The fourth meeting of the Honey Platform took place on May 5, 2026. EBA was represented by Dr Nik Lupše, Head of the EBA Scientific Committees, and Prof Dr Andreas Thrasyvoulou, member of the Scientific Committee on the Safety and Quality of Bee Products.
As usual, the Honey Platform sent participants specific questions a few days before the meeting and invited speakers to address the topic under discussion. This meeting focused on the important issue of honey traceability. As is well known, the current honey traceability system has significant weaknesses and is considered one of the main factors contributing to the serious problem of honey fraud.
In addition, the Honey Platform once again raised the issue of the quality criteria used to determine honey overheating, with particular emphasis on the acceptance of the enzyme diastase as an additional criterion.
Below are the answers provided by EBA to the questions.
Q1. In practice, how is honey currently traced along the supply chain from the harvesting producer, or importer, to the final consumer, and what information is recorded at each stage of the chain?
• Beekeepers’ Registry: A mandatory registry linking each producer to their number of colonies, hive locations, and estimated production capacity. This registry verifies the identity of the producer, the geographic origin of the honey, and the scale of the operation.
• Mass Balance System: A critical control mechanism ensuring the quantity of honey marketed aligns with the registered production capacity. The intersection of the Beekeepers’ Registry and the Mass Balance system is vital for combating food fraud, as it confirms that the volume sold is consistent with what the hives are physically capable of producing.
• Mass Balance Verification: Used to determine if exporting countries have the actual capacity to produce the volumes they claim to export.
• TRACES NT. A digital customs notification platform. It provides EU authorities with data on the shipper, the origin, and the official certification. While TRACES NT is an essential entry control and traceability tool, it records data provided by the exporting country without inherently verifying its authenticity.
• CHED: A mandatory document for all honey consignments at EU borders. It confirms that the honey originates from approved establishments, complies with EU residue limits and microbiological criteria, and is fit for human consumption.
• Residue Monitoring Plan: Each honey batch must be supported by laboratory analysis reports from an exporting country that maintains an EU-approved Residue Monitoring Plan.
• Approved Establishments: Under current EU rules, the “Competent Authority” of the exporting country is responsible for maintaining the list of approved facilities. Authorities must verify that the facility ID on the drum matches the TRACES database.
• Percentage Origin Declaration (Directive 2024/1438): Commercial documentation (such as invoices and batch sheets) must now list every country of origin and its exact percentage within a blend.
• Bill of Lading: This is required to prove that honey in transit through non-approved countries maintained its “sealed” status and was not compromised.
• HACCP Certificate: While not always mandatory at the border, most EU buyers are legally required to verify the processing facility’s HACCP plan as part of their “Due Diligence” obligations.
Q2. What are the main practical or technical challenges in implementing a Unionwide traceability system that would reliably identify the harvesting origin of honey?
Challenges in implementing & Recommendations for Policy & Enforcement
• The Commission should transition from advisory platforms to the immediate establishment of a EURL under Article 92 & 94 of Regulation 2017/625. An EURL is the only body capable of providing a “Binding Reference Method” and an enforceable traceability system.
• The EU should develop a publicly owned Nuclear Magnetic Resonance (NMR) database. This ensures that the “binding method” for testing authenticity is not dependent on proprietary software from private companies, which currently acts as a significant barrier.
• To prevent consumers from unknowingly purchasing “expensive sugar,” the EU should centralize a database of authentic honey fingerprints and implement a blockchain-style digital passport for every drum. This would prevent “honey laundering” in Free Trade Zones (FTZs).
• To combat “lost traceability,” a harmonized system should assign unique identification codes at the first point of entry. This digital trail must follow the mass balance even if the honey is blended multiple times.
• A TRACES entry should be considered legally incomplete without a physical or digital (PDF) copy of the signed certificate.
• To detail the percentage breakdown needed by Honey Directive (EU) 2024/1438, traders must have commercial documentation (invoices/batch sheets) that explicitly lists every country of origin and its exact percentage in the blend
• BCPs or national authorities should demand the full chain of invoices and health certificates leading back to the original harvest, effectively bypassing fraudulent documentation generated in Free Trade Zones.
Detailed Analysis of traceability vulnerabilities
• In Free Trade Zones, blending and filtering are used as a “substantial transformation” which permits the changes of TRACES/CHED. The country of origin is reset.
• Advanced methods like NMR can find adulterated honey, but without an EURL, they cannot prove it to a judge.
• The traceability system cannot be applied to a non-compliant product that is considered suspect due to the lack of enforceability of the method.
• Systems like TRACES NT and CHED track movement but not authenticity; they act as “administrative mailboxes” rather than lie detectors.
• Once cleared, large “lots” are split, relabeled, and distributed, causing the traceability flag to disappear.
• The new requirement to list exact percentages on labels is essentially impossible to police without a binding reference method from an EURL.
Q3. What additional costs would such an enhanced traceability system entail?
Funding and Infrastructure of the EURL
The EURL is the cornerstone of a functional traceability system. It may function as a single laboratory, a consortium, or be hosted by the Joint Research Centre (JRC). These would ideally be national institutes that already possess the infrastructure and staff required by Article 93 of Regulation 2017/625.
Financial Framework:
• Once designated, the EURL receives a grant from the EU budget to cover mandated tasks, governed by Regulation (EU) 2021/690.
• Under Article 79 of Regulation 2017/625, Member States may collect fees from operators to cover official controls, indirectly supporting the national laboratory networks linked to the EURLs.
• In many instances, the host laboratory or Member State covers overhead and infrastructure, while EU grants fund “EU-added value” activities.
• The Commission issues annual “Financing Decisions” to allocate specific budgets to each EURL based on their approved work plans.
Composition criteria to ensure that honey has not been heated or treated in such a way that the natural enzymes have been either destroyed or significantly deactivated, taking into account the invertase index
At the 2nd meeting of the Honey Platform, the European Beekeeping Association (EBA) stated that the current use of HMF content and diastase activity as indicators for detecting honey overheating must be revised and supplemented with additional provisions.
To ensure that honey quality standards reflect scientific evidence and modern fraud detecting techniques, the EBA recommends:
• amending current HMF and diastase criteria to account for honeys with naturally low enzymatic activity;
• providing an official EU-wide list of monofloral honeys with documented low diastase levels.
• clarifying the legal interpretation of the phrase “after processing and blending” to protect producers from post-processing degradation penalties;
• legislating detection methods for enzyme adulteration and HMF removal;
• considering invertase as an alternative quality parameter only after thorough standardization and validation through a structured pilot phase.
The adoption of invertase as the exclusive criterion for determining overheating in honey should only be accepted under the following conditions:
• Sufficient time should be granted to member states to analyze a large number of monofloral honeys to determine natural variability and identify those with naturally low enzyme activity .
• Honeys that are naturally low in enzymes should be recognized as exceptions to the thresholds, without being linked to other honey parameters.
• Enzyme activity should be measured immediately after processing and blending. Honey packers should not be held responsible for enzymatic changes that occur during storage.
• A method of analysis capable of distinguishing between bee-derived and added industrial invertase should be legislated.
EBA Scientific Committee on the Safety and Quality of Bee Products