nutrillius
Label Requirements

Honey label requirements

A jar of pure honey needs four things on the label: the name Honey, the net quantity of contents, your name and place of business, and — unless you're exempt — a Nutrition Facts panel. Pure honey needs no ingredient list, because it isn't fabricated from two or more ingredients, and no allergen statement, because honey isn't one of the nine major allergens. Most small beekeepers are exempt from the panel entirely.

The Nutrillius teamUpdated August 4, 202615 min read
on this page
  1. 1. The four elements every jar carries
  2. 2. Do you actually need a Nutrition Facts panel on honey?
  3. 3. The added sugars quirk, and it is genuinely strange
  4. 4. Serving size: 1 tablespoon, and the number that isn't 15
  5. 5. What you may call it: FDA's honey guidance
  6. 6. Is an infant botulism warning required on honey?
  7. 7. Net weight, not fluid ounces
  8. 8. Honey by state: where the rules actually differ
  9. 9. What a honey panel costs
  10. 10. FAQ

That's the whole federal answer. The complications are in three places: the added sugars line, which behaves like no other product on the shelf; what you're allowed to call your honey; and your state, which almost certainly has its own apiary rules layered on top.

The four elements every jar carries

ElementRuleWhat it means for honey
Statement of identity21 CFR 101.3The word Honey, on the principal display panel, in bold type, generally parallel to the base of the package
Net quantity of contents21 CFR 101.7Weight, not fluid ounces. Bottom 30% of the front panel
Name and place of business21 CFR 101.5Packer, manufacturer or distributor, with street address, city, state and ZIP
Nutrition Facts21 CFR 101.9Required unless you qualify for an exemption. See below

Two things people expect to see here and don't.

No ingredient list. The ingredient statement requirement applies to food "fabricated from two or more ingredients." Pure honey is one ingredient, and the statement of identity does the job. Add anything — cinnamon, chili, lavender, a second sweetener — and you owe a full ingredient statement in descending order of predominance by weight under 21 CFR 101.4.

No allergen statement. The nine major food allergens are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Honey is none of them, and pollen is not an allergen under FALCPA. That changes the moment you infuse: pecan honey names the species, sesame-honey candy carries sesame, and a honey blended with a nut butter carries whatever that butter carries. Our contains statement guide covers the two legal ways to declare.

Do you actually need a Nutrition Facts panel on honey?

Probably not, and this is where most beekeepers stop reading label services. The small business exemption at 21 CFR 101.9(j)(18) covers you if your business has fewer than 100 full-time equivalent employees and sold fewer than 100,000 units in the US in the preceding 12 months. That is essentially every beekeeper in the country.

There's a smaller carve-out inside it. If you are not an importer, have fewer than 10 full-time equivalents, and sell fewer than 10,000 units a year, you don't even have to file the notice. Above that and under the main thresholds, you file annually — and FDA's own materials are blunt that "FDA DOES NOT NOTIFY FIRMS WHEN IT IS TIME TO FILE A NOTICE." Our walkthrough of the small business exemption covers the form and the filing window.

The exemption is void the moment you make a nutrient content claim or a health claim — on the label, in labeling, or in advertising. For honey that is a live risk, because the marketing language is right there. "Raw" and "unfiltered" are not nutrient content claims. "Natural energy," "low glycemic," "antioxidant-rich," "immune support" and "a healthier sweetener than sugar" are claims or health claims, and one of them in an Etsy listing pulls a panel onto your jar. See what counts as a nutrient content claim.

The added sugars quirk, and it is genuinely strange

Here is the single most-asked honey labeling question, and the answer surprises everyone.

Under 21 CFR 101.9(c)(6)(iii), added sugars include "sugars from syrups and honey." So honey is, by definition, added sugars. But section 12516 of the Agriculture Improvement Act of 2018 (the Farm Bill, Pub. L. 115-334) directs that packages of single-ingredient sugars, honey, agave and syrups "do not need to bear the declaration 'Includes Xg Added Sugars.'"

Note where that comes from. It is not in the CFR text. It's statute plus FDA's June 2019 guidance, The Declaration of Added Sugars on Honey, Maple Syrup, Other Single-Ingredient Sugars and Syrups, and Certain Cranberry Products. If someone cites you a CFR paragraph for this rule, they haven't read it.

What FDA asks for instead: declare the percent Daily Value for added sugars, drop the gram amount, and carry a symbol to a footnote. The %DV lands on the Total Sugars line — the one line on a normal panel that never has a percent Daily Value.

Here is FDA's own example panel for a jar of pure honey, in text:

Nutrition Facts
16 servings per container
Serving size                    1 Tbsp (21g)
-----------------------------------------------
Amount per serving
Calories                                     60
-----------------------------------------------
                                % Daily Value*
Total Fat 0g                                 0%
  Saturated Fat 0g                           0%
  Trans Fat 0g
Cholesterol 0mg                              0%
Sodium 0mg                                   0%
Total Carbohydrate 17g                       6%
  Dietary Fiber 0g                           0%
  Total Sugars 17g                         34%†
Protein 0g
-----------------------------------------------
Vitamin D 0mcg                               0%
Calcium 0mg                                  0%
Iron 0mg                                     0%
Potassium 0mg                                0%
-----------------------------------------------
† One serving adds 17g of sugar to your diet and
  represents 34% of the Daily Value for Added Sugars.

* The % Daily Value (DV) tells you how much a nutrient
  in a serving of food contributes to a daily diet.
  2,000 calories a day is used for general nutrition advice.

Three things to copy exactly:

  1. There is no "Includes Xg Added Sugars" line at all. Not zero grams. Absent.
  2. The 34% sits on the Total Sugars line, followed by a dagger. The math is 17 g ÷ the 50 g Daily Value for added sugars = 34%, rounded to the nearest whole percent.
  3. The footnote wording is FDA's recommended text. "One serving adds 17g of sugar to your diet and represents 34% of the Daily Value for Added Sugars."

The reasoning explains the design. Nobody adds sugar to honey, and "Includes 17g Added Sugars" on a single-ingredient jar reads as an accusation that the beekeeper cut it with corn syrup. But the honey still spends the consumer's added sugars budget when it goes into their tea. The format keeps the dietary information and drops the misleading sentence.

The compliance date has passed. FDA exercised enforcement discretion "until July 1, 2021." Any honey panel printed after that should already be in this format.

And the limit: this applies to pure, single-ingredient honey only. Cinnamon honey, hot honey, creamed honey with added sweetener, a honey-and-corn-syrup blend — all of those go back to the ordinary "Includes Xg Added Sugars" format with grams and a %DV. Full detail in our added sugars guide.

Serving size: 1 tablespoon, and the number that isn't 15

Honey's reference amount comes from Table 2 of 21 CFR 101.12, in the row reading "Honey, jams, jellies, fruit butter, molasses, fruit pastes, fruit chutneys." The reference amount is 1 tbsp, and the label statement column shows "1 tbsp (__ g); 1 tbsp (15 mL)." That single row covers honey and fruit spreads together, so the serving-size math here is the same one on our jam and preserves page.

That 15 mL is a volume. Honey is dense — a tablespoon of it weighs about 21 g, which is why FDA's example panel says "1 Tbsp (21g)" and calculates 60 calories and 17 g of carbohydrate off 21 g rather than 15. Weigh a level tablespoon of your own honey and use that number. If you calculate on 15 g you will understate every value on the panel by roughly 30%.

Servings per container, using 21 g and the rounding at 101.9(b)(8)(i):

Jar sizeNet weightServings per container
8 oz227 g11
12 oz340 g16
1 lb454 g22
3 lb1,361 g65

The small-jar trap

Wedding favors, sampler sets and hotel amenity jars land in an awkward band. Under 101.9(b)(12)(i), a product packaged and sold individually containing at least 200% and up to and including 300% of the reference amount needs two columns.

  • 1 oz (28 g) jar = 133% of 21 g. Under 200%, so it's a single-serving container under 101.9(b)(6). One column, whole jar declared as one serving, about 80 calories.
  • 2 oz (57 g) jar = 271%. Inside the band. Dual column mandatory: one column per 21 g serving, one for the whole jar.
  • 4 oz (113 g) jar = 538%. Above the band. One column, 5 servings.

Honey sticks work differently. A 7 g stick is 33% of the reference amount, so under 101.9(b)(2)(i)(A) the serving is the number of whole sticks closest to 21 g — 3 sticks. Our dual column guide works the full band.

What you may call it: FDA's honey guidance

FDA has no standard of identity for honey. What it has is a final guidance issued February 2018, Proper Labeling of Honey and Honey Products. Three rules come out of it.

Pure honey is called "honey." That's the common or usual name, and it's what goes on the front.

A blend cannot be called honey. FDA is direct: a product consisting of honey and a sweetener cannot be labeled with the common or usual name "honey," because that name "does not properly identify the basic nature of the food." The acceptable name is a description like "Blend of honey and corn syrup" or "Blend of corn syrup and honey," ordered by which predominates by weight.

Adding a sweetener without saying so is both adulteration and misbranding. Adulterated because a valuable constituent (honey) has been omitted in part and a substance substituted in part; misbranded because the name and ingredient statement don't identify the actual composition. This is the enforcement path FDA uses on syrup-cut honey, and it is not a paperwork violation.

Floral source naming. "Clover Honey," "Orange Blossom Honey," "Tupelo Honey" are permitted if you or the producer "has information to support the conclusion that the plant or blossom designated on the label is the chief floral source of the honey." No floral declaration is required. But any claim you make about the floral source has to be truthful and not misleading, and "information to support the conclusion" means something you could show — hive placement records, bloom timing, a pollen analysis — not a guess about what was flowering nearby.

"Raw" and "unfiltered" are not defined by FDA regulation. They're not prohibited either. Use them for what they actually describe about your process.

Is an infant botulism warning required on honey?

Not by federal law. There is no FDA regulation requiring a warning statement about infants on a honey label. Anyone telling you FDA mandates it is wrong, and it's worth knowing that before you redesign a label.

What is true: infants under 12 months should not be given honey, because Clostridium botulinum spores in honey can germinate in an infant gut. CDC and the American Academy of Pediatrics advise against it, and in 2018 FDA issued a safety alert about honey-filled pacifiers after infant botulism cases. The industry convention of printing "Do not feed honey to infants under one year of age" grew out of that advice, not out of a rule.

The Minnesota Department of Agriculture puts the position exactly right on its food labeling page: "Although not required by regulation, a warning statement is common on honey indicating 'Do not feed to infants under one year of age.'"

Some states do require it, inside their own exemptions. Virginia is the clearest example. If you sell honey from your own hives under the home food processing exemption at Va. Code § 3.2-5130(C)(5), the label must carry a specific statement that includes the infant warning verbatim — see our Virginia page. So the honest answer is: not federally required, sometimes state-required, and voluntarily printed by most of the industry. Adding it is free and it isn't a claim, so most beekeepers do.

Net weight, not fluid ounces

Honey is viscous, so 21 CFR 101.7(b) puts it in weight: "The statement shall be in terms of fluid measure if the food is liquid, or in terms of weight if the food is solid, semisolid, or viscous." A honey label reading "12 fl oz" is wrong. It reads NET WT 12 OZ (340 g).

Placement is fixed at 101.7(f): the bottom 30% of the principal display panel, in lines generally parallel to the base of the package. Type size scales with panel area under 101.7(i), starting at 1/16 inch for panels of 5 square inches or less.

On metric: FDA's own rule at 101.7(p) treats the metric statement as permitted rather than required. But the Fair Packaging and Labeling Act reaches consumer commodities, and the Uniform Packaging and Labeling Regulation in NIST Handbook 130 — adopted into law in 45 states — requires both inch-pound and metric on consumer packages. Print both. It costs nothing and it removes a state weights-and-measures problem.

Honey by state: where the rules actually differ

This is where honey stops being a federal question. Most states regulate honey under an apiary or beekeeping statute rather than under their cottage food law, and several of the state-specific rules are stricter than anything FDA asks for.

Three examples of how far apart they sit:

  • Texas runs a separate track. A "small honey production operation" labels under Tex. Health & Safety Code § 437.0199, which requires net weight in both avoirdupois and metric, the beekeeper's name and address, and the verbatim statement "Bottled or packaged in a facility not inspected by the Texas Department of State Health Services."
  • Ohio exempts beekeepers under ORC 3717.021 when at least 75% of the honey comes from their own hives. Ohio's cottage food list separately allows flavored honey from an exempt beekeeper.
  • Virginia caps own-hive honey at under 250 gallons a year and mandates a label statement that includes the infant warning.

Here's where the 15 states we cover in depth stand. Caps are cottage food caps; the honey column is where honey sits in that state's system.

StateCottage food capWhere honey sitsPage
ArizonaNoneExclusion model — honey isn't excluded, so it's in scopeArizona
California$75,000 Class A / $150,000 Class B"Honey and sorghum syrup" is a named CDPH categoryCalifornia
Colorado$10,000 per productHoney is named in C.R.S. § 25-4-1614(2)(b)Colorado
Florida$250,000Honey named in FDACS/UF-IFAS guidanceFlorida
GeorgiaNoneHoney and syrup regulated separately, not as cottage foodGeorgia
IllinoisNoneExclusion model — honey is in scopeIllinois
IndianaNoneHoney named on IDOH's allowed listIndiana
Michigan$50,000Not named on MDARD's cottage food list — confirm with MDARDMichigan
North CarolinaNoneGoverned by a 1984 MOU between NCDA&CS divisions, not the home processing listNorth Carolina
OhioNoneBeekeeper exemption under ORC 3717.021 at 75% own hives; flavored honey is cottage foodOhio
PennsylvaniaNonePDA publishes separate honey guidance outside the Limited Food Establishment trackPennsylvania
TennesseeNoneExclusion model under the Food Freedom Act — honey is in scopeTennessee
Texas$150,000In cottage food scope since SB 541, plus the § 437.0199 small honey production routeTexas
VirginiaUnder 250 gallons/yr for honeyOwn-hive exemption at § 3.2-5130(C)(5) with a mandatory infant warningVirginia
Washington$35,000Not named on the WAC 16-149-120 list — confirm with WSDAWashington

Two honest caveats. First, none of these state rules replaces the federal ones — a state exemption from inspection is not an exemption from 21 CFR Part 101. Second, apiary statutes get amended constantly, and a state agriculture department can change published guidance without a bill passing. Call your state agriculture department or apiary inspector before a print run.

What a honey panel costs

You only need this if you've lost the exemption or want the panel anyway. Real 2026 prices:

RoutePriceTurnaround
Full lab analysis$1,609–$1,724 per sample, rush = 2xWeeks
Consultant panel$240Per project
University extension (UGA)$195, +$40 per revision2–4 weeks
Nutrillius$39 one timeAbout a minute

Honey is the worst possible candidate for lab analysis, because you already know what's in it. It's sugar and water. A lab will charge you four figures to confirm a composition that a database lookup gets right. Full breakdown in how much a nutrition label costs, and lab versus software on when a lab is genuinely worth it.

If you do want the panel, the single-ingredient format above is the part that gets built wrong most often. Nutrillius produces it correctly — %DV on the Total Sugars line, dagger, footnote, no grams of added sugars — from your jar size and honey weight. $39 one time, PNG/PDF/SVG, 90 days of edits. Build a honey label.

Frequently asked questions

Does honey need a nutrition facts label?
Usually no. Under 21 CFR 101.9(j)(18) you're exempt with fewer than 100 full-time equivalent employees and fewer than 100,000 units sold in the US in 12 months, which covers nearly every beekeeper. The exemption disappears if you make a nutrient content claim or health claim anywhere, including in advertising. Selling on Amazon is a separate reason you'll need one regardless.
Why does honey show a percent daily value for added sugars but no grams?
Because section 12516 of the 2018 Farm Bill says single-ingredient sugars, honey, agave and syrups don't have to bear the "Includes Xg Added Sugars" declaration. FDA's June 2019 guidance fills the gap: declare the %DV, put a dagger after it on the Total Sugars line, and add a footnote reading "One serving adds Xg of sugar to your diet and represents X% of the Daily Value for Added Sugars." Compliance was expected by July 1, 2021.
What is the serving size for honey on a nutrition label?
One tablespoon, from the "Honey, jams, jellies, fruit butter, molasses, fruit pastes, fruit chutneys" row of Table 2 in 21 CFR 101.12. A tablespoon of honey weighs about 21 g, not 15 g, and every number on your panel should be calculated on the weight you actually measure.
Do I have to put a warning on honey about infants?
Not under federal law. No FDA regulation requires an infant botulism warning on a honey label. CDC and the American Academy of Pediatrics advise against honey for infants under one year, and most producers print "Do not feed honey to infants under one year of age" voluntarily. Some states do require it inside their own exemptions — Virginia's own-hive honey statement is one. Check your state.
Can I call my honey "raw clover honey"?
Yes, with conditions. FDA's 2018 honey guidance permits a floral source name if you have information supporting that the named blossom is the chief floral source. "Raw" isn't defined by FDA regulation and isn't prohibited. Neither term is a nutrient content claim, so neither one voids your small business exemption. "Antioxidant-rich" or "low glycemic" would.
Do I need an ingredient list on pure honey?
No. The ingredient statement requirement applies to food fabricated from two or more ingredients, and pure honey is one ingredient identified by its own name. Add cinnamon, chili, fruit or a second sweetener and you need a full ingredient statement in descending order of predominance by weight — and if you added a sweetener, you can no longer call the product "honey" at all.

Keep reading