Relating to honey production operations and the harvesting and packaging of honey and honeycomb.
LowStandard timeline
Low Cost
Effective:2025-06-20
Enforcing Agencies
Texas Department of State Health Services (DSHS) • Texas Department of Agriculture
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date:June 20, 2025 (Note: This legislation passed with a 2/3 supermajority, overriding the standard September 1 date).
Compliance Deadline:June 20, 2025 (Retailers must update vendor intake protocols by this date to legally accept non-inspected wholesale honey).
Agency Rulemaking: No immediate rulemaking is mandated, but the Texas Department of State Health Services (DSHS) will likely issue guidance memos to inspectors regarding the cessation of enforcement on pure honey operations.
Immediate Action Plan
1.Retailers: Update vendor onboarding checklists to create a "Statutory Exempt Honey" category by June 1, 2025.
2.Producers: Contact insurance carriers immediately to remove "commercial exclusions" and add wholesale product liability coverage.
3.Legal: Draft a standardized affidavit for vendors to sign, attesting that their product is 100% raw, unblended, and from Texas-located hives under their management.
4.Operations: Segregate inventory. Ensure "infused" honey products are produced in a licensed facility, while pure honey operations are separated to maximize the exemption utility.
Operational Changes Required
Contracts
Supply Agreements: Retailers and wholesalers must amend Supplier Quality Assurance (SQA) agreements. Remove standard clauses requiring "DSHS Food Manufacturer License" for honey vendors.
Indemnification: Replace licensing requirements with strict warranty clauses stating the supplier complies with Texas Health & Safety Code § 437.001(7). Ensure indemnification clauses explicitly cover product liability claims, as the state no longer provides a safety inspection shield.
Leases: If leasing land for apiaries, agreements must explicitly grant the lessee (beekeeper) full management control of the hives to satisfy the "owned and managed" statutory requirement.
Hiring/Training
Procurement Staff: Train buyers that a lack of a DSHS license is no longer a disqualifier for honey vendors. Staff must be trained to verify product purity (raw vs. infused) rather than facility licensing.
Production Staff: If you are a producer, staff must be trained that adding *any* ingredient (flavoring, spices) voids the exemption and immediately triggers full commercial licensing requirements.
Reporting & Record-Keeping
Origin Verification: Producers must maintain records proving 100% of the honey is from hives they own and manage within Texas.
Labeling: Review inventory. The specific "Bottled in a facility not inspected..." warning required by previous law is repealed. Labels must now simply comply with Texas Agriculture Code Chapter 131.
Fees & Costs
Fee Reduction: Producers save the cost of commercial food manufacturing licensing and commercial kitchen rental fees.
Insurance: Producers moving into wholesale must upgrade from general liability to Product Liability insurance, as retailers will require this in the absence of state inspection.
Strategic Ambiguities & Considerations
The "Purity" Trap (Infused Products)
The law exempts honey that is "not blended with any other product." It is unclear if DSHS will attempt to regulate "creamed" or "whipped" honey (which is physically processed but chemically pure).
Risk: Adding jalapeños, vanilla, or corn syrup is manufacturing. If a business sells both pure and infused honey, DSHS may argue the facility requires full licensing, potentially negating the exemption for the pure honey lines as well.
Zoning vs. Production Preemption
The bill prohibits municipalities from regulating the *production* of honey. However, it does not explicitly strip municipalities of *zoning* authority regarding traffic and noise.
Risk: A home-based operation scaling to 50,000 lbs may be shut down by a city for violating residential zoning ordinances (truck traffic), even if the city cannot regulate the honey extraction process itself.
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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.
Under previous law, all honey producers extracting and bottling their own honey were required to be licensed with the Department of State Health Services (DSHS). However, legislation was enacted in 2015 that provided small honey production operations an exemption from DSHS licensing requirements, with certain restrictions. In 2020, DSHS adopted the 2017 guidance under the FDA Food Safety Modernization Act with respect to honey and now considers extracting and bottling honey as harvesting and packaging a raw agricultural commodity, which are "on farm" processes that do not require registration. This created some misalignment between federal standards and state law, with state statutory language regarding small honey production operations being more restrictive than the current position of DSHS. H.B. 519 seeks to align state statute with the FDA Food Safety Modernization Act in order to prevent confusion among beekeepers and local enforcement by revising provisions relating to a small honey production operation.
CRIMINAL JUSTICE IMPACT
It is the committee's opinion that this bill does not expressly create a criminal offense, increase the punishment for an existing criminal offense or category of offenses, or change the eligibility of a person for community supervision, parole, or mandatory supervision.
RULEMAKING AUTHORITY
It is the committee's opinion that this bill does not expressly grant any additional rulemaking authority to a state officer, department, agency, or institution.
ANALYSIS
H.B. 519 amends the Health and Safety Code to expand the scope of statutory provisions that establish labeling requirements for small honey production operations satisfying certain criteria relating to the amount of honey produced, the origin of the product, and the manner of production, sale, and distribution but exempt those operations from regulation as a food service establishment and prohibit their regulation by local governmental authorities. The bill makes those provisions applicable instead to all honey production operations, defined by the bill as beekeepers that sell or distribute honey or honeycomb they produce that is or from which is extracted pure honey that is raw and not blended with any other product or otherwise adulterated. The bill defines "pure honey" by reference to the Agriculture Code as the nectar of plants that has been transformed by, and is the natural product of, bees and that is in the comb or has been taken from the comb and is packaged in a liquid, crystallized, or granular form.
H.B. 519 removes the requirement that the label for an operation's honey or honeycomb include the following:
·the net weight of the honey expressed in both the avoirdupois and metric systems;
·the beekeeper's name and address; and
·the statement "Bottled or packaged in a facility not inspected by the Texas Department of State Health Services."
The bill establishes that an operation that extracts honey from honeycomb is harvesting a raw agricultural commodity and that an operation that bottles extracted honey and packages cut honeycomb is packaging a raw agricultural commodity without necessitating any additional manufacturing or processing. The bill defines "raw agricultural commodity" by reference to its definition under the Texas Food, Drug, and Cosmetic Act.
HB519 effectively deregulates the Texas honey market by abolishing the "Small Honey Production Operation" classification and removing the 2,500-pound annual production cap. Effective June 20, 2025, honey producers of any size are exempt from food manufacturing licensing and may sell wholesale to retail outlets, provided the honey is pure, raw, and produced from their own hives. Implementation Timeline Effective Date: June 20, 2025 (Note: This legislation passed with a 2/3 supermajority, overriding the standard September 1 date).
Q
Who authored HB519?
HB519 was authored by Texas Representative Mary Gonzalez during the Regular Session.
Q
When was HB519 signed into law?
HB519 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB519?
HB519 is enforced by Texas Department of State Health Services (DSHS) and Texas Department of Agriculture.
Q
How urgent is compliance with HB519?
The compliance urgency for HB519 is rated as "low". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB519?
The cost impact of HB519 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB519 address?
HB519 addresses topics including agriculture, occupational regulation, occupational regulation--other trades & professions, safety and food.
Legislative data provided by LegiScanLast updated: November 25, 2025
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