Honey is the exception: Canadian labelling rules that follow the export

The general rule for Canadian food exporters is that the domestic consumer labelling regime is built for a purchaser in Canada and largely stops being the operative one when the product leaves. Honey is the clearest exception on this route, and an exporter working from the general rule will get it wrong.

The requirements for honey apply to imported pure honey, and to honey manufactured, processed, preserved, graded, packaged or labelled in Canada for interprovincial trade **and for export**. That phrase is doing real work. Canada has a view about what an exported jar of Canadian honey says about itself, and the view is written into the regulations, not left to the market.

The grade name is required on exported honey

This is the provision to know first, because it is unusual and it is not optional.

The grade name is required on the label of all honey that is exported, imported or traded interprovincially. Honey must meet the requirements set out in the Canadian grade compendium for the applicable grade, and must be labelled in accordance with the compendium with the applicable grade name.

Volume 6 of the compendium specifies the requirements for honey; Volume 9 specifies import grade requirements.

So an export pack carries a grade, the grade is assessed against a published Canadian standard, and the product has to actually meet the grade it claims. For a company that has sold domestically into channels where the grade was routine, this changes nothing. For one that has sold in bulk or into food manufacturing, where the grade may never have appeared on anything, it is a new requirement discovered at exactly the wrong moment.

There is a route for product that does not meet a grade, and it is worth knowing rather than relying on. Honey not meeting the grade requirements and sent from one province to another does not need to meet the compendium or carry a compendium grade name if it is labelled "Substandard" and its French equivalent.

Separately, non-compliant honey may be sent interprovincially or imported, except as regards standard container sizes, provided a label bearing "For Further Preparation Only" and its French equivalent is applied, attached or accompanying, and the food is brought into compliance by a licence holder within three months, or a longer period the Minister specifies on written request.

Both of those are interprovincial and import provisions, not an export workaround, and reading them as a way to ship ungraded honey abroad would be a mistake.

Origin marking is prescribed, not chosen

The second surprise is that where honey produced in Canada is graded under the regulations, the container shall be marked with the words "Product of Canada" and its French equivalent, or "Canadian Honey" and its French equivalent.

That is a requirement, not a permission. A Canadian exporter who assumed origin marking was a marketing decision has been making a regulatory statement without treating it as one.

The rules for imported and blended honey are equally specific, and they matter to any packer whose supply is not exclusively Canadian.

Prepackaged imported honey must be marked with the name of the country of origin preceded by "Product of" and its French equivalent. So must consumer prepackaged honey packaged from imported honey and graded under the regulations. Where honey is sourced from multiple countries, those countries must be named **in descending order of their proportion** in the "Product of" statement, giving labels of the form "Product of Argentina and Brazil".

The regulations call this the foreign state of origin, which is worth knowing when reading the source text.

The descending-order rule is the operationally awkward one. A blend whose proportions change between production runs may need its country order changed, which makes origin a print-run variable instead of a fixed element of artwork. A packer running blends and printing in volume has a genuine planning problem here, and it is better recognised before the plates are made.

Claims that are defined rather than descriptive

Honey attracts more voluntary claims than most commodities, and two of the common ones have specific treatment.

Raw is defined by what has not happened: honey can be considered raw when it has not undergone treatment or processing such as heat treatment, other than minimal heating for extraction, or filtering. Information clarifying the term, such as "unfiltered", may accompany the claim to avoid being misleading.

That definition is narrower than the way the word is used commercially. A product that has been filtered is not raw under this reading, however gently it was handled, and a company using the word loosely at home is making a claim it may not be able to support when somebody assesses it.

The Industry Labelling Tool also treats Manuka honey specifically, which is a reminder that varietal and provenance claims tend to be regulated somewhere even when they are not regulated here. A claim about a blossom source, a region or a grade of activity is a claim, and the destination may have its own rules about it.

Container sizes are regulated too

One more provision that catches packers planning an export line, because it constrains the format, not the artwork.

Honey has standard container sizes under the regulations: 375 g or less, 500 g, 750 g, 1 kg, 1.5 kg, 2 kg, 3 kg and 5 kg. Net quantity is declared in grams or kilograms, with the numerical quantity in boldface, and the common name "Honey", alone or with the name of the blossom, must appear on the principal display panel at a minimum type height of 1.6 mm in both English and French.

A company designing a pack for an export customer who wants an unusual fill weight is designing against a list, and the sensible order is to check the list before agreeing the specification rather than after.

Notice also what that summary contains: a prescribed minimum type height and a prescribed panel. Those are the elements that make a single pack for two markets difficult, because a destination adding its own language is adding it to a panel where the Canadian elements cannot be shrunk to make room.

The destination still has its own view

None of the above removes the ordinary export position: the destination sets what its own market requires, and a Canadian grade name means nothing to a foreign regulator unless it happens to recognise it.

So an exported jar of Canadian honey can be carrying two sets of requirements at once. The Canadian ones, which follow it because the regulations say they do for exported honey, and the destination's, which govern its sale there.

Where those conflict, the conflict is real and needs resolving, not choosing between. It is also an argument for a dedicated export artwork rather than a single pack, because the Canadian elements that must be present are prescribed in form and cannot simply be dropped to make room.

Honey is also a product where authenticity testing is an active international concern, and a consignment can be questioned on composition, not on paperwork. That is outside labelling, but it bears on the same decision: the claims on the pack should be ones the analysis will support.

Bulk and food service change the question

Most of the rules above are written around consumer prepackaged honey. A great deal of Canadian honey leaves in drums, pails and totes, and exporters in that trade sometimes conclude that labelling is therefore not their problem.

The grade requirement does not distinguish. It applies to honey that is exported, and a drum is exported honey.

What changes is which set of particulars applies and where they go. The regulator maintains separate summaries for consumer prepackaged honey and for honey prepackaged other than as consumer prepackaged, and the second is the one a bulk shipper needs. Standard container sizes, which bind the consumer formats, are not the constraint on a drum; the grade name, the origin marking and the identification that ties the container to production are.

For a bulk shipper the practical risk is also different. A consumer pack is reviewed because somebody is designing it. A drum is marked by whoever fills it, from a template that may predate the export programme, and the marking is the only thing travelling with a container whose contents are indistinguishable from anyone else's.

The order to work in

• Confirm the grade the product actually meets against the compendium, before deciding what the label says
• Treat origin marking as a regulatory element with prescribed wording, not as marketing copy
• For blends, establish whether the country order can change between runs, and plan artwork around that
• Test every voluntary claim, particularly raw, against its definition, not against usage
• Check the destination's requirements separately, and expect both sets to apply to an export pack
• Make sure the analysis supports the claims, because honey attracts scrutiny on composition

The general lesson generalises past honey. Where Canada has a standard for a commodity, that standard tends to reach exported product in a way the consumer labelling regime does not, and an exporter reasoning from "Canadian rules stop at the border" will miss it.

Maple, dairy, fish, meat and processed fruit and vegetable products all have their own commodity-specific requirements, and the honey case is the clearest illustration of why checking the commodity page is worth the ten minutes.