AFI Association of Food Industries

AFI Serving the U.S. Food Import Sector

2020 NHPDA Report

Greg Olsen
Lamex Foods, Inc

The past 12 months have seen the National Honey Packers and Dealers Association continue its long history of identifying and addressing industry issues. 

For example, a team of representatives from NHPDA member firms met several times with officials with Customs & Border Protection to discuss our concerns about the agency’s use of a trace metals test in decisions regarding country-of-origin determinations. This is a huge issue because of existing antidumping and countervailing duties on honey. We said the trace elements test has shortcomings, uses a limited database and is not available for use by the industry. It’s resulted in CBP erroneously determining that entries of honey from India were Chinese honey being transshipped to avoid antidumping duties.

Importers and packers outlined steps many in the industry take to ensure quality and traceability and expressed frustration that the trace elements test can’t even be considered for inclusion in their efforts because CBP doesn’t share the methodology. We also offered to help develop a template of sorts that would outline recommended traceability documents specific to honey. We pushed for risk-based protocol or a decision tree following a testing concern on CBP’s part that would show that if the importer could produce documents A, B and C, it could be reasonably sure the issue would be resolved. 

While our dialogue hasn’t resulted in CBP halting use of the trace metals test, it’s brought the industry’s efforts to the agency’s attention and resulted in significant progress in that agency officials have said they’re willing to consider other factors as well.

CBP officials continue to tout the Customs-Trade Partnership Against Terrorism and Importer Self-Assessment programs as ways importers can demonstrate due diligence. Even after industry reps said they’ve been told by CBP personnel that antidumping/countervailing duty concerns override C-TPAT and ISA participation, CBP reps said participation in those programs would be viewed upon positively by CBP. I recommend members of other sections within AFI keep those comments in mind.

Regarding the database issue, CBP officials have been in contact with government officials in India for information and assistance. We offered guidance and assistance for a CBP trip to visit beekeepers in India in 2019 and another one that was scheduled to take place at about the time this report was being written. 

NHPDA representatives have also met several times, sometimes alone and sometimes as part of an industrywide group, with officials at FDA. 

NHPDA’s meetings with FDA have been focused on creating and maintaining a dialogue with key agency personnel regarding measures such as testing procedures and food safety/quality control efforts within the honey sector.

The industry as a whole is concerned about FDA’s approach to the added sugars requirement on the new Nutrition Facts panel. Though a jar of honey won’t be required to list added sugars, FDA is requiring some wording and awkward spacing that raise concerns. Per FDA’s request, the industry conducted consumer research that proves our point – the proposed labeling creates a mixture of confusion and mistrust. Consumers feel “added sugars” refer to additional sweeteners, beyond any naturally occurring sugars, that are included in a product’s ingredients. Consumers don’t understand what’s happening with the blank spaces; many believe it was a mistake or manufacturing error. The research also confirms our biggest fear – the suggested labeling creates concerns that lead to a decreased intent in purchasing honey.

NHPDA will continue to work with others in the industry on this important issue. We’re fortunate that although there are several sectors within the honey industry, all of those sectors are represented on an industrywide task force that meets regularly to discuss and address industry issues. The task force represents an excellent example of the value of industry associations. In this case, associations from each sector have equal representation on the task force. If one of the sectors didn’t have an association, that sector’s voice wouldn’t be heard.

I encourage all reading this to become members of the trade association that represents your sector in your home country and in countries to which to you export. The voice, the knowledge and the contacts make trade association membership an incredibly powerful tool for you.

Association of Food Industries: Serving the U.S. Food Import Trade Since 1906
3301 Route 66, Ste. 205, Bldg. C • Neptune, NJ 07753
(732) 922-3008 • Fax: (732) 922-3590 • •