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Food Fraud in Food Additives

Food additives such as flavour-enhancers, gums, enzymes, emulsifiers, stabilizers, anti-caking agents, anti-oxidants and non-nutritive sweeteners are a bit of a “black box” when it comes to food fraud.  There are few records of food fraud in food additives in our Food Fraud Risk Information (Trello) Database, with the exception of vanilla extract flavouring, which has more entries.  However, just because we don’t have many public records for food fraud does not mean that it does not sometimes occur in food additives.

Food fraud problems with food additives might be less likely to become public knowledge because they are less likely to cause serious food safety issues compared to other food components, due to the tiny concentrations at which additives are present in finished products.  In the absence of a food safety incident or food recall, it is less likely that a food fraud will become public knowledge.

Food fraud in food additives might be easier to detect than food fraud in other ingredients.  For example, if a food additive was fraudulently diluted with a cheap filler, it would not perform as expected in a recipe, which would alert the food manufacturer to a problem.

Many food additives (excluding flavours) have short(ish) supply chains compared to other food types, which reduces the chances of fraudulent tampering with the product.

Fraud in food colourings

During July 2022, there were two border rejections for food colouring additives that contained unauthorised colouring agents.  The border rejections occurred in Europe.  The food colours originated in India.  It is not known whether the unauthorised components were present as a deliberate deception – that is food fraud – or if the importer was unaware of their regulatory status in the European Union. Links can be found in the food fraud incidents section.

 

Image: Pawel Czerwinski on Unsplash

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Food Safety Standards Compared (2022)

 

food vulnerability assessment

 

When it comes to food fraud, each food safety standard has slightly different food fraud 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.

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 protecting the retailers’ brands as well as keeping 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 practice in 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 often 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 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, 2022. 

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 activities Ingredients (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) Yes Yes Risk assessment Yes Implied (Edition 9)
Mitigation plan required?

 

 

 – Mitigation activities are to be included in the vulnerability assessment Yes Yes Yes Yes
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? – – Yes – 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 – – Yes Yes
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 (NEW!)

BRCGS Food Safety, Issue 9 (NEW!)

FSSC 22000, Version 5.1

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

IFS Food, Version 7

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 beginning!  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.
  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. Whether or not it is explicitly required in your standard, we recommend you 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.

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How to do a Vulnerability Assessment for Storage and Distribution

From the desk of Karen Constable, our Principal Consultant

The other day, a frustrated food safety manager wrote to me, wanting help to figure out how to do a food fraud vulnerability assessment for storage and distribution (BRCGS Issue 4).

It’s such a tricky one, because storage and distribution (S & D) facilities have so little direct control over product choices.  And the BRC standard is so wordy!

The good news is that when BRC first added product fraud to their storage and distribution standard in 2018 (Issue 3), they wrote a position paper that attempted to provide some guidance.

Even though Issue 4 is a bit different to Issue 3, the guidance in the position paper is still useful.

Here’s just a small portion of guidance from BRC Position Paper:

“The Standard does not define the exact process that the company must follow when completing the vulnerability assessment;however, it is likely to incorporate the following steps:

  • draw up a list of products and services and the controls that are already in operation (e.g. approval of suppliers by customers, pre-packaged products purchased)
  • consider any relevant information regarding potential fraud for each product and service
  • complete a risk assessment on the vulnerability of the products.

The output of the vulnerability assessment is usually a ranking or scoring of the materials to identify those which need additional controls. The ranking and actions required could, for example, be as follows:

  • Very high – a high-profile product with recent reports of adulteration or substitution published by regulatory authorities. Action or monitoring is required to ensure that only genuine materials are purchased.
  • High – a high-profile product that provides an attractive target for potential substitution or adulteration. Some action and/or monitoring is required to ensure that only genuine materials are purchased.
  • Low – this product is unlikely to be a target for substitution or adulteration. However, a re-assessment may be necessary if new information becomes available.
  • Negligible – no further action is required as the product is extremely unlikely to be a target for fraud.”

 

There’s more in the position paper, which you can read or download from the BRC Website: https://www.brcgs.com/media/1055426/sd308-position-statement-accommodating-the-requirements-of-gfsi-benchmark-72-into-issue-3-v2-12082019.pdf

If you are completely new to vulnerability assessments, we have step-by-step instructions on our website, which might help a little if you haven’t seen it yet.  Plus, our on-demand, online food fraud training might also help.  Although both of these resources were created primarily for food manufacturers the concepts of vulnerability assessments also apply to S & D facilities.

I can also assist with custom one-on-one consulting, guidance/feedback or custom templates if you need.   Just get in touch and we can hop on a phone call to discuss.

Regards,

Karen Constable

Food Fraud Advisors

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Vulnerability Assessments

What is a vulnerability assessment?

 

A vulnerability assessment is a risk-assessment-style evaluation of a food’s vulnerability to food fraud.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

Vulnerability assessments are also done to assess the threat of a malicious attack on food.  Malicious attacks include attacks conducted for extortion, ideological reasons or terrorism. We call these issues of food defense. To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

Why ‘vulnerability’ and not ‘risk’? 

 

  • A risk is something that has occurred before and will occur again. A risk can be quantified using existing data.
  • A vulnerability is a weakness that can be exploited.  A vulnerability can lead to a risk.

Food fraud is difficult to estimate and quantify, so we use the word vulnerability rather than risk.

Why do a vulnerability assessment?

 

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]

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Interpol and Food Fraud; Celebrating 10 Years of Operation Opson

Operation Opson is a joint activity of Interpol and Eurpol that targets counterfeit and sub-standard food and beverages.

This year marks the tenth iteration of Operation Opson.

Operation Opson X ran from December 2020 to June 2021 in 72 countries. Food and drinks worth €53.8 M were seized and 663 arrest warrants were issued.  Honey, beverages and horsemeat were areas of focus for this operation.  You can find the official Europol press release here.

Honey

Authorities performed 495 checks on honey samples as part of Opson X.  Samples were obtained from all along the supply chain, including from the farmgate, wholesalers, distributors and retailers. Most of the checks aimed to detect added sugars or corn syrup in the honey.  Of the 495 checks, 7% were found to be non-compliant and 51,000 kg of honey was seized.

Beverages

During Opson X, the most problematic beverages were wine and vodka.  A total of 1.7 M liters of alcoholic beverages were seized by authorities.  For wine, fraudulent bottling and labeling was a notable problem, with wine bottling operation(s) in Italy allegedly applying labels that misrepresented the geographical origin of the wine. In Spain, whisky with added colorant was found.  The colorant was said to have been added to enhance the perceived quality of the product.

Horsemeat

Horsemeat and the use of unapproved horsemeat for human food continues to be a focus for food fraud enforcement in Europe.  During Opson X, authorities uncovered sophisticated operations in which horses that were not approved for human consumption were being traded across international borders with false documents.  Investigations are continuing.

Other Meat

A survey of meat products in Germany found that 3% of samples (n = 264) were affected by species substitution, that is, the meat contained species that were not declared on the label. Source: Food Safety News

Unsafe and Fraudulent Seafood

Spanish and Portugese authorities identified illegal fishing of bivalve seafood such as clams in a wide-ranging investigation.  The seafood was harvested illegally and was not processed, handled or labeled properly, resulting in potential food safety issues.  At least 12 fishing vessels were implicated.

Food Supplements

In this iteration of Operation Opson, food supplements and additives were the second most seized food type, by quantity, after alcoholic beverages.  At the time of writing no details of such seizures are available.

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