Yes, and as I've said in this thread, I believe they have got it wrong.
There IS a possible exemption from the "Country of Origin" labelling for direct sales - which the BBKA don't mention.
Gloucester trading standards
http://www.tradingstandards.gov.uk/cgi-bin/glos/bus1item.cgi?file=*BADV091-1001.txt#tsi4
However there is no mention of lot/batch numbers in the food labelling regulations
A 'guidance' document on a website isn't the actual law. It is what they think it says.
I also notice that Gloucestershire TS insist that "Country of Origin" is required. Which we have the law references that dispute whether it is required. /// See my Addendum
I'm suggesting
that they have it wrong - on two counts (almost as though they - or the BBKA - had copied the other!)
And I'll hold to that view until anyone can give me a reference to the law (EU Directive, Statute, SI, or case law) that says Lot ID is not required for direct sales.
I've given a reference to the wide-ranging EU Directive that says it IS needed ("A foodstuff may not be marketed unless it is accompanied by an indication as referred to in Article 1(1).") and none of the exemptions listed in Para 2 apply, so where is the exemption?
/// Addendum - the Food Standards Agency refer to the actual laws in their "guidance" - what a pity Gloucestershire don't!
The term “prepacked for direct sale” is defined in the FLR as a food that is prepacked by a retailer for sale by him or her on the premises where the food is packed, or from a vehicle or stall used by him or her.
Products which fall within this category will be subject to certain exemptions by virtue of Regulation 23 of the FLR. This applies to honey harvested at home and sold at the home, farmgate or in market stalls. Regulation 4(1) of the Honey Regulations requires certain additional labelling information such as an origin declaration to be given on specified honey products. It does provide that this is without prejudice to the generality of Part II of the Food Labelling Regulations 1996, which means that the general provisions in that part of the 1996 Regulations continue to apply. Part II of the 1996 Regulations through the application of regulation 23 provides that certain products which are prepacked for direct sale are exempt from the majority of the labelling requirements specified in Regulation 5 of the FLR, with certain specified exceptions. Since country of origin labelling is part of Regulation 5 (by way of Regulation 5(f) which is implemented via the 1998 amendment to the FLR), it is the Agency’s opinion that honey prepacked for direct sale may be exempt from the origin labelling requirements of the Honey Regulations.
However, for clarity, I myself think that it is simplest to put the Country of Origin on the label so that it could be used for indirect (shop) sales - whether or not it might be strictly required for Direct Sales.