Country Approval and Risk Levels

How did/does True Source Honey determine which countries would be approved and which would not?

Countries were selected for approval based upon certain specific criteria as follows:

Total historical volume traded globally: It is impractical to implement an audited traceability program simultaneously in all countries, True Source elected to focus initial efforts on those countries that trade a significant volume of honey.

Established history of export to both the US and EU: Those countries that have exhibited dramatic and erratic swings in export were excluded from the approved country list. As an agricultural commodity, honey is not subject to dramatic increases and declines in production and export given consistent trading conditions such as price and international trade agreements or regulation. Official import statistics to both the US and EU are used to make this evaluation.

Government/Enforcement Recommendations: Countries that were identified by individuals and organizations within the US Government as suspect or non-producing countries were excluded from the approved countries list. These recommendations were given to the industry at open meetings as presentations by DHS/ICE.

Emphasis on Major Countries of Export: To develop a robust system of certification in any country requires significant investment on the part of True Source as well as from the 3rd party audit service provider. To that end, True Source Certified^® is placing initial emphasis on those countries that account for 80% or more of the legitimate global trade in honey. As the program becomes more mature, countries with developing honey export markets and lower volumes will be considered for general inclusion.

Other Criteria: Additional information gathered by individuals and companies is used to support the exclusion of certain countries based upon several factors. Honey Color – large volumes of White honey traded from countries within 15 degrees North and South of the Equator as it is widely understood that honey produced in these regions are primarily darker in color. When volumes of White honey from these regions are disproportionately large compared to Extra Light Amber and Light Amber honey it suggests sources outside of that region of production. Pollen Analysis – the presence of pollen from countries other than those claimed on import documents suggests that the country of export is not a legitimate exporter, as does the export of honey that does not contain any pollen or only pollen fragments suggestive of ultrafiltration. Media Reports – over the course of the past several years, a number of media reports have described a variety of schemes that involve transshipment and false declaration of imports. Countries identified in these reports have been considered and many have been excluded from the approved list.

How did/does True Source Honey determine the risk level for a given country?

The following factors are considered when evaluating the assignment or change to a risk level:

Established history of domestic production for export and circumvention: The most significant risk factor taken into consideration is those countries that have both a history of legitimate honey export and a history of participation in circumvention. Notable examples include India, Vietnam and Russia – these instances present a unique challenge to traceability and require additional measures to ensure honey traded from these origins is as declared.

Existence and/or maturity of a government traceability System: Some countries have established traceability systems or other programs in place that adequately preclude the possibility of transshipment activity through that country.

Government regulations in general: Some governments have and enforce trade regulations related to transshipment of goods more effectively than others. Those countries with more robust systems of enforcement are considered lower risk when approved.

Geographic Location: Some countries appear to be more favorably located along trade channels in such a manner as to make transshipment a more natural occurrence. These locations may be assigned a higher risk level if approved.

Importer Exemption

Why are importers not required to undergo a certification audit?

Importers are exempted from the audit requirement for two reasons; the first is that the design of True Source places the emphasis on the product – honey. Ultimately, it is the honey that is certified and not the individual companies. The only reason that an individual company would be certified is to demonstrate that they are only handling or processing honey as required by the standard – when those companies are in a position to confuse the origin of the honey by commingling certified and non-certified product. The importer can gain no value within the established system by introducing uncertainty – each load of honey traded under True Source Certified has a unique and randomly assigned number. This number has no value outside of the association with a specific load of honey; therefore the importer cannot add, delete or change the nature of a certified load without risk of detection. Importers that engage in such activity would lose their registered status and be precluded from future trade under the True Source Certified system. The second reason has to do with the magnitude of a traceability audit for importers. As has been demonstrated, importers engaged in questionable activity often conduct business under any number of aliases and company names, shell companies and from locations that do not really exist. The degree of complexity that would be involved in any such audit would require more expense than could be justified. In the end, it was determined that because this point in the supply chain could not be controlled by audit that it must be controlled by other means within the system of certification.

Trademarks

What does the True Source Certified trademark stand for or signify?

As indicated in the text and logo of True Source Certified, the purpose of the program is to CERTIFY through the 3rd party audit that the SOURCE of the honey is TRUE or without deception. While some consumers may naturally read more into that declaration than intended, the trademark itself does not suggest expectations beyond those stated above. With that said, it remains a future goal of True Source Certified to incorporate elements of honey purity and safety but in the beginning, simply requiring participants to clearly declare honey imported into North America will enhance the ability of Customs and Border Patrol to maintain risk based food safety monitoring programs. The decision to use the logo will be made at the discretion of the participant – for example, many food manufacturers are required to obtain food safety certifications, those certifications all carry logos that could be used on products. Few companies choose to display those logos on individual products and rather use the certification to demonstrate adherence to a certain set of standards.

Certification Audits

Why are biannual certification audits required?

Technically only the first audit is a certification audit, all subsequent audits are considered surveillance audits. The surveillance audits are both shorter in duration and unannounced by the audit firm, they do not necessarily take place at 6 month intervals. This audit schedule is designed to mitigate the possibility that a participant might secure a block of uncertified honey and then use that honey between audits in an attempt to avoid detection.