Organic labels and beekeeping in Luxembourg

1. Organic beekeeping in Luxembourg
Summary comparison of policies (asofJuly 2014)
(Not exhaustive)
1
EU organic label
COUNCIL DIRECTIVE 2001/110/EC of 20 December 2001 relating to honey
Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91
Commission Regulation (EC) No 889/2008 of 5 September 2008 laying down detailed rules for the implementation of Council Regulation (EC) No 834/2007
on organic production and labelling of organic products in regards to organic production, labelling and control
Note that there are updates since June 2013 that may be relevant though have not been taken into consideration in the comparison table
below:
Commission Implementing Regulation (EU) No 354/2014 of 8 April 2014 amending and correcting Regulation (EC) No 889/2008 laying down
detailed rules for the implementation of Council Regulation (EC) No 834/2007 on organic production and labelling of organic products in regards
to organic production, labelling and control
Commission Implementing Regulation (EU) No 836/2014 of 31 July 2014 amending Regulation (EC) No 889/2008 laying down detailed rules for
the implementation of Council Regulation (EC) No 834/2007 on organic production and labelling of organic products in regards to organic
production, labelling and control
Marque nationale du
miel: quality of honey
label
Marque nationale du miel: quality of honey label
Règlement grand-ducal du 21 juillet 2012 portant création de la Marque nationale du miel.
Lastenheft der Nationalmarke für Honig selon article 4du règlement grand-ducal du 21 juillet 2012 portant création de Ia Marque du miel national

2. 2
Bio-Lëtzebuerg (BL)
Bio-Lëtzebuerg (BL)
Their rules for beekeeping to obtain their organic label are the same as the EU's.
www.bio-letzebuerg.lu
Control:
Users of Bio LËTZEBUERG are controlled by one of the approved inspection bodies and certified by the Label Commission.
Guidelines:
Users of Bio LËTZEBUERG work according to the guidelines of the EU organic regulations and undertake additional to comply with the three
points from the team:
1. Logo BL 2015
A conversion of the entire operation is mandatory.
http://www.bio-letzebuerg.lu/index.php/bio-letzebuerg/kontrolle-richtlinien-bio-label
Richtlinien Bienenhaltung und Imkereierzeugnisse (Guidelines beekeeping and apiculture products)
http://www.bio-letzebuerg.lu/index.php/demeter/kontrolle-richtlinien
A system of bee keeping that respects a colony's natural integrity will not only reduce stress and encourage healthy bees, it will also
be commercially viable.
http://www.biodynamic.org.uk/farming-amp-gardening/bees/
Standards for Beekeeping and Hive Products June 2007:
http://www.biodynamic.org.uk/fileadmin/user_upload/Documents/Demeter_Standards/Demeter_International_Bee_Standards.pd
f
Glossary / Definitions
http://www.beesource.com/resources/elements-of-beekeeping/beekeeping-glossary/
Term Definition / Explanation Reference
Buckfast bee The Buckfast contains heritage from mainly Apis mellifera ligustica (North
Italian), Apis mellifera mellifera (English), Apis mellifera mellifera (French),
Apis mellifera anatolica (Turkish) and Apis mellifera cecropia (Greek). The
Buckfast bee of today also contains heritage from two rare and docile African
stocks Apis mellifera sahariensis and the Apis mellifera monticola, but not
the "Africanized" Apis mellifera scutellata.
https://en.wikipedia.org/wiki/Buckfast_bee
http://www.pedigreeapis.org/elver/ori/origin-
en.html
Grafting Grafting is the most common method of queen rearing and is used
worldwide.
Grafting is simply the transfer of larvae that were intended to be workers
into queen cell cups.
http://www.dave-cushman.net/bee/grafting.html
Midrib The beeswax foundation in a frame. It might also mean the middle of
naturally build comb.

3. 3
From right to left the requirements range from more restrict to less restrict. That is, the Demeter label has more restrictive conditions to be satisfied than EU label.
The organic labels are about how you keep your bees. Generally, the organic labels require you to keep records that allow an inspector to trace the origin and
destination of the equipment and products that you purchase and that you sell. If you sell your honey to a store, you will need to provide a copy of your certificate to
the store owner. The cost of an inspector's visit is approximately EUR 400 per annum for a 3 hour visit.
The Marque National is only about the quality of your honey.
Conversion 889/2008, Article 38
3. Beekeeping products can be sold with references to the
organic production method only when the organic production
rules have been complied with for at least one year.
4. The conversion period for apiaries does not apply in the case
of application of Article 9(5) of this Regulation.
5. During the conversion period the wax shall be replaced with
wax coming from organic beekeeping.
Article 9, 5. For the renovation of apiaries, 10 % per year of the
queen bees and swarms may be replaced by non-organic queen
bees and swarms in the organic production unit provided that
the queen bees and swarms are placed in hives with combs or
comb foundations coming from organic production units.
Standards Section 8. Conversion
A conversion plan is required leading to full certification after, at
most, three years.
"In conversion to Demeter" status may be granted if 12 months
have elapsed since the last application of prohibited substances
and if the old wax used in the combs has been excreted or
replaced by wax of certified organic origin.

4. 4
Placing of bee colonies /
Apiaries
On Luxembourgish
territory
889/2008, Article 13, 1. (...) that, within a radius of 3 km from the
apiary site, nectar and pollen sources consist essentially of
organically produced crops and/or spontaneous vegetation and/or
crops treated with low environmental impact methods.
889/2008, Article 13, 2. The Member States may designate regions
or areas where beekeeping complying with organic production rules
is not practicable.
889/2008, Article 78, 1. A map on an appropriate scale listing the
location of hives shall be provided to the control authority or
control body by the beekeeper.
Where no areas are identified in accordance with Article 13(2),
the beekeeper shall provide the control authority or control
body with appropriate documentation and evidence, including
suitable analyses if necessary, that the areas accessible to his
colonies meet the conditions required in this Regulation.
889/2008, Article 78, 4. The zone where the apiary is situated
shall be registered together with the identification of the hives.
The control body or authority shall be informed of the moving of
apiaries by a deadline agreed on with the control authority or
body.
Standards Section 2. The Siting of Apiaries
Biodynamically and organically managed land or uncultivated and
wild areas should be selected as preferred sites for setting up
beehives. T
Beehive I 889/2008, Article 13, 3. The hives shall be made basically of
natural materials presenting no risk of contamination to the
environment or the apiculture products.
Standards Section 3. Beehives
With the exception of fixings, roof coverings and wire meshing,
hives must be built entirely of natural materials such as wood, straw
or clay.
3.1 Interior Treatment
The inside of the hive may only be treated with beeswax and
propolis obtained from Demeter beekeepers.
3.2 Exterior Treatment
Only natural, ecologically safe and non-synthetic wood
preservatives may be applied to the hive exterior.
3.3 Cleaning and Disinfection
The cleaning and disinfection of hives may only be undertaken
using heat (flame or hot water) or mechanically
Queen replacement
and uniting colonies
Standards Section Methods for increasing Honey Production
Multiple and routine uniting of colonies as well as systematic
queen replacement is not permitted.

5. 5
Queen excluder I I The queen is allowed to move freely throughout the hive.
Systematicuseof queen excludersnot allowed.
Origin of the bees I 889/2008, Article 8, 2. Apis mellifera and their local ecotypes are
to bepreferred.
889/2008, Article 9, 5. 10 % per year of the queen bees and
swarms may be replaced by non-organic queen bees and
swarms.
889/2008, Article 47, (b). lnmajor emergencies(high
mortality) renovation of the apiarieswithnon-organic I
biological bee colonieswhen there are insufficient ecological/
organic bee colonies available
Standards Section 4.3 Breeds
A locally adapted breed of bee suited to the landscape should be
chosen.
Standards Section 4.1.1 Buying-in of Colonies and Queens
Any bees or queens purchased must wherever possible stem
from Demeter beekeepers. If these are not available they may
be sourced from organically certified beekeepers. Colonies of
neither Demeter nor organically certified origin must be
integrated without comb.
Breedingand
Reproduction
I I
[No mention is made as to whether artificial breeding of
queens is permitted or not.]
Standards Section 4.1 Colony Increase and Selective Breeding
Swarming is the natural way to increase the number of bee
colonies and is the only permitted means for increasing
colony numbers. Pre-empting swarming by creating an
artificial swarm with the old queen is allowed.
For the further increase the remainder of the hive can be
divided into artificial swarms.
As with all forms of livestock management some selective
breeding is necessary. The production of queen cells is part of
the swarming instinct.
The replacement of an old queen through the swarming
process is permitted for breeding purposes.
Clipping the wings of
queens
I 889/2008, Article 18, 3 Mutilation such as clipping the wings of
queen bees is prohibited.
Standards Section 4.1.2 Wing Clipping
Clipping the wings of queens is prohibited.

6. 6
Wax and comb I 889/2008, Article 38, 5 During the conversion period the wax
shall be replaced with wax coming from organic beekeeping.
889/2008, Article 18, 4 The bees wax for new foundations shall
come from organic production units.
At least one frame must be built by the bees (i.e. without
foundation wax).
Standards Section 4.4 The Comb
The comb is integral to the beehive. Therefor all combs should
be constructed as natural combs. Natural combs are those
constructed by the bees without the help of waxed midribs.
Natural combs can be constructed on fixed or movable frames.
Strips of beeswax foundation to guide comb building is
permitted.
Combs in the Brood
Chamber
See above Standards Section 4.4.1 Combs in the Brood Chamber
The brood area naturally enough forms a self-contained unity.
Both comb and brood area must be able to grow as the bee
colony develops through building more natural comb. The brood
chamber and frame size must be so chosen that the brood area
can expand organically with the combs and without being
obstructed by wood from the frames. Separation barriers are not
allowed as integral elements of the management system.
Exceptions to this are possible during the conversion period.
Partitioned brood
chamber
Standards guidelines must be followed when the first year of
conversion begins. The following derogations are allowed during
this period:
- Partitioned brood chamber
[Implicitly, after the first year of conversion a partitioned brood
chamber is not permitted. The brood area naturally enough
forms a self-contained unity. Does this mean that a separation
board to make the box smaller, such as 6 frames, in a brood box
for 10 frames is not permitted?]
Combs in the Supers See above Standards Section 4.4.2 Combs in the Supers
Only in the supers may waxen midribs be used. It is nonetheless
desirable to avoid their use here too.

7. 7
Food I 889/2008, Article 19, 3 At the end of the production season
hives shall be left with sufficient reserves of honey and pollen to
survive the winter.
889/2008, Article 19, 3 The feeding of bee colonies shall only be
permitted where the survival of the hives is endangered due to
climatic conditions. Feeding shall be with organic honey, organic
sugar syrups, or organic sugar.
889/2008, Article 19, 3 and Article 47, Catastrophic
circumstances, The competent authority may authorise on a
temporary basis: (d) the feeding of bees with organic honey,
organic sugar or organic sugar syrup in case of long lasting
exceptional weather conditions or catastrophic circumstances,
which hamper the nectar or honeydew production;
At least 5kg of honey for a small colony is needed as winter
food.
Standards Section 4.5 Feeding
4.5.1 Over Wintering
Honey and blossom pollen are the natural foods for bees. The
aim should be to winter them on honey. Where this is not
possible supplementary winter feed must contain at least 5%
honey by weight. This must come from a Demeter certified
source. Camomile tea and salt should also be added to the feed.
All feed supplements must be of organic if not Biodynamic
origin.
4.5.2 Emergency Rations
Where feeding is necessary prior to the first honey flow of the
season, the same procedure as for winter feeding may be carried
out. If emergency feeding is required later in the season and
before the last harvest of the year, only Demeter honey should
be used. The use of sugar is not allowed in such rations.
4.5.3 Stimulative Feeding
No form of stimulative feeding is permitted.
4.5.5 Pollen
All pollen substitutes are forbidden
Food for swarms and
those remaining in the
hive
Standards Section 5.5.4 Feeding of Swarms and Residual Colonies
In order to build up the strength of swarming bees and those remaining
behind, supplementary feeding may be carried out as in the winter..
Bee health Standards Section 6. Bee Health
A bee colony should be able to correct any occurring imbalances out of
its own resources. Measures taken by the Demeter beekeeper should
aim to reinforce and maintain its vitality and capacity for self-
regeneration. The occasional loss of colonies particularly susceptible to
certain pests and diseases should be accepted as a necessary part of
natural selection. Where the implementation of pest and disease
control measures is unavoidable, only those treatments listed in
appendix 2 may be applied. (see below)

8. 8
Varroa treatment I 889/2008, Article 25, 3. The practice of destroying the male
brood is permitted only to isolate the infestation of Varroa
destructor.
889/2008, Article 25, 6 Treatments permitted are: formic acid,
lactic acid, acetic acid, oxalic acid, menthol, thymol and
camphor.
Veterinary medicines against varroa:onlyorganic acids permitted.
Standards Appendix 2 Allowable Treatments and Permitted Substances
Brood removal, warmth treatment, artificial swarming, herb teas,
formic acid, acetic acid, lactic acid, oxalic acid, non-transgenic bacillus
thuringiensis, sodium carbonate for disinfecting of American Foul Brood
organic produced sugar, salt.
Standards Appendix 2 Colonies requiring emergency treatment
must have their harvest removed before hand.
Honey production Honeycombs
containing brood may
not be used for honey
extraction.
Honey must not be
heated.
Honey must be stirred,
which reduces its
tendency to crystalise.
889/2008, Article 13, 7 Honeycombs containing brood, may not
be used for honey extraction
During the extraction, pressing, sieving, purifying and
subsequent bottling of the honey,
Refer to Standards Section 10. Demeter Hive Product
Identification
Standards Appendix 2 Products originating from treated colonies
cannot be marketed using the trade mark during the same
season.
Standards Appendix 3 Transportation, Decanting, Heating.
Transportation Containers
Using containers of artificial materials for honey is only
permitted for the purposes of transportation and special
contracts.
jars (glass or metal)
Honey Processing I I
889/2008, Article 31
Packaging and transport of products to other operators or units
(c) the name and/or the code number of the control body or
authority to which the operator is subject;
Standards Appendix 3 Transportation, Decanting, Heating.
Only an indirect warming of the honey can be considered.
Heating beyond 35 °C is to be
completely avoided.
Standards Section 10. Demeter Hive Product Identification
The following text must be printed on honey labels:
The special quality of Demeter honey derives from a unique,
species appropriate approach to bee keeping. Due to their
extensive flying range, bees cannot be expected to fly solely over
biodynamically managed areas."

9. 9
Requirements for
measurable quality of
the honey
(If the water content is
more than 20%, there is
a high risk that the
honey will ferment.
If the water content is
around 18%, you have
to consume the honey
within 6 to 9 months.)
Water content up to
18% maximum.
HMF content -
measured according
to Winkler - 8 mg/kg
maximum
invertase no.
according to Hadorn
minimum of 10
2001/110/EC, ANNEX II, 2 Water content up to 20% maximum.
2001/110/EC, ANNEX II, 6 (b) HMF content - measured according to
Winkler - 40 mg/kg
maximum
invertase number according to Schade minimum of 8
Standards Section Appendix 1 Measurable Honey Quality
Requirements
Water content - measured according to DIN/AOAC - 18%
maximum and for heather honey 21.4%.
The HMF content - measured according to Winkler - 10 mg/kg
maximum .
The Invertase level - measured according to Hadorn - must be at
least 10 (except honeys with a low content of enzymes like
honey from acacia)
Honey control Systematic sampling.
Physical analysis and
organoleptic testing
889/2008, Article 65, 2, 4 Random sampling possible at any
moment.
Honey analysis on residues upon suspicion ofexcessive exposureto
the environment.
Supervisory body Honey inspector of
honey Commission
ControlbyOrganic Farming Association of Karlsruhe
(D).(Kontrollverein Ökologischer Landbau aus Karlsruhe)
Control by Organic Farming Association of Karlsruhe (D), on behalf of
Demeter Luxembourg.
Control of the
beekeeping hives
Random sampling
possible at any
moment
889/2008, Article 65, 2, 4 Random sampling possible at any
moment.
889/2008, Article 65, 1 Annualinspection visit.
889/2008, Article 67 access to all parts of the unit and all
premises
Random sampling possible at any moment.
Annual inspection visit.
Conversion period I 889/2008, Article 38, 3 Atleast 1year 1-3years
Marketing of bee
products in regards to
policy on Iabels
Glasses of 500 gr or
250 gr with official
labelling or additional
labelling
889/2008, Article 31, 1 Indication of EC control body. Indication of EC control body.
In addition, the guidelines for labelling Demeter products have to be
respected.

10. 10
Bookkeeping Harvest register 889/2008, Article 66, Article 67
Operating description, register of apiaries, evidence of additional
purchases, financial accounting, marketing etc.
889/2008, Article 78, 2. The following information shall be entered
in the register of the apiary with regard to the use of feeding: type
of product, dates, quantities and hives where it is used.
889/2008, Article 78, 3. Whenever veterinary medicinal products
are to be used, the type of product, including the indication of the
active pharmacological substance, together with details of the
diagnosis, the posology, the method of administration, the duration
of the treatment and the legal withdrawal period shall be recorded
clearly and declared to the control body or authority before the
products are marketed as organically produced.
889/2008, Article 78, 5. Particular care shall be taken to ensure
adequate extraction, processing and storage of beekeeping
products. All the measures to comply with this requirement shall be
recorded.
889/2008, Article 78, 6 The removals of the supers and the
honey extraction operations shall be entered in the register of
the apiary.
Operating description, register of apiaries, evidence of additional
purchases, financial accounting, marketing etc.
Standards Section 9. Trading with Bought-in Products