3. Legal Standards and Labelling Requirements for GM Material in Bee Products
3.1 GM Food Labelling
Honey has been specifically included in Australian and New Zealand legislation concerning the labelling of GM food (Anon D, 2001), which states that:
- "Honey is not, by definition, a food produced using gene technology under the standard",
- "the standard allows a food or ingredient to have up to 10g/kg (1%) of a GM food where its presence is unintentional. This applies to the presence of pollen from an approved GM food commodity",
- "Outcome: No GM labelling required".
Presumably this 1% rule could apply equally to other bee products such as bee-collected pollen and propolis. As worded, the regulations seem to be stating that honey or other bee products containing up to 1% of pollen containing GM material need not be labelled. This is a more stringent requirement than if honey containing up to 1% of the GM material itself was permitted, since transgene DNA or novel protein will comprise only a fraction of the weight of a "GM" pollen grain (see Section 2.1.1 and Table 1).
A similar situation pertains in the European Union, where small amounts (up to 1%) of GM material that are accidentally present in non-GM ingredients do not have to be labelled (Anon E, 2001). This threshold for accidental inclusion of GM material may change in the future however, since the European Parliament has recently called for a reduction from 1% to 0.5% (Anon F, 2002).1
Saudi Arabia also allows up to 1% unintentional inclusion of GM product (Gray, 2002). Since United Arab Emirates and Yemen are also members of the Gulf Cooperation Council, which sets food standards for these countries, it may be assumed that the Saudi Arabian limit also applies.
Japan's Agriculture Ministry requires labelling of GM foods in which GM material is one of the top three ingredients and where it accounts for 5% or more of the food weight (Takada, 1999).
The South Korean government requires labelling where GM content exceeds 3%, but apparently the United States government is applying pressure for this to be raised to 5% (Anon G, 2002).
China has recently (Anon H, 2002) implemented new regulations for GM crop and food imports, requiring labelling of all foods with GM ingredients and certificates of harmlessness to human and non-human animals, and to the environment. United States soybean imports have been granted temporary safety certificates until December 2002.
In Canada and the United States, there are, as yet, no GM labelling requirements for any food, since their food legislation focuses only upon potential impacts on human health, rather than consumer preferences (Anon I, 2001; Anon J, 2001). This situation may change in the future. In May 2002, new draft legislation concerning GM food labelling (Genetically Engineered Food Right to Know Act 2002) was placed before the US Congress (Anon K, 2002).
Between 1996 and 1998 New Zealand honey was exported to European Union countries, the United States, Korea, Malaysia, Singapore, Japan, Hong Kong, Taiwan, Saudi Arabia, Yemen and the United Arab Emirates (Bourn et al., 1999).
Only honey samples with the very highest pollen counts (5 million grains per 10 g) may exceed a 1% pollen content (see Section 2.2 above). Thus the vast majority of honeys produced by bees foraging even solely on GM crops would be exempt from a legal requirement to label for GM content in New Zealand, Australia or the European Union. All such honeys would be exempt from labelling if destined for Japan, South Korea, the United States or Canada. The situation with regard to Chinese markets is not certain.
3.2 Organic Honey Standards
Organic farming prohibits the use of GM crops and honey containing GM pollen cannot be certified as organic (Bourn et al., 1999; Moyes and Dale, 1999). Presumably honey tests are required for certification unless absolute evidence that the bees cannot have visited GM crops can be produced, but this is not explicitly stated in organic food standards such as the United Kingdom Register of Organic Food Standards, which does not quote a figure for accidental inclusion of material from GM crops (Moyes and Dale, 1999; Anon L, 2000).
The only organic honey production standards to specifically mention GM crops are those of the Organic Crop Improvement Association (OCIA) in Canada which recommend (but apparently do not require) that "apiaries shall not be located near flowering crops which have undergone genetic manipulation" (Anon M, undated).
These and other standards specify proximity of hives to conventional crops, with the aim of minimising contamination with conventional pesticides. It is not certain whether these separation distances would also satisfy organic regulators with respect to GM crops and field trial sites.
The 2001 BIO-GRO New Zealand Organic Standards for honey do not specifically mention GM crops (Anon N, 2001). However, they do require that beehives are located more than 3 km away from land used for intensive conventional horticulture or cropping. Interestingly, these standards appear to have been relaxed since 1998 when a 5 km distance from conventional cropping was required (Bourn et al., 1999).
Organic regulations overseas are similar, with restrictions on the location of hives near conventionally-grown crops or other areas which may be sprayed with non-organic pesticides or polluted in some way (e.g. golf courses, urban areas, dumps etc.). A 3 km limit is used for some producers in the European Union (Anon O, 1999), Canada and the United States (OCIA regulations; Anon M, undated). Other European and US standards (IFOAM, KRAV Sweden, Bioland Germany, Oregon Tilth USA) stipulate only that the hives are not close to areas where conventional pesticides have been used (Bourn et al., 1999). The NASAA Australian standard specifies a 5 km separation distance and the UK Soil Association a 7 km separation distance (Bourn et al., 1999).
It is interesting to compare the recommended separation distances for organic bee hives from conventional crops with information and statements about bee foraging distances (see Section 4.3.1.1 below).
1 New regulations that came into force on 7 November 2003 make the labelling threshold for unintended presence of approved GM material in food and animal feed no higher than 0.9%
Contact for Enquiries
Dr Sharon Adamson
Manager,
Innovation Policy
Ministry of Agriculture and Forestry
PO Box 2526
Wellington
NEW ZEALAND
Phone: +64 4 894 0618
Fax: +64 4 4 894 0741
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