Re-use of honey jars

SBKA Chairman Stewart Gould provides a timely update about pre-used honey jars and lids:
As there is much confusion regarding the re-use of honey jars and lids, I contacted the Food Standards Agency for their thinking on the topic. Previously they had told me that jars should not be re-used, but several years later, they seem to have relaxed that view. Please read their response carefully, as it isn't plain sailing.
Dear Stewart
Thank you for your enquiry, I hope the following proves of assistance to your members.
Food Business Operators (FBO) are responsible for ensuring the food they place on the market is safe under retained European Regulation (EC) 178/2002 - Article 14, and thus the duty and onus is on the FBO to ensure that the food they place on the market is fit for human consumption. Decisions on whether to re-use returned jars and how potential risks should be managed is a decision of the business owner.
https://www.legislation.gov.uk/eur/2002/178/article/14
Re-using glass containers like jam jars occasionally to supply food does not present a food safety concern. This means it is safe to sell home produced honey in re-used jars at village fetes and other occasional events. The key thing is good hygiene – if the jars are re-used they should be free from chips and cracks, and should be clean and sterilised prior to each use. The regulations on food contact materials apply to businesses and these regulations are unlikely to apply to the use of jars for occasional community and charity food provision.
For the lids, it is advisable not to re-use these as they have a gasket within that is designed for single use. In this instance, appropriate lids will therefore need to be procured as films are unlikely to be suitable for honey.
It would be the decision of the local enforcement authority as to whether any particular reuse constituted an infringement of the legislation, as they are tasked to examine compliance paperwork for food contact materials and the circumstances of the placing of the packaged food onto the market.
The legislation on the safety of the packaging your membership will need to comply with is can be viewed at: https://www.food.gov.uk/.../food-contact-materials...
For any food contact material or article placed onto the market in England, the relevant regulations will be the Materials and Articles in Contact with Food (England) Regulations 2012 (as amended*)
https://www.legislation.gov.uk/uksi/2012/2619/contents/made
*The original Regulations for England have been amended as per the following individual amending Regulations and will also need to be referred to:
The Materials and Articles in Contact with Food (Amendment) (EU Exit) Regulations 2019
https://www.legislation.gov.uk/uksi/2019/704/made
The Food and Feed Hygiene & Safety (Misc. Amendments etc) (EU Exit) Regulations 2020
https://www.legislation.gov.uk/uksi/2020/1504/contents/made
The Food and Feed Hygiene & Safety (Misc. Amendments) (England) Regulations 2020
https://www.legislation.gov.uk/uksi/2020/1410/body/made
Unfortunately there isn’t a consolidated version that you can refer to at the moment.
I hope this proves of value to you and your membership.
Best Regards
Vince
Mr Vincent Greenwood
Policy Advisor I Food Contact Materials
Food Standards Agency 6th Floor I Clive House I 70 Petty France ILondon ISW1H 9EX [email protected]