Magnetic Resonance Profiling (NMR) tests by the Center for Science and the Environment found that 77% of certified honey in India was adulterated. The lack of profitability of the modern honey market is cited as a reason. The largest exporter and producer of honey is China. Although there is limited evidence to support widespread fraud, China is the world’s biggest producer of honey (excess of 250,000 tons per year) and the producer of some of the world’s most affordable honey (export in excess of 100,000 tons per year). The FDA and the EU have both identified China as a potential source of food fraud. The Observatory of Economic Complexity mandates two separate pages for honey’s export/import through China: Verified natural honey and all honey. China is also a primary exporter of modified sweeteners designed for the purpose of honey adulteration. This syrup is resistant to all modern analysis except the most advanced and expensive testing, NMR, and is exported to India at a rate of over 10,000 metric tons annually. 

The United States primarily tests honey as an import product in small batches. The standard embraced by the FDA and the USDA is the C4/C3 sugar test, which does not detect the modified sweeteners exported from China to India at a rate of 10,000 metric tons annually. The C3 test is the only Association of Official Agricultural Chemists approved test, and the one that is most often used by the FDA and USDA in honey testing processes. The C4 test is the modified version of the C3 test that detects all C4 sugar modifications and some C3 sugar modifications. Both tests are susceptible to deception through the use of modified sweeteners designed and manufactured specifically to pass the tests. The only tests that can detect honey adulteration made with the modified sweeteners is the NMR test or the Liquid Chromatography-High Resolution Mass Spectrometry analysis (HRMS), which is not widely embraced due to its expense. Both tests identify specific markers in the honey product, including the botanical origins and the country of origin, by comparing the product to a chemical database of over twenty botanical varieties of pure honey.

Much of the sale of C3/C4 testing resistant syrup occurs through commerce website Alibaba, which is based primarily in China. Alibaba has long been considered a potential security threat because of its ability to store large amounts of consumer data, and because regulation standards for Chinese e-commerce websites are vastly different from U.S. based e-commerce websites, leading to discrepancies in product quality and priorities for food standards. The current administration (2022) launched an investigation into Alibaba that is ongoing and as of yet inconclusive.

Honey and cane syrup, a common diluent in honey adulteration, are chemically very similar. However, they have vastly different effects on the human body. Honey contains antibodies that combat cardiovascular disease. In some animal studies on the differing effect of honey and cane sugar, cane sugar was seen to increase fatty deposits and degenerations in the organs of the subjects, while honey increased positive bacterial growth. Some tests reveal indicators that honey decreased the risk for diabetes while simultaneously increasing organ function. 

Honey is classified, in many places, as medicine. In the United States, it is a homeopathic remedy utilized by medical professionals and homeopathic practitioners for a variety of conditions including heart disease, mental illness, and even wound care. It is also used to treat minor anaphylaxis and create lasting antibodies in individuals with more severe allergies, and is most commonly used as a cough suppressant. It has even been identified as a possible remedy for Covid-19 by the National Institute of Health, along with HIV, influenza virus, herpes simplex, and varicella-zoster virus. Cane syrup, and other artificial additives identified to have been used in food fraud, have not been found to have the same impact. Cane sugars have been assumed safe for human consumption, but their overall impact on the human body is vastly different than that of honey. Currently, heart disease and other sugar-consumption-related illnesses are some of the primary causes of illness and death in the United States. Differentiating between honey and other sweeteners is occasionally a part of treatment for these conditions. 

Sourcing products directly or indirectly from Chinese commerce websites presents a number of issues for U.S. interests. Honey and sugar are both agricultural products, but the artificial sweeteners designed to circumvent traditional honey testing are manufactured products that can be traced to agricultural districts. Bloomberg News found in an investigation of Shein products that the fibers on the fabrics were traceable to the Xinjiang province, a clear indicator that their origins may have been in suspected labor camps currently housing Uyghurs. More significantly, U.S. Customs did not make the connection between the fibers on the products and the origin, primarily due to low staffing and a lack of sensitive testing tools, two issues that also impact the USDA and the FDA. Most natural honey is carefully monitored and cataloged in the province of Zhejiang, but the irrigated agricultural landscape of regions further north, such as Xinjiang, make it perfect for growing and editing sweeteners like sugarcane to be more resistant to purity testing. Chinese officials deny that they have any involvement in the manufacturing of artificial sweeteners designed for honey adulteration, but the large scale of the production contradicts the claim that it is a few independent farmers acting alone in such isolation that the fraud is unenforceable. 

Definitive testing on the origins of adulterated honey can only tell the general region of origin, and not the specific location. However, 2023 testing of select honeys in the European Union indicated that 74% of the suspected adulterated honey originated in China, in an area that was both agricultural and irrigated. China has taken a relaxed policy on the accusations that it is using forced labor to manufacture textiles, and has seen limited internal retaliation or investigation since the revelation. This is likely due to their favored trade policies in both the United States and India, policies which see Chinese exporters paying little-to-no fees or tariffs on trade while simultaneously stimulating the economy and economically enforcing reliance on China’s growing e-commerce market. Chinese product manufacturers have limited incentive to stop unethical and illegal business practices. The United States sources no honey from China directly, but is far from the ability to tell adulterated honey with potentially illegal origins from natural honey when it is imported from third parties like India or the United Kingdom- except in cases of advanced testing, which is done infrequently.