1132 



GLEANINGS IN BEE CULTURE. 



Sept. 1 



THE QUESTION OF HONEY-LABELS AGAIN, 



AND THE POSITION OF THE BOARD OF 



FOOD AND DRUG INSPECTION. 



In our issue for Aug. 1, page 1009, we pub- 

 lished a letter from Secretary Wilson and 

 two government oflScials on the subject of the 

 proper wording to be used on honey-labels 

 when the honey was bottled by some one 

 other than the producer. It will be recalled 

 that we presented some arguments in favor 

 of the phrase "put up by" as against the 

 other phrase, "distributed by," which latter 

 seemed to have the approval of Secictary 

 Wilson and his colleagues. We sent a copy 

 of that editorial to Frederick L. Dunlap, 

 acting chairman of the Board of Food and 

 Drug Inspection, asking whether or not, in 

 view of the further evidence presented, the 

 Board would not sanction the wording " put 

 up by " for all cases where honey was bot- 

 tled by some one other than the producer. 

 We received a letter from Mr. Dunlap, but 

 it came a little too late for insertion in our 

 Aug. 15th issue, and therefore we present it 

 at this time. 



U. S. DEPARTMENT OF AGRICULTURE, 



BOARD OV FOOD AND DRUG INSPECTION. 



Washington, D. C, Aug. 7. 



Mr. E. R. Boot:— I have noted with interest what 

 you say about the labels which have already been 

 printed containing the phrase " put up by," and that 

 this expression has always been understood by the 

 bee-keeping trade, producers, and bottlers generally, 

 as meaning " packed by " in the sense that the honey 

 was bought of some one other than the packer, and 

 prepared for market. While this interpretation of 

 the phrase " put up by " is understood by the trade, 

 bottlers, and producers, in the sense that you sug- 

 gest, yet the Food and Drugs Act requires that the 

 label shall bear no statement that is misleading in 

 any particular. Of course, this means misleading to 

 the purchaser or consumer, so that it reduces itself 

 down to the question whether or not the phrase " put 

 up by " is understood by the consumer to mean the 

 same as you state it is understood to mean by the bee- 

 keepers, bottlers, and producers. This is, it seems to 

 me, the kernel of the whole question. In order to dif- 

 ferentiate between the actual producer and the one 

 who is not the actual producer, but yet desires his 

 name on the package, suggestions have been made 

 that in the latter case the words "prepared for," 

 " manufactured for," " distributed by," etc., be used. 



I do not see on what grounds it would be possible 

 for the bee-keepers who bottle their own honey, sell 

 it under their own label with their own names at- 

 tached, and then later, when their own supply of 

 honey is exhausted, buy from other producers and 

 bottle the product thus obtained, to sell it under the 

 identical label that they used in the first case where 

 they were the actual producers of the honey. In oth- 

 er words, the phrase " put up by " is not sufficiently 

 explicit to be of much significance to the ordinary 

 consumer. It does not differentiate between the actual 

 producer and the one who is not, which differentiation 

 is necessary. 



I do not see that it is possible to get a phrase which 

 would be satisfactory, and cover alike the honey pro- 

 duced by the bottler and that which he buys of some 

 one else. Any such phrase that would be satisfactory 

 to tne bottler would be misleading to the public be- 

 cause it would leave them absolutely in the dark as to 

 whether the bottler were the actual producer or bot- 

 tled the product of the apiary of somebody else. 

 Respectfully, 



F. L. Dunlap. Acting Chairman. 



Mr. Dunlap draws attention to the fact 

 that the national pure- food law, among oth- 

 er things, will not allow a statement on the 

 label that is in any sense misleading to the 

 consumer. It is possible that the latter 

 would be misled by the phrase "put up by;" 



but it is our opinion that he would not; but 

 in this we may be mistaken. 



As a matter of fact, three wordings have 

 been used on honey-labels. When the bot- 

 tler is the proJui"T he uses the phrase " pro- 

 duced by" or "from the apiary of." But 

 when the honey docs not come from his 

 bees he uses the phrase "put up by," pro- 

 viding he is honest; and under the new law 

 it will not be safe for him to be otherwise. 

 Moreover, it has long been customary to use 

 the words " put up by " on labels covering 

 honey both produced by and purchased by 

 the undersigned on the label. The ques- 

 tion, as Mr. Dunlap now says, hinges on 

 whether or not the consumer does under- 

 stand and has understood these distinctions. 

 We are of the opinion he does. 



In relation to the question whether it is 

 practical to use one label on a honey which 

 une may take from his own bees and that 

 which he might buy, it would seem to us 

 that the words "distributed by," if offi-^ially 

 sanctioned by the Board, might be used 

 without defrauding or misleading. If one 

 were a producer, and used the words "dis- 

 tributed by" on his honey, the language 

 would not convey to the consumer the im- 

 pression that he was buying a better article 

 when he was not; for it should always be 

 understood that, when one knows the honey 

 comes from his own bees, he has drect 

 knowledge that the same is not adulterated. 

 Therefore, if he does not claim more than he 

 has a right to, he is not deceiving his cus- 

 tomer into buying an inferior article. Nay, 

 rather, he is giving him a better one. 



It had not previously occurred to us that 

 the words "distributed by," however ob- 

 jectionable, could not be used on the two 

 kinds of honey. If it be necessary for the 

 average bee-keeper to have two sets of la- 

 bels, one to use on honey of his own produc- 

 tion and another on a product that he buys, 

 it would entail an extra expense and no lit- 

 tle inconvenience. To be compelled to use 

 two different labels on a honey that is iden- 

 tical in quality and flavor to any othei; hon- 

 ey would at once convey to the consumer 

 the impression that one lot was not as good 

 as the other, or at least different. All the 

 consumer wants to know is that he is getting 

 a honey that is identical in quality and flavor 

 to that which he had before. He does not 

 care whether it is produced by the bottler or 

 some one else equally competent to produce 

 the same article. 



However much some rulings may incon- 

 venience some honest people, it is a matter 

 of gratification that the authorities are over- 

 strenuous rather than too lax in the inter- 

 pretation of a law that is doing and will do 

 more for the bee-keeping industry than any 

 other piece of legislation that has ever been 

 enacted. A little laxness at the start might 

 practically nullify the law entirely. If we 

 can not get just what we want we will take 

 what we can get and be very thankful. In 

 the mean time we shall not despair of a rul- 

 ing favorable to the phrase "put up by " in 

 the sense indicated. 



