Food Fraud Advisors

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What to do About Food Fraud (USA)

I was talking to a new client the other day.  They are based in the United States and had discovered their competitors’ products contain undeclared ingredients.

What should they do, they asked.

There is no simple answer, especially not in the US where there is a patchwork of overlapping government agencies and rules to navigate.

Here’s the process I follow with this type of enquiry:

  1. Establish whether food fraud has occurred or not
  2. Categorise the fraud into one of two types
  3. Determine which regulations and agency(s) are relevant to the fraud
  4. Review the evidence – what made you think this was fraud in the first place?
  5. Decide whether more evidence is needed before pursuing the matter
  6. Choose who to tell, and in which order
  7. Choose how to progress after initial responses
  8. Inform interested parties
  9. Follow up if needed
  10. Execute further action if required

Example: hazelnut oil

We’ll use the example of a company that sells pure hazelnut oil and has discovered that their competitors’ products, labelled “100% pure hazelnut oil” actually contain significant quantities of sunflower oil.

1. Establish whether food fraud has occurred or not

Is this food fraud?  Yes, because consumers or customers are being misled by the labels, the mislabelling provides an economic benefit to the seller and the mislabelling is illegal.

2. Categorise the fraud into one of two types

At this step, I ask myself “Has the food itself been affected in some way – for example by adding or subtracting an ingredient – or not?”, and categorise accordingly.

In this example, the food contains an ingredient that isn’t expected or declared.  Therefore the food has been affected.  On the other hand, if the fraud was a false organic claim on the pack I would categorise that as not affected.

Why is this important?  Because it can highlight any urgent food safety issues and helps me to decide how/where to report and what evidence will be needed.

Speciality oils like hazelnut oil are vulnerable to food fraud, including dilution with cheaper oils like sunflower oil. Image generated with Canva AI

 

3. Determine which regulations and agency(s) are relevant to the fraud

For the hazelnut oil example, the two main agencies are the Federal Trade Commission (FTC) and the US Food and Drug Administration (FDA): the FTC because the oil is ‘misbranded’ according to the Food, Drugs & Cosmetics Act (misbranding means the label is false or misleading); and the FDA because they are responsible for ingredient lists, traceability and quality defects in foods.

4. Review the evidence

In this example, we knew that the fraud-affected products contained sunflower oil because of testing my client had performed.  Before we decide on a course of action we need to know more about this testing:

  • Who did the testing?  Is the testing laboratory independent?  Is it accredited for this scope?
  • What method was used? Has the method been validated or approved?  What is the accuracy and precision?
  • How were the samples chosen?
  • Does the laboratory impose conditions on the use of results and reports?
  • Would the results stand up in court if needed?
  • Have duplicate or repeat test(s) been done?  Alternative methods tried?

For the hazelnut oil, we concluded we can be confident that the results show evidence of fraud, however, an internal laboratory was used, and this means the results are not independent and would not stand up in court, or to media scrutiny.

5. Decide whether more evidence is needed before pursuing the matter

In this case, the test results are not independent, so further testing would be needed if the matter were to be pursued in a court of law, or presented to media outlets.

6. Choose who to tell, and in which order

Who you choose to tell about a fraud depends very much on your relationship with the suppliers of the fraud-affected foods.

For example, if you are a customer – that is if you purchase the fraud-affected products – you should talk to the supplier on the telephone to explain what you found and find out what they have to say.  It’s entirely possible that the company is a victim of their supplier and are unaware of any problem.

If you are a competitor it is best practice to let the company know what you found.  Again, they could be victims of their suppliers.  Give them the laboratory report (if an external lab) and tell them to direct any questions to the lab – if the lab is okay with this.  Let them know you intend to take the matter further.

You can report the fraud to enforcement agencies immediately after you have told the company, or wait to see how they respond.

If there is a credible food safety risk you must report the issue to the relevant authorities so that they can take action to protect consumers.

The hazelnut oil company is in the United States, so we decided to report the issue to the organizations below, after informing the owners of the affected brands.

7. Choose how to progress after initial responses

We decided that if the brand owners did not take action to correct the frauds and prevent them from occurring in future – for example by changing the claims on product labels, or by altering formulations – that we would commence a civil lawsuit against the brand owners.

A lawsuit would require us to obtain further evidence, including independent tests performed by an accredited laboratory.

8. Inform interested parties

We contacted the brand owners first, then the authorities, keeping accurate records of conversations and correspondence.

9. Follow up

We expect to have to follow up with the companies and the enforcement agencies, and have set timeframes for this.

10. Further actions

We hope to avoid taking legal action against the perpetrators in the civil courts, and would like to see the matter pursued by the FTC and the FDA in a timely manner.

We will repeat the tests in the internal laboratory in a few months’ time to see if there have been any changes to the formulation of the products.

Want help with a situation like this?

If can brief senior management, help formulate a plan of action, work with your laboratory and take charge of all the communications.

Get in touch with me

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Is Food Fraud to Blame for the Cinnamon-apple Recall?

[Listen to an audio version of this post here]

In October 2023, cinnamon fruit puree baby foods were recalled in the United States after four children were found to have elevated levels of lead in their blood.  Multiple lots of the products were found to have “extremely high” concentrations of lead.

As of 23 January 2024, the number of affected people had increased to at least 385.

And this could be just the tip of the iceberg, because it’s thought that around 1.8 million packages were affected, accounting for around 8 months of production.  That means thousands, or perhaps tens of thousands, of other people also consumed the tainted food.

Watching the case numbers go up, from 4 cases in October to 251 in December and now 385, has been like watching a slow-motion train crash.

a chart of case numbers in the cinnamon applesauce recall
The number of cases has climbed from four to more than three hundred in just a few months.  Source: (US) FDA

How much lead was in the food?

The earliest reports from the FDA said the level of lead in the recalled foods was “extremely high”.  Later, they reported finding lead at levels of 2 parts per million (ppm) in one sample of the fruit puree.  That level is more than 200 times the maximum level proposed by the FDA in their draft guidance for fruit purees intended for babies and young children.

 

How did the lead get into the food?

Cinnamon was suspected of being the source of the lead contamination from the earliest days of the recall because products made by the same manufacturer without cinnamon were not affected.  It took some time for the FDA to obtain samples of the cinnamon for testing, and it was not until mid-December that results were published.

In December, the FDA confirmed that the cinnamon ingredient in the foods was the source of the lead.

How much lead was in the cinnamon?

The FDA found lead at up to 5,110 parts per million (ppm) in the cinnamon.

That is more than two thousand times higher than typical.  Cinnamon usually contains just 2 ppm of lead (Hore, et. al (2019)).  The amount in the cinnamon is also more than two thousand times higher than the ‘safety’ limit of 2.5 ppm proposed for cinnamon by the Codex Alimentarius Commission.

The figures below provide a graphical representation of the amount of contamination. The image on the left shows 5,110 ppm, the amount of lead found in one sample of the contaminated cinnamon, equal to five squares of the 32 x 32 grid. The image on the right represents the maximum amount of lead allowed in cinnamon: less than one pixel on your screen.

A graphical representation of the amount of lead in the samples. Left: 5,110 ppm, the amount of Pb found in one sample of cinnamon; Right, 2.5 ppm, the proposed maximum allowable limit.

Why was there so much lead in the cinnamon?

Cinnamon can become accidentally contaminated with lead in various ways.  Cinnamon trees, from which the spice is made, can absorb lead from the soil as they grow.  Cinnamon can also become contaminated with lead through contact with machinery or transport vehicles that have lead-containing alloys, solders or paints, or lead-containing environmental dust and dirt.

However, accidental contamination such as from the soil or through contact with paint results in low levels of contamination.  The levels of lead in the samples tested by the FDA were thousands of times higher than would occur from accidental contamination.

In the first months of the investigation, many food safety commentators openly discussed the possibility that the cinnamon was deliberately adulterated with lead for economic gain.  Tampering with food for economic gain is more commonly known as food fraud, or, in the USA “economically motivated adulteration”.

Lead adulteration of spices

For buyers and sellers of spices like cinnamon, one way to make more money is to add colourants to the spices to make them look better.  For example, fresh high-quality turmeric has an intense yellow colour, so adding yellow colourant to turmeric can increase its appeal, meaning it can be sold for a higher price.

Unfortunately, the colourants used by unscrupulous spice traders are not always safe.  Many of them are lead-based pigments, which are cheap, have intense colours and are easy to obtain in some countries.

The most well-studied example of such fraudulent adulteration is the use of lead chromate (‘chrome yellow’) to impart a bright yellow colour to turmeric.

🍏 Read how traders in Bangladesh were using lead chromate to color the turmeric roots they were selling (and what made them stop) 🍏

Lead chromate comes in a range of intense colours, ranging from pale brown to intense oranges and crimson.  In addition, because lead is a heavy metal, it is literally heavy.  Spices are traded by weight, so adding a lead-based pigment increases their weight and hence the price.

Lead-based pigments in spices have caused harm to children in the past. Lead-chromate adulterated turmeric caused children in the USA to be poisoned in 2010 – 2014. Paprika adulterated with lead oxide caused the hospitalisation of more than 50 people in Hungary in 1994.

A sample of the Georgian spice kviteli kvavili, also known as yellow flower or Georgian saffron, was discovered to contain 48,000 ppm of lead in a NYC Department of Health and Mental Hygiene (DOHMH) lead-in-foods survey. In the same survey, which assessed more than 3,000 food samples over ten years, nineteen cinnamon samples had a median lead level of 2 ppm, with the highest level in cinnamon being 880 ppm.

That figure, 880 ppm of lead in cinnamon, from a paper published in 2019, is not as high as in the latest incident, but it is more than four hundred times higher than ‘normal’, and enough to result in dangerously high levels of lead in any food to which the spice was added.

Mean lead concentrations in various spice samples: cumin, red chili, turmeric, coriander powder. The line at 2.5 mg/kg (ppm) is the allowable limit in Bangladesh. Source: Alam et al (2023)

Is this a case of food fraud?

Deliberately adding lead-based pigments such as lead chromate to spices is, unfortunately, a common food fraud practice.  The intention is to make more money for the perpetrator.

Some weeks after the lead results were shared by the FDA, they revealed that the cinnamon contained high levels of chromium as well.  Test results for other heavy metals, including arsenic and cadmium, were not higher than usual.

Two samples of cinnamon contained 1,201 ppm and 531 ppm of chromium, respectively.  The ratio of lead to chromium is consistent with lead chromate having been added to the cinnamon.

There have been many past cases in which food fraud perpetrators have added lead chromate to spices.  Because the cinnamon in this investigation likely contains lead chromate, and because lead chromate is added to spices to increase their apparent value by changing their appearance and adding weight, food fraud is the most probable explanation for the presence of lead.

Probable explanations for the extremely high levels of lead in the cinnamon:

  • lead is a component of the pigment lead chromate, which is used to impart bright colours to textiles;
  • lead chromate is cheap and easy to obtain in some countries;
  • lead chromate is sometimes used to illegally add colour to spices, particularly turmeric;
  • spices coloured with lead chromate appear fresher and of higher quality than uncoloured spices, and can be sold for a higher price;
  • lead chromate comes in a range of colours, including browns, crimsons and yellows;
  • the cinnamon in this incident contained very high levels of chromium as well as lead.  Chromium is also a component of lead chromate pigment;
  • spices adulterated with lead chromate are heavier than pure spice, so they can be sold for a higher price;
  • the addition of lead chromate to the cinnamon could have allowed the perpetrator to sell it for a higher price, resulting in economic gains.

Not a food defence (malicious contamination) incident

While some food adulteration actions are intended to cause harm for malicious purposes, lead adulteration does not lend itself to intentionally harmful adulteration.  Malicious acts are intended to create a high impact on consumers or companies, but lead poisoning is slow-acting and can take months or years to be identified, minimising the potential for a high-impact incident.

If the cinnamon was intentionally adulterated, the slow-acting nature of lead poisoning means the primary purpose of the adulteration was probably not to cause harm to consumers.

Conclusion

When the history of lead chromate adulteration of spices is considered, along with the presence of high levels of both chromium and lead in the cinnamon, and the fact that lead poisoning is slow-acting, it seems likely that the cinnamon used to make the recalled fruit purees was intentionally adulterated with lead chromate-containing material for economic gain.  That makes it an example of food fraud.

More details about the recall and investigation can be found here: Investigation into elevated lead levels in cinnamon-applesauce pouches (US FDA)

An earlier version of this post originally appeared in The Rotten Apple, a weekly newsletter for food professionals, by Karen Constable

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Olive Crisis (Fraud Warning)

The world’s olive crisis is hitting supply chains hard and fraud is rampant.

First it was the disease Xylella fastidiosa, which decimated olive groves across parts of Europe. Then came a drought in key growing areas of Europe. Production is down, and crime is up.

Puglia in Italy once produced half of Italy’s olive oil and was home to 60 million of olive trees, many of which were hundreds of years old but has lost 21 million trees to Xylella fastidiosa since 2013.

 

Olive oil is one of the most fraud-affected food products on earth, with reports dating back to the first century. The ancient historian Aelius Galenus described how merchants would dilute expensive olive oils with cheaper ingredients to increase their profits. A fifth-century Roman cookbook describes how to make cheap Spanish oil resemble expensive Italian oil by adding minced herbs and roots.

Since I began collecting food fraud stories in 2015, olive oil adulteration and misrepresentation have featured often, but in the past few months, the number of incidents has increased noticeably. And these days, it’s not just oil, other olive products are also at risk of food fraud.

I first started collecting information about threats to olive oil supplies in 2016, writing that olive growers were having trouble with pests and diseases, including Xylella fastidiosa, in Italy, Greece and Spain.  In 2016, experts were predicting price rises for olives and olive oils in Europe, the United Kingdom and America because of risks to harvests from the disease.

One area hit hard by the disease was the Italian region of Puglia, which used to produce 50 percent of Italy’s olive oil. Xylella fastidiosa appeared in the region in 2013, and 21 million trees were lost to it within a few years.

Less high-quality Italian olive oil meant more motivation for fraud, and the criminals responded.

In 2017, a survey of more than three hundred thousand litres of olive oil, conducted over two years in Brazil found 64% of 279 samples were substandard, with some products containing 85% soybean oil.

Since then, the number of food fraud incidents for olive oil appears to have grown, with a startingly high number this year. Among the food fraud reports that I have seen and collected for the Trello-hosted Food Fraud Risk Information Database and The Rotten Apple, this year’s tally stands at more than triple the ‘usual’ annual count.

From 2015 to 2021 there were zero to four reports of olive oil fraud in international media per year. In 2022, that number climbed to six. This year I have counted fifteen.

An unscientific tally of food fraud incidents and survey results, 2015 – 2023, by the author

 

It’s worth noting that this tally is indicative at best because it only captures incidents and survey results which are reported by mainstream media outlets or scientific journals AND discovered by me and my software during my searches for food fraud intelligence.

Olive fraud in 2023

In 2022, olive oil was predicted to become 25 percent more expensive due to droughts in the main olive-growing areas of Europe. However, the predictions fell short and prices have risen by significantly more than 25 percent.

Olives are becoming so expensive and scarce that criminals are chainsawing off fruit-laden branches of olive trees, and even taking whole olive trees from ochards by night in Europe. Some growers are even microchipping their trees in response to the thefts.

Last month, Bloomberg reported that European retail prices have doubled in the past year, and that EU exports of olive oil are expected to be lower by 10 percent.

In 2023 I have recorded a total of fifteen incidents and survey results from countries including Spain, Canada, Italy, Greece, Morroco, Brazil and Portugal. The fraud types included clandestine manufacture, marketing irregularities, theft of oil, theft of olives, labelling irregularities, blending with undeclared oils and mislabelling of the grade of oil.

In October I warned that due to the shortage of olives in Europe, non-European-grown oils could be fraudulently misrepresented as European oils.

Today’s food fraud news contains warnings about Moroccan olive oils, which are now subject to export restrictions to protect domestic supplies, after annual production dropped to less than half of 2021 levels following two years of drought in the country.

On the other side of the world, Brazillian authorities are closing down clandestine manufacturing sites, while Spanish law enforcement agencies have undertaken 300 different operations in olive growing areas, stopping vehicles full of stolen fruit, raiding oil mills and arresting mill operators who are processing stolen fruit. In Greece, the government is warning consumers of increased fraud risks and recommending they only buy their oil from reputable vendors.

Takeaways for food professionals

If you or your business purchase olive oil, limit your risk of purchasing fraud-affected oil by:
  • purchasing from reputable vendors and authorised stockists – avoid online stores, markets, street vendors, small independent outlets and anonymous sellers which are more likely to sell counterfeits and products from unauthorised or grey market sources;
  • purchasing premium brands, which are more likely to tightly control their supply chains;
  • considering sourcing oil from non-European growing regions, which may be less affected by scarcity and price increases;
  • paying attention to the taste and aroma of the oil and informing the vendor of any defects.

In short: 🍏 Olive oil has been vulnerable to food fraud since the beginning of recorded history 🍏 Experts have been warning of impending supply problems and price rises for olive oil since 2016 🍏 Tree diseases have decimated harvests in many major olive growing regions, and drought is also having a severe impact 🍏 Prices have increased significantly, for both olives and olive oil 🍏 Fraud activities in olives and olive oil appear significantly more numerous in 2023 compared to past years 🍏

Sources:

Mueller, T. (2007). Italy’s Great Olive-Oil Scam. The New Yorker. Available at: https://www.newyorker.com/magazine/2007/08/13/slippery-business

‌Ministério da Agricultura e Pecuária. (n.d.). Inspeção do Ministério da Agricultura identifica 45 marcas de azeite fraudados. Available at: https://www.gov.br/agricultura/pt-br/assuntos/noticias/mapa-identifica-45-marcas-de-azeite-fraudados

Olive Oil Times. (2022). Reimagining the Xylella-Devastated Landscape of Southern Puglia. [online] Available at: https://www.oliveoiltimes.com/business/reimagining-the-xylella-devastated-landscape-of-southern-puglia/114128

‌Petroni, A. (n.d.). The plan to save Italy’s dying olive trees with dogs. [online] www.bbc.com. Available at: https://www.bbc.com/future/article/20230111-the-super-sniffer-dogs-saving-italys-dying-olive-trees.

‌Food Fraud Advisors Food Fraud Risk Information Database: Olive Oil. Available at: https://trello.com/c/GHwJnQGp/369-olive-oil

 

This post originally appeared in The Rotten Apple.

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Fake (Counterfeit) Health Supplements

Two US supplement companies share their food fraud stories

Photo by Mika Baumeister on Unsplash

Supplements are supposed to be good for you, but two major brands in the USA have recently gone public over their challenges with counterfeits… and the counterfeits are not at all healthy.

Some of the counterfeit products contained plain rice flour instead of the labelled active ingredients. Some contained undeclared allergens like gluten and soy. One even contained traces of a scheduled pharmaceutical.

The brands NOW Foods and Fungi Perfecti recently went public about their discoveries of unauthorised copies (‘counterfeits’) of their products on Amazon, the online store platform. A third leading brand is said to also be affected.

The NOW Foods counterfeits were discovered after the brand owner received information from loyal consumers who noticed problems with products they had bought online and realised their purchases were not genuine.

One consumer reported that the product did not have the correct smell, colour or capsule size. The company has released images to educate consumers about how to identify genuine and fake versions of their products. Their vice president of global sales and marketing says the brand has experienced significant problems with counterfeits internationally for “years” and says the company is “looking into” anti-fraud measures.

Amazon reported that the fake NOW Foods products had originated in Kenya and contacted consumers who had purchased the product, telling them to throw it away and issuing refunds. Together, the brand owner, Amazon and the Department of Homeland Security plan to pursue and prosecute the supplier.

NOW Foods explains how to spot a fake on their website.

NOW Foods explains how to spot a fake on their website

 

The Fungi Perfecti counterfeits were discovered by the brand owner, which continuously monitors its sales channels to protect its brand. During recent monitoring, the company discovered packages with “irregularities” in one Amazon store and went on to find 23 separate Amazon storefronts all selling counterfeit versions of its products.

Adulterants and allergens

One counterfeited NOW Foods product was labelled as a herbal supplement but turned out to be simply capsules of plain rice flour.

When Fungi Perfecti tested their ‘fake’ products they were alarmed to learn that they all contained the allergens gluten and soy, while the genuine products do not.

Amazon has notified the Fungi Perfecti (fakes) purchasers and removed the products from their site. The brand owner has published the names of the storefronts that were selling counterfeit versions of their products and issued an allergen warning on their website.

Like NOW Foods, they also published images and descriptions showing consumers how to identify counterfeits, as well as a list of authorised sellers of their genuine products.

Amazon reportedly removed 6 million counterfeit items from its online sales platform in 2022, including food, fashion and electronics.

Sources:

https://www.newhope.com/news/now-foods-fungi-perfecti-still-investigating-counterfeit-products-sold-amazon

https://hostdefense.com/blogs/press-releases/fungi-perfecti-makers-of-host-defense-mushrooms-discovers-counterfeit-products-with-known-allergens-being-sold-on-amazon

This story was originally published in The Rotten Apple, a weekly newsletter for food professionals, policy-makers and purveyors. Subscribe for free for weekly insights, latest news and emerging trends in food safety, food authenticity and sustainable supply chains.

🍏 Discover The Rotten Apple 🍏

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Food Safety Standards Compared (2023)

 

food vulnerability assessment

There are many different food safety management system standards (FSMS), and they all have different requirements.  So how do you know which standard is the best one for your food company?

When it comes to food fraud, the food safety standards have minor differences in their requirements. For example, some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t; some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on finished products.  Some explicitly require training in food fraud awareness, while others do not.

Confused? We are here to help.  Read on to find out which standards have what requirements, and get recommendations for creating a great food fraud prevention (VACCP) program.

Background

Food safety standards are standards that describe requirements for food and related businesses.  The requirements aim to ensure that food and food-related goods are safe for consumers and customers.  The correct term for such standards is food safety management systems standards (FSMS).

There are food safety standards for all types of operations within the food supply chain, including:

  • growing and packing fresh produce;
  • manufacture of food and food ingredients;
  • buying and selling food (“brokers”);
  • storage and transport of food;
  • manufacture or converting of packaging materials;
  • manufacture of animal feed or pet food;
  • services such as cleaning, laundry, or pest control for food businesses.

The over-arching aim of all food safety standards is to keep consumers safe, but most standards also have secondary aims. Some of the most popular food safety standards were developed by food retailing groups, and these standards were written to protect the retailers’ brands as well as keep consumers safe. Other standards were developed to help food businesses understand best practices and gain a way to demonstrate their excellence through independent certifications.  Some standards include quality parameters, while others only address food safety issues.

There are dozens of internationally accepted food safety management system standards, each with slightly different requirements.  This can make it difficult to know which standards are ‘better’ or more suitable for your food company.

To solve this problem, a standard for food safety standards was created by the GFSI (Global Food Safety Initiative).  The GFSI assesses and approves food safety standards using a process called benchmarking. The aim of GFSI benchmarking is to define best practices for food safety standards and provide a way to compare and align different food safety standards.

Among the dozens of food safety standards, some are benchmarked by the GFSI (Global Food Safety Initiative), while others are not.  Benchmarked standards usually have more requirements and more rigorous expectations than non-benchmarked standards.  The auditing and certification processes for benchmarked standards are typically more time-consuming and more expensive than for non-benchmarked standards.

Food Fraud in Food Safety Standards

Food fraud prevention activities are an important part of all food safety management systems because food fraud can pose a risk to food safety.  Some food safety standards have separate, stand-alone requirements for food fraud prevention activities, while others do not.  Standards that are GFSI-benchmarked all include explicit, separate food-fraud-related requirements. Other standards rely on the hazard analysis elements of the food safety system to identify and control hazards from food fraud.

The GFSI requires all benchmarked standards to require food companies to do a vulnerability assessment for food fraud and create a mitigation plan for food fraud prevention.  Most GFSI-benchmarked standards also include details about which materials should be assessed and which types of food fraud need to be managed.

Non-GFSI standards vary in how they require a food company to approach food fraud.  Some specify or recommend a VACCP program, which is based on food fraud vulnerability assessment activities. Others, like AIB, require that food fraud risks be considered in the supplier approvals processes.  The regulations of the USA Food Safety Modernization Act (FSMA) require that food businesses identify hazards from economically motivated adulteration-type food fraud (EMA) and implement preventive controls to minimise the risks.

Among the most well-known standards, there are some notable differences. For example, the SQF Food Safety Code requires food businesses to assess and manage risks from counterfeit-type food fraud, while the BRC Food Safety Standard only requires businesses to assess the risks from adulteration or substitution activities. BRC requires horizon scanning activities, while the SQF and IFS standards explicitly mention food fraud training.

Below you will find a table that compares the current food fraud requirements of each of the major food safety standards.

Table 1.  Food fraud requirements of major food safety standards, 2023. 

Click here to open or download a pdf version of this table

 AIB*BRC*FSSC*GlobalGAP*IFS*SQF*
Food types to include in food fraud prevention activitiesIngredients (implied)

 

 

Raw materials

 

 

Products and processes

 

 

Unclear

 

 

Raw materials,

ingredients,

packaging,

outsourced processes

Raw materials,

Ingredients,

finished products

 

Food fraud types

 

 

 

Economically motivated adulteration (only)

 

 

Adulteration,

substitution

(only)

 

 

Any type where consumer health is at risk (in definition, Appendix A)

 

Unclear, however counterfeit or non-foodgrade packaging or propagation materials are included as examples

 

Substitution, mislabelling, adulteration, counterfeiting

 

 

Substitution, mislabelling, dilution, counterfeiting

 

 

Vulnerability assessments explicitly required?Risk assessment (implied, Appendix A)YesYesRisk assessmentYesImplied (Edition 9)
Mitigation plan required?

 

 

–Mitigation activities are to be included in the vulnerability assessmentYesYesYesYes
Does packaging need to be included in the vulnerability assessment?Yes

(implied)

 

Yes

(see 3.5.1.1)

 

Yes

(as per food fraud definition, Appendix A)

Yes

 

 

Yes

 

 

Implied

(primary packaging is a ‘raw material’)

Is a separate food fraud procedure explicitly required?––Implied (“method shall be defined”)–Implied

(“responsibilities shall be defined”)

Implied

(“methods and responsibilities shall be documented”)

Is training in food fraud explicitly mentioned?–Implied

(Clause 5.4.1)

––Yes

(Clause 3.3.4)

Yes
Is an annual review explicitly required?–Yes––YesYes
Other

 

 

–Horizon scanning for developing threats must be done (Clause 5.4.1)––Criteria for vulnerability assessments must be defined

(4.20.2)

Food safety risks from food fraud must be specified (2.7.2.2)

*  The full names of the standards are as follows:

AIB International Consolidated Standards for Inspection of Prerequisite and Food Safety Programs, 2023

BRCGS Food Safety, Issue 9

FSSC 22000, Version 6 (NEW!)

GlobalG.A.P. Integrated Farm Assurance (IFA), Version 5.4-1

IFS Food, Version 8 (NEW!)

SQF Food Safety Code, Edition 9

Takeaways

Among the major food safety management system standards, there are small but significant differences between food fraud prevention requirements.  Key differences include whether finished products or ingredients are to be assessed, which types of food fraud must be included and the presence/absence of requirements related to horizon scanning and training.

If that all seems confusing, don’t despair…

Recommendations for a robust and compliant food fraud prevention program (VACCP)

At Food Fraud Advisors we have been working at the intersection of food fraud and food safety since the very first days of food fraud requirements in food safety standards… and we’ve been helping businesses since day one.

Creating a robust and compliant food fraud program can take time and effort but it isn’t complicated.  Follow the steps below to get started:

  1. Carefully read the food fraud clauses of the standard you are/will be certified to. Pay attention to the food types and the food fraud types that are mentioned in your standard.  HINT: you may need to check the definitions or glossary. Carefully read the food fraud clauses of the standard you are/will be certified to.
  2. Pay attention to the food types and the food fraud types that are mentioned in your standard. HINT: you may need to check the definitions or glossary.
  3. Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
  4. Create a food fraud prevention procedure that defines the methods, responsibilities and criteria for food fraud prevention.
  5. You should also conduct training for all relevant staff and ensure that the food fraud system is reviewed at least annually.

Get a complete guide to the food fraud requirements of all the major food safety standards from us, the food fraud experts, here.