- Subject to exceptions, when we put our honey up for sale, the label on the jar or other container must include a 'Best Before Date' and sometimes a Lot number.
- If a Best Before Date is in this specific form 'day/month/year' e.g. 31st October 2019, then a Lot number is optional because the 'Best before date' acts as a Lot number.
- If a 'Best before date' is expressed as 'Best before end month/ year' e.g. ' Best before end October 2019 or even 'Best before end year' e.g. 'Best before end 2019' then these expressions are no more than indications of the actual dates and a Lot number MUST be provided.
- The producer (i.e. a beekeeper) can always add a Lot number to a label even when optional (see 2 above). Whether the addition of a Lot number is optional or obligatory (see 3 above) the producer is always free to decide whether to Lot number each jar or other container individually or apply one Lot number to a batch of them. The downside of 'one batch one single number' is that if some fault is found in any part of the batch, the whole batch may be recalled by the authorities and/or destroyed.
- Is there anything we beekeepers can do to minimise the risk of a whole batch being recalled or destroyed? Perhaps one should just ask this further question: as honey is such a safe product, as the authorities clearly agree and as we all take so much trouble to produce a first class product is the risk so low that it can be safely ignored? But if you do wish to minimise further the risks, here are two actions you can take:
1) First, obviously, you can separately lot number each of your jars or containers. If this is done 'by hand' the task will take time and if printed on labels, there may be additional printing costs.
2) Secondly, code each jar or container for the purpose of additional identification. For example, you could add the following wording to the label '1OSRFFBF' meaning '1st Oil seed rape from Farmer Brown's Farm'. With this further identification, it should become very easy to identify later any offending jars or containers without risk to the remainder of the crop and to the satisfaction of the authorities concerned. But do keep precise records to back up and confirm any further identification on the jars or containers.
6. Other points
1) What is a batch? The authorities will consider a batch to be the product of a single process. It could be all the honey you have extracted and jarred in a day, it could be, say, four 30 lb buckets of honey filled at various times but melted and mixed at the same time and then jarred. However, if instead, say, the contents of the four buckets had been melted and jarred separately each would be a separate batch.
2) The provision of 'Best before dates' is for the benefit of the consumer, the provision of Lot numbers (or deemed Lot numbers (see 2 above)) for the benefit of the authorities to track down faulty produce. To satisfy these provisions, a beekeeper could be forced into making frequent changes to his or her own labels perhaps at inordinate cost. A solution here might be the following: add the following statement to the label 'For [Best before date] [Lot number] see e.g. lid of jar ' This information could then be affixed to the jar or container by a suitable supplementary label. Note the main label must always state where any information e.g. Best before date is to be found if not on the main label.
3) There is an argument to the effect that if a Best before date is indicated (see 3 above) then a 'Best before month/ year' or a 'Before before Year' will also do away with the need for a Lot number. It is clear that the authorities generally do not accept the argument and as the issue could only be clarified by the Courts it is probably best not pursued especially as it is simple to put a fixed Best before date (e.g. 31st December 2019) on the label.
4) There are specific exemptions from lot numbering. Perhaps the most notable is produce prepared for immediate sale. e.g. a small time beekeeper extracting in the morning for sale later in the day. The argument, however, might be that these 'fresh bread' provisions do not apply to long life products like honey so for the purposes of this article this possible exemption is ignored.