Comments by "SkyRiver" (@SkyRiver1) on "Thoughty2" channel.

  1. Below is from the actual FDA regulations regarding honey. You are totally incorrect in this. And therefore none of your information is truly above suspicion. What enforcement authorities does FDA have for food products that are represented solely as “honey,” but contain other ingredients? FDA’s enforcement authorities for food products that are represented as “honey,” but contain other ingredients, are described below. Case A : A product is labeled as “honey,” but it contains natural raspberry flavoring. The ingredient statement lists only “honey.” According to section 403(i) of the FD&C Act, a food is misbranded unless the label bears : (1) the common or usual name of the food, if there be any; and (2) the common or usual name of each ingredient, if the food is made from two or more ingredients. In this case, the name of the food , “honey ,” does not accurately describe that the food is a raspberry -flavored honey, so “honey” is not an appropriate common or usual name under 21 CFR 102.5(a). Moreover, the ingredient statement lists only one ingredient, “honey,” wh ile the food contains “honey” and “natural flavoring .” Therefore, the product fails to satisfy the requirements under 21 CFR 101.4(a)(1) and section 403(i)(2) of the FD&C Act , and FDA would consider such product to be misbranded. Case B : A product is labeled as “honey,” but it contains honey and another sweetener, such as sugar or corn syrup. The ingredient statement lists only “honey.” Under section 402(b) of the FD&C Act, a food is adulterated if any valuable constituent has been omitted in whole or in part , if any substance has been substituted wholly or in part, or i f any substance has been added so as to reduce the quality of the food or make it appear to be better or of greater value than it is. In this case, the food is represented as honey when another sweetener (e.g., sugar or corn syrup) has been substituted in part for honey. Products that contain only honey and no other ingredients are considered more valuable than a food that contains both honey and sugar or both honey and corn syrup. 3 Therefore, we would consider such product adulterated under section 402(b)(1) of the FD&C Act because a valuable constituent (honey) has been omitted in part ; under section 402(b)(2) of the FD&C Act , because a substance (sugar or corn syrup) has been substituted in part ; and/or under section 402( b)(4) of the FD&C Act , because a substance (sugar or corn syrup) has been added to the honey so as to increase its bulk or weight or make it appear better or of greater value than it is. 3 Honey is more valuable than other sweeteners. See “Sugar and Sweeteners Yearbook Tables,” United States Department of Agriculture Economic R esearch Service. 2017 . Available at: https://www.ers.usda.gov/data - products/sugar -and -sweeteners -yearbook -tables.aspx . 8 Further, we would consider such food misbranded under section 403 of the FD&C Act due to improper labeling of the food: i.e. , the name of the food and the ingredient statement (see Case A and Q&A 5
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