In the United States, "raw honey" has no legally enforced definition. The FDA has never established a standard of identity for honey, the USDA's honey grades are voluntary and say nothing about rawness or purity, and no federal agency verifies the words "raw," "natural," or "unfiltered" before a jar reaches a shelf. This article walks through the full regulatory record: the honey industry's own petition asking the FDA to define honey, the FDA's denial, the guidance the agency issued instead, the state laws that filled part of the gap, and how the definitional vacuum connects to honey adulteration.
By Kara Brown, beekeeper and founder of Chesterhaven Beach Farm on Maryland's Eastern Shore. Every factual claim below is linked to a primary source; see the Sources and Methodology section.
What This Article Covers
- The Short Answer
- The Honey Industry Asked for a Legal Definition. The FDA Said No.
- What the FDA Did Instead: Guidance, Not Law
- USDA Grades Are Voluntary, and Silent on "Raw"
- Where States Stepped In
- What Each Label Term Legally Means
- The Enforcement Gap and Honey Fraud
- What This Means When You Read a Label
- Sources and Methodology
The Short Answer
Honey is regulated in the United States, but not in the way most shoppers assume. As a food, honey falls under the Federal Food, Drug, and Cosmetic Act: section 402 prohibits adulteration and section 403 prohibits misbranding, so a product labeled "honey" that contains added corn syrup is illegal to sell. What the United States does not have is a federal standard of identity for honey, the binding legal recipe that defines what a food must be before it can use a name. Maple syrup has one. Peanut butter has one. Honey does not.
The word "raw" sits one step further outside the law. No federal statute, regulation, or standard defines what "raw" means on a honey label, no agency tests for it, and two producers using the same word can mean entirely different things by it. The rest of this article documents how that came to be.
The Honey Industry Asked for a Legal Definition. The FDA Said No.
The push for a legal definition of honey came from beekeepers themselves. In March 2006, the American Beekeeping Federation, joined by honey producer and packer associations including the American Honey Producers Association and the Sioux Honey Association, filed a citizen petition asking the FDA to adopt a standard of identity for honey based on the Codex Alimentarius international honey standard. The petition was assigned Docket No. FDA-2006-P-0207, the file number that still governs federal honey labeling policy today.
The industry's argument was straightforward: without a binding definition, honey diluted with cheap sweeteners could be sold under the same name as the real thing, undercutting honest producers and misleading consumers. Congress noticed the delay; a fiscal year 2010 House committee report directed the FDA to respond to the petition and to address products illegally marketed as honey.
On October 5, 2011, more than five years after the petition was filed, the FDA denied it. The agency concluded that a standard of identity for honey was unnecessary because its existing enforcement authorities could achieve the petitioners' goals, and that a standard "would not promote honesty and fair dealing in the interest of consumers." The denial letter is filed in the same public docket.
Congress tried once more. Section 10012 of the 2014 farm bill (Public Law 113-79) directed the USDA to examine the case for a federal standard, and the department's Agricultural Marketing Service solicited public comment in August 2014. The USDA's resulting report found broad support for a standard but divergent opinions on its wording, according to the Congressional Research Service. As of this writing, the FDA has still not established a standard of identity for honey.
What the FDA Did Instead: Guidance, Not Law
In place of a standard, the FDA issued a guidance document. A draft appeared in April 2014, and the final version, "Proper Labeling of Honey and Honey Products: Guidance for Industry," was published in February 2018. Two things about this document matter for anyone writing about honey law.
First, it is nonbinding. The guidance itself states that it does not establish legally enforceable responsibilities. It describes the FDA's current thinking and summarizes existing law rather than creating new requirements. The FDA describes honey in plain dictionary terms, as the syrupy food bees make from flower nectar and store in honeycombs, a description of common usage rather than a compositional standard.
Second, its substantive recommendations are about additions, not processing. A food that is nothing but honey must be named "honey" and may declare its floral source, such as orange blossom honey. A food that combines honey with another sweetener cannot be labeled simply "honey"; it must carry a name that reflects what it is, such as a blend of honey and corn syrup, with a full ingredient statement. Selling sweetener blends under the bare name "honey" is misbranding under section 403 of the FD&C Act.
Notice what is absent. The guidance says nothing about heat, nothing about filtration, and nothing about the word "raw." Federal honey labeling policy, in its entirety, addresses whether something was added to the honey. It is silent on what was done to it.
USDA Grades Are Voluntary, and Silent on “Raw”
The "US Grade A" seal on a honey label looks like government verification. It usually is not. The USDA's United States Standards for Grades of Extracted Honey, effective May 23, 1985, and its companion standard for comb honey from 1967, are voluntary grade standards issued under the Agricultural Marketing Act of 1946, as the USDA itself explains.
The grade factors are quality measures: soluble solids, flavor and aroma, absence of defects, and clarity. The standards define "filtered" and "strained" as styles of honey for grading purposes, but they do not test for purity, added sugars, heat treatment, or geographic origin, and honey does not require official inspection to carry a grade mark. A packer can print "Grade A" based on its own assessment. Nothing in the grading system defines, measures, or verifies rawness.
Where States Stepped In
Because there is no federal standard of identity, there is no federal preemption, and a number of states wrote their own honey laws. The most developed example is Florida. In 2009, the Florida Department of Agriculture and Consumer Services adopted Rule 5K-4.027, a full standard of identity for honey. The rule defines honey as the natural food product resulting from the harvest of nectar by honeybees, prohibits any additives, forbids removing pollen except where unavoidable, caps moisture content, sets minimum combined fructose and glucose content, and bans chemical treatments that influence crystallization. A companion rule, 5K-4.028, defines when honey sold in Florida is adulterated or misbranded and gives the state a basis for enforcement that federal law does not provide.
Utah's administrative code takes a different angle, providing that honey may not be heated or processed to the point that its essential character is changed or its quality impaired (Utah Administrative Code R70-520), which is the closest any US jurisdiction comes to regulating the territory that "raw" gestures at. Other states, including Wisconsin, have adopted or proposed their own standards or definitions, and no two are identical. The result is a patchwork: what "honey" legally means depends partly on the state where it is sold, and even the strictest state standards define honey itself rather than the word "raw."
What Each Label Term Legally Means
“Honey”
The one word with real federal teeth. Under the FD&C Act and the FDA's 2018 guidance, a product labeled only "honey" must contain nothing but honey. Added sweeteners make the label misbranding, and the FDA maintains an import alert, Import Alert 36-01, under which imported honey suspected of containing added sweeteners can be detained.
“Pure honey”
Addressed by the 2018 guidance: "pure" is appropriate only when nothing has been added. It carries no meaning about processing. Honey that has been pasteurized at high heat and filtered until the pollen is gone can still be legally labeled "pure honey," so long as nothing was mixed in.
“Raw”
No federal definition, no verification, no enforcement. By industry convention the word usually signals honey that was not pasteurized and not ultra-filtered, but that convention is not law, and producers apply it to everything from lightly strained honey to honey bottled with wax and debris still in it. The claim is only as reliable as the producer making it.
“Natural”
The FDA has never formally defined "natural" for any food, honey included. The agency's longstanding informal policy reads it to mean that nothing artificial or synthetic has been added that would not normally be expected in the food, and the FDA notes the policy was not intended to address processing methods such as pasteurization. On a honey label, "natural" tells you essentially nothing that "pure" does not.
“Unfiltered”
No legal definition. The USDA grade standards define "filtered" and "strained" as styles for voluntary grading, but no rule governs when a producer may call honey "unfiltered," and the term is not verified by any agency.
“US Grade A”
A voluntary quality designation measuring moisture, flavor, defects, and clarity. It does not verify purity, origin, or rawness, and official inspection is not required for the mark to appear on a label.
The Enforcement Gap and Honey Fraud
The practical consequence of a guidance-based system is that enforcement happens case by case, mostly at the border, and mostly after the fact. Detecting adulteration is genuinely hard: older isotope tests catch cane and corn syrups but can miss syrups made from rice, wheat, or sugar beet, whose sugar signatures resemble honey's.
The best recent measurement of the problem comes from the European Union. In a coordinated action published in March 2023, EU authorities randomly sampled 320 honey consignments imported from 20 countries and sent them to the European Commission's Joint Research Centre for analysis. The JRC flagged 147 samples, 46 percent, as suspicious of adulteration with sugar syrups. An earlier EU control plan in 2015 through 2017 had flagged 14 percent, though the JRC notes it applied more sensitive methods in the newer exercise, which may explain part of the increase, and the findings represent suspicion rather than confirmed fraud. The economics explain the incentive: the JRC reported an average EU import value near 2.32 euros per kilogram for honey in 2021, while rice syrup sold for roughly a fifth of that.
No equivalent randomized federal survey exists for the US market, which is itself part of the story. With no standard of identity, no mandatory testing regime, and a voluntary grading system, the burden of verifying what is in a jar falls on state regulators, private certifiers, importers, and ultimately buyers.
What This Means When You Read a Label
None of this means honey labels are meaningless. It means the words on them are promises made by producers, not claims verified by the government, and some words carry more weight than others. "Honey" and "pure" are enforceable against added ingredients. "Raw," "natural," and "unfiltered" are unregulated descriptors whose value depends entirely on the producer behind them.
For practical label-reading guidance, including what the degrees of "raw" look like in real jars and why cloudiness is not a purity badge, see our shopper's guide to raw honey versus regular honey. For how floral source shapes what ends up in the jar, our guide to types of honey covers more than forty varietals, and our honey glossary defines the full vocabulary.
Sources and Methodology
All dates, docket numbers, and outcomes in this article were checked against the primary documents below in July 2026. Adulteration figures are cited only from the European Commission's own publications. Where a secondary source is listed, it was used for context, not for any factual claim.
- FDA, Guidance for Industry: Proper Labeling of Honey and Honey Products, February 2018 (PDF)
- Federal Register, Notice of Availability, Proper Labeling of Honey and Honey Products, March 2, 2018
- Docket FDA-2006-P-0207, regulations.gov, containing the 2006 citizen petition and the FDA's October 5, 2011 denial letter
- Federal Register, United States Standard of Identity for Honey, USDA Agricultural Marketing Service, August 20, 2014
- Congressional Research Service, Ongoing Efforts to Address Fraud and Adulteration of Honey (IF12185)
- USDA Agricultural Marketing Service, United States Standards for Grades of Extracted Honey, effective May 23, 1985
- Florida Administrative Code, Rule 5K-4.027, Standard of Identity, Honey (see also the Cornell LII reproduction)
- Utah Administrative Code R70-520, Standard of Identity and Labeling Requirements for Honey
- FDA, Use of the Term Natural on Food Labeling
- FDA Import Alert 36-01, detention without physical examination of honey and blended syrups suspected of containing added sweeteners
- European Commission, Joint Research Centre, Food fraud: How genuine is your honey?, March 23, 2023, reporting the "From the Hives" coordinated action
FAQs About Is Raw Honey Regulated? What US Law Actually Says About Honey Labels
Is raw honey regulated by the FDA?
Honey is regulated as a food under the Federal Food, Drug, and Cosmetic Act, which prohibits adulteration and misbranding, but the FDA has never defined the term raw honey. No federal rule specifies what raw means on a label, and no agency verifies the claim before honey is sold.
Is there a legal definition of honey in the United States?
There is no federal standard of identity for honey. The honey industry petitioned the FDA to adopt one in 2006, the FDA denied the petition in 2011, and the agency issued nonbinding labeling guidance in 2018 instead. Some states, most notably Florida, have adopted their own legal definitions of honey.
What does pure honey mean legally?
Under the FDA's 2018 labeling guidance, pure is appropriate only for honey with nothing added to it, such as sugar or corn syrup. The term says nothing about processing, so honey that has been pasteurized and ultra-filtered can still legally be labeled pure honey.
Does the USDA regulate or certify raw honey?
No. USDA honey grades are voluntary quality standards dating to 1985 that measure factors like moisture, flavor, defects, and clarity. They do not test for purity, added sugars, or heat treatment, official inspection is not required for a grade mark to appear on a label, and nothing in the grading system defines or verifies rawness.
Which states have their own honey standards?
Florida adopted a full standard of identity for honey in 2009 under Rule 5K-4.027, which bans additives and sets compositional limits. Utah's administrative code restricts heating or processing that changes honey's essential character, and other states, including Wisconsin, have adopted or proposed their own definitions. Because there is no federal standard, states are free to set their own, and no two are identical.
Why does honey adulteration persist?
Sugar syrups made from rice, wheat, or beet cost a fraction of what honey costs and are difficult to detect with older tests. In a 2023 European Commission coordinated action, the Joint Research Centre flagged 46 percent of 320 sampled imported honey consignments as suspicious of adulteration. In the US, the absence of a standard of identity and mandatory testing leaves enforcement to case-by-case action.
