Honey Country-of-Origin Labeling Explained (FDA and CBP Rules)
Where your honey comes from is one of the most useful facts on the jar, and one of the most misunderstood. Several federal agencies have a hand in it. Customs and Border Protection (CBP) governs import marking, USDA governs grade marks, the FDA governs truthful labeling, and the FTC governs “Made in USA” claims. Here’s how the rules fit together, in plain English. This post is part of our Killer Bee Honey guide.
This is a general explainer, not legal advice. Producers and packers should confirm their own labels with counsel or the agencies involved.
Rule 1: Imported honey must be marked with its country of origin
The foundation is the Tariff Act of 1930 (Section 304, 19 U.S.C. 1304), enforced by CBP. As the National Honey Board’s industry guidance summarizes it:
- Every article of foreign origin imported into the U.S. must be marked in a conspicuous place.
- The marking must show the country of origin, in English, to the “ultimate purchaser” in the U.S.
- The ultimate purchaser is the last person in the U.S. who receives the product in the form in which it was imported.
Packing in the U.S. doesn’t change the origin
This is the key point for honey. Bulk imported honey is often packed into retail jars by a U.S. company. Under a 1984 Customs ruling summarized by the NHB, processing and packing honey is not a “substantial transformation.” Honey in a retail jar is still the same product it was in the import drum. So the retail consumer is the ultimate purchaser, and the jar has to name the foreign country or countries of origin.
The NHB guidance gives a simple comparison. Mixing ingredients from several countries into cookies creates a new product. Repackaging, diluting, and similar minor processes usually don’t. Honey packing falls in the second group.
U.S. words on an imported jar trigger extra rules
CBP’s regulation at 19 CFR 134.46, as quoted in the NHB guidance, covers imported products whose labels show “United States,” “American,” “U.S.A.,” or the name of a U.S. city or place, if those words could mislead buyers about origin. In that case, the actual country of origin must appear legibly and permanently, close to those words and in comparable size, preceded by “Made in,” “Product of,” or similar words. A U.S. packer’s address on the back of the label is the classic example.
The NHB guidance also says packers may not use a vague phrase like “a Blend of Domestic and Foreign Honeys” in place of naming the countries.
Rule 2: USDA grade marks require “Product of”
The 2008 Farm Bill added a honey-specific rule. If a container of honey carries a USDA grade mark or statement (such as “U.S. Grade A”) or another official USDA mark, it must also show the country or countries of origin, preceded by “Product of” or similar words, in comparable size and close to the mark. Violations can lead to losing the right to use USDA grade statements.
In a 2018 Federal Register notice, summarized by the NHB, USDA’s Agricultural Marketing Service clarified that this didn’t create a loophole for ungraded honey. Honey without a USDA mark is still covered by the Tariff Act, so imported honey must be marked either way. The NHB’s sample label shows what this looks like in practice, for example “Product of USA, Canada, Argentina” printed near the grade statement.
Best practices from the NHB guidance
- Put the origin statement on the main front label (the principal display panel) or an alternate main panel.
- If a U.S. company is named as distributor, put the origin statement near that name and address, in comparable type.
- Don’t rely on ink-jet printing on a cap or lid. It scuffs off, is often too small, and may not sit near the U.S. wording it needs to clarify.
Rule 3: The FDA requires labels to be truthful
FDA guidance on honey labeling is built on the Federal Food, Drug, and Cosmetic Act. A food is misbranded if its labeling is false or misleading “in any particular.” For honey specifically:
- Pure honey must be labeled “honey.”
- Honey mixed with another sweetener must be labeled as a blend.
- A floral source can be named only if the seller can support that it’s the chief floral source.
An origin claim that isn’t true is a false label claim, whatever the specific marking statute says.
Rule 4: “Made in USA” and “Product of USA” claims must meet the FTC standard
Domestic honey doesn’t have to say it’s American. The FTC notes there’s no law requiring most products to carry a “Made in USA” label. If a seller chooses to make that claim, it has to be true under the FTC’s standard:
- An unqualified U.S.-origin claim means the product is “all or virtually all” made in the U.S., with no more than negligible foreign content.
- Since the FTC’s Made in USA Labeling Rule (16 CFR Part 323, finalized in 2021), unqualified “Made in USA” labels that don’t meet that standard can bring civil penalties. That includes labels shown online.
- Claims can be express (“Product of the U.S.A.”) or implied (flags, maps, or “American” imagery that suggests U.S. origin overall).
- Qualified claims must be specific and truthful. The FTC’s examples include “Made in U.S. from imported parts” and “Designed in USA, Made in Finland.”
For honey, the honey itself is the whole product. A jar of foreign honey packed in Ohio can’t honestly be called “Product of USA.”
What this means for buyers
When you pick up a jar, look for:
- A country of origin, or several. If the honey is imported, it must be there.
- Origin near any U.S. wording, such as the distributor’s address or a grade mark.
- Specific U.S. claims you can trust: “Product of USA” should mean U.S. honey. Better yet, look for a state or region.
- Consistency. If a label is vague, check the seller’s website or ask. A transparent producer will tell you.
For the bigger picture on authenticity, see How to Tell If Honey Is Real. For what “killer bee honey” origin should look like in particular, see What Is Killer Bee Honey?.
The bottom line
“Product of USA” on honey should mean U.S. honey, all or virtually all of it. Imported honey must name its country of origin, even after it’s packed in the U.S., and a U.S. address on the label isn’t an origin claim. When in doubt, a state or region on the label, or a seller who will tell you where the hives were, is the best sign.
Frequently asked questions
Does imported honey have to say where it’s from?
Yes. Under the Tariff Act and CBP rules, imported honey must be marked with its country of origin for the ultimate purchaser. For retail-packed honey, that’s the consumer.
If honey is packed in the U.S., is it “Product of USA”?
Not if the honey was imported. Packing isn’t a substantial transformation, so the foreign origin carries through to the jar.
Does domestic honey have to say “Product of USA”?
No federal law generally requires it. If the seller makes the claim, it must meet the FTC’s “all or virtually all” standard.
What if a jar has a USDA grade mark?
Under the 2008 Farm Bill, it must also say “Product of” the country or countries of origin, near the mark and in comparable size.
Can a blend say “Blend of domestic and foreign honey”?
According to NHB guidance summarizing the CBP rules, that’s not enough. The specific countries must be named.
Related reading
Sources
- National Honey Board, “Guidance to Industry: Country of Origin Labeling of Packed Honey” (summarizes the Tariff Act, the CBP ruling, 19 CFR 134.46, the 2008 Farm Bill, and the 2018 AMS notice): https://honey.com/images/files/NHB-Country-of-Origin-Labeling.pdf
- FTC, “Complying with the Made in USA Standard” (July 2024): https://www.ftc.gov/business-guidance/resources/complying-made-usa-standard
- FDA, “Proper Labeling of Honey and Honey Products: Guidance for Industry”: https://www.fda.gov/files/food/published/PDF—Guidance-for-Industry–Proper-Labeling-of-Honey-and-Honey-Products.pdf
- FDA, guidance landing page: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-proper-labeling-honey-and-honey-products