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How food fraud is uncovered; two cases of origin fraud

Origin fraud occurs when a food is misrepresented with respect to its geographical origin; it’s a type of fraud that can be categorised as ‘mislabeling’.

Examples of mislabeling include:

  • describing a fruit or vegetable as ‘organic’ when it was conventionally grown
  • cheeses and meats labeled as kosher or halal that are not
  • Spanish olive oil falsely declared as being ‘Italian’.  This is origin fraud.

Mislabeling is also called misbranding in some countries.  Because it is intended to deceive customers and consumers it is illegal under consumer protection laws and trade/contract laws just about everywhere.  Because almost every type of food fraud involves mislabeling to some extent, quoting statistics on mislabeling is difficult.  As an example, a botanical supplement labelled as 100% turmeric extract but that actually contains 15% filler is both mislabeled and diluted.  To make it even trickier, different organisations using different words to describe similar food fraud activities.  Learn more about classifying food fraud types in this great Food Safety Tech Article.  Suffice to say, mislabeling fraud is very common and, according to US Grocery Manufacturers Association, it affects around 10% of food products globally.

Coffee growers in Hawaii have launched a class action to protect their products

How do we expose origin fraud?  Typically, origin fraud is uncovered after authorities have been tipped off about suspect activity in a supply chain, either by people from within the supply chain or by competitors of the mislabeled product.   The evidence used to pursue the fraudsters often comes from either fraudulent documentation, or from testing of finished products.  This year we have seen an increase in the use of authenticity testing by representatives of ‘authentic’ brands to expose fraudulent products.  This is a trend that I expect to continue as test methods are improved, refined and can more easily be extended to assess specific product attributes.

I have been following this trend with interest and was reading, today, about alleged origin fraud in coffee in the United States. This is a case that is representative of the trend to use sophisticated test methods to authenticate finished product attributes.  Another recent example would be honey testing in Australia.  In the coffee case, growers from the Kona district of Hawaii have filed a lawsuit against retailers for allegedly selling ‘Kona’ coffee that does not contain a reasonable amount of coffee from the district. Kona coffee production is 2.7 million pounds, however more than 20 million pounds of coffee labelled ‘Kona’ is sold each year.  The plaintiffs claim to have analytical test results to support their claims.  Nineteen brands of coffee, sold by retailers including Walmart, Cosco and Amazon, have been named in the complaint.  Chemical testing technology underpins this current lawsuit, as it allows the coffee growers to show, for the first time, the actual Kona content of the coffee that is being allegedly mislabeled.  For this to be possible, the coffee growers would have had to organise for testing laboratories to create a database of chemical test results of authentic samples of Kona coffee.  Databases like this are used to model a product’s unique chemical fingerprint using sophisticated mathematical computations.  The test method can then be used to compare the ‘fingerprints’ of suspect brands against those of authentic products, such as Kona-grown coffee, and infer the amount of genuine material in each sample.  Developing databases for this type of testing is expensive and time consuming.  However, there are an increasing number of laboratories that have the machinery, skills and software to perform this work, so it is becoming more accessible to brand owners.

Specialty vinegars fetch high prices and can be vulnerable to economically motivated food fraud.

In cases that do not originate with product testing, it is activities in the supply chain that provide clues to origin fraud.  This month there have been reports of origin fraud for a specialty vinegar, Modena balsamic vinegar.  Modena balsamic is protected by a special geographical designation under European regulations.  According to these rules, Modena balsamic vinegar must be produced using grapes only from certain regions in order to be considered authentically ‘Modena’.  A massive fraud involving 15 million Euros worth of materials has been uncovered in Italy after a special operation by local authorities found that the wrong grapes were being used to produce this very expensive product.  Although operational details about this investigation are scarce, these types of actions by authorities are often initiated after authorities have received a tip off from someone connected with the supply chain.   Another example of such a tip-off includes this recent wine counterfeiting operation in which authorities became aware that a printing shop had received an order for 4,500 wine labels from a company that was not the brand owner.

More tip-offs and more testing are my predictions for 2019 and 2020.  These are going to lead to more investigations, complaints and enforcement actions against perpetrators of food fraud.  And that’s a win for everyone!

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Where’s my tricorder?

We would all love to have a magic machine that can tell us exactly what is in a food or a health supplement, but our current technology isn’t quite at the level of Star Trek yet.  Here’s a question asked recently on Reddit/foodscience . It follows a common theme for questions asked by entrepreneurs who are investigating food and supplement business opportunities.

Supplement testing

 

Question: How do I test supplements to make sure the ingredients are authentic and organic?

The Reddit poster explained that he had stumbled upon a mix of plant extracts that helped his acne and wants to make and sell a pill with those ingredients.  He writes:  “I sourced some plant extract manufacturers in china but I do want to test the plant extracts to check if they are actually what they are and if they are truly organic. Can someone please point me in the right direction as to how to do that?“.  A food manufacturing expert suggested that he seek a contract manufacturer to make the pills for him, which he said sounded like a good idea.  Then he asked “I’d feel a lot better if there was maybe a machine I could buy to check the composition of what was in there“.

Answer: I think you want a Star Trek Tricorder

I wish it was possible to buy a magic machine that will tell you what is in a product.  On the other hand I am a food/supplement fraud expert so if there was such a thing I wouldn’t have a job.

Organic testing is ‘simple’. Sort of.  To test for ‘organic’ status in a finished capsule supplement you can check that pesticide residues are absent.  There is no technology that allows you to put a pill into a machine and ask it to look for ‘anything’, so you need to ask the machine to look for specific pesticides.  The USDA perform this type of testing every year on fruit and vegetables.  Each sample is tested separately for around 200 different pesticides.  The USDA use a network of independent labs so it should be easy to find a lab that can test your finished product for pesticide.  More on the pesticide testing program here:  https://www.ams.usda.gov/datasets/pdp

Authenticity testing is not simple.

Herb-like ingredients can be tested for authenticity by an expert who looks at them under the microscope.  This only works if they are not ground up too small.

Liquid extracts and soluble powders can be tested using chromatographic methods, such as HPLC and GC.  In these methods the machine creates a chemical ‘fingerprint’ for the material and then compares that to the fingerprint of an authentic sample.  There are two things that make it difficult: firstly you need to find a lab that knows what an authentic sample fingerprint looks like for the material you want to test (they call this ‘having a database’); secondly, these methods are best suited to single ingredients.  Once you mix a whole bunch of ingredients together, if you test the mixture all the chemical fingerprints get mixed up and the machine can’t tell you which peak (which part of the ‘fingerprint’) comes from which ingredient.  There are ways around this but the methods are expensive as the databases are custom-made for each finished product that is to be tested.

Unfortunately it usually comes down to trust in your suppliers and a reliance on their systems and certifications.  Check all certifications to make sure they are not forged as unfortunately that is common in some countries.  Do this by contacting the certifier directly.

Reddit user: Karenconstable4

Want help with supplement authenticity?  Don’t know where to start?
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Letter from Thailand – food fraud, food safety, food excellence

The World of Food Safety Conference was held in Bangkok in conjunction with THAIFEX in early June 2017.  Delegates represented large and medium sized food businesses in South East Asia as well as government and trade organisations.  Thai, Singaporean, Malaysian and Myanmar delegates dominated the group.  The attendees were hungry for knowledge about food fraud and food fraud prevention; almost 50% of the topics across the two-day conference were related to food fraud, traceability, supply chain management and crisis management.

As well as speaking about recent trends and developments in food fraud, I enjoyed learning from the other speakers, sampling the wonders of THAIFEX and enjoying Thai food which was truly excellent.

Karen Constable spoke about Food Fraud at World of Food Safety Conference

 

Background checks as an aid to fraud mitigation

I was lucky to gain some fantastic insights into the intricacies and challenges of performing background checks on business people in Asia from Jingyi Li Blank,  Mintz Group.  Background checks on business owners are a great way to understand vulnerabilities to food fraud when seeking new suppliers or investigating sources of new raw materials.  South East Asia and China present some challenges for companies performing background checks, including the way that people in the area often have multiple spellings and versions of their names, as well as issues related to cross-border jurisdictions.

Prevalence of food fraud prevention systems

Julia Leong from PricewaterhouseCoopers shared some statistics on current levels of compliance among food companies who have interracted with the PwC SSAFE tool: 41% of companies have no systems to detect or monitor fraud, 36% have no whistle-blowing systems and 38% do not perform background checks on employees. Food businesses that neglect these areas are exposing themselves to serious financial risks from food fraud.

Support for food businesses in developing countries from GFSI

It was heartening to hear about the new program being launched by the Global Food Safety Initiative (GFSI) in developing countries.  The Global Markets Program is designed to bridge the gap between food operations with no formal food safety systems and those who have GFSI-endorsed certification by helping companies to develop food safety management systems through a process of continuous improvement.  Within the program, manufacturing support systems related to hygiene and other basic principles of food safety are implemented progressively over a defined time period as the companies work to attain either a basic or intermediate level of compliance.  The results are not accredited but become the foundation for further improvements so that the business can work towards implementing a complete food safety program.

Sustainability in the food supply chain; palm oil and coconut oil

Matthew Kovac of Food Industry Asia presented on behalf of Cargill, providing a fascinating introduction to the sustainability programs Cargill has introduced in their palm oil and coconut oil supply chains.  Cargill is a major grower, purchaser and refiner of palm oil and are aiming for a 100% sustainable target by 2020.   For Cargill, sustainability in palm oil means:

  • No deforestation of high value areas
  • No development on peat (burning beat causes air pollution and contributes to climate change)
  • No exploitation of indigenous peoples
  • Inclusion of small land holders

Coconut oil sustainability is being improved in conjunction with The Rainforest Alliance, by providing training and support for Filipino growers so that they can increase their yields, as well as providing them with access to wood fired dryers that allow the growers to produce copra that has better colour, less aflatoxins, less environmental contaminants and lower free fatty acids than traditionally sun-dried copra.

The many and varied hazards in HACCP for fish

It was both fascinating and scary to be reminded of the hazards to food safety from fresh fin fish by Preeya Ponbamrung, from Handy International: pathogenic bacteria, viruses, biotoxins such as ciguatera, biogenic amines (histamine being the most common), parasites and chemicals such as water pollutants and antibiotics used in aquaculture.  That’s quite a hazard list; it was heartening to hear Ms Ponbamrung describe the control methods employed by the fish processing industry to keep those hazards out of our food supply.

Crisis communications; winners and losers

We learnt about successful methods – and not-so-successful-methods – that food companies use to communicate food safety and food fraud risks to consumers.  Nestle was applauded for its fast, clear and practical response to reports of counterfeit versions of its popular MILO chocolate drink powder in Malaysia.  The brand owner promptly published instructions for consumers on social media and in the local press explaining how to tell the difference between the fake and the real product.

Image: MILO Malaysia Facebook, March 2015

 

Some other companies do not do so well with crisis communications.  Cesare Varallo of Inscatech, showed us that the public communications of Chipotle in the USA about its food safety problems were less than ideal.  The brand has suffered serious losses and it has been reported that 13% of its former customers say they will never return.  Time is of the essence in a food safety or food fraud crisis.  Does your company have a crisis plan?

Want to know more about any of these topics?  Get in touch with us, we love to help.

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Vulnerability assessment methods

There are two general approaches to performing a vulnerability assessment for food fraud.

But first…. for the purposes of this page, a vulnerability assessment is a risk-assessment-style evaluation of a food product or ingredient’s vulnerability to food fraud.  For information about food defense vulnerability assessments (intentional adulteration vulnerabilities), click here.

The two approaches are (1) a conventional risk assessment model or (2) based on the recommendations of the British Retail Consortium (BRC) in their guidance document Understanding Vulnerability Assessment (2015)

Food fraud vulnerability assessment Food fraud vulnerability assessment BRC

The conventional method is a combination of the likelihood of something occurring versus consequences if that thing occurs.  This method is recommended for all types of food businesses.  It allows businesses to identify their most vulnerable ingredients, products and brands and provides an excellent framework to prioritise mitigation strategies.

The second method is recommended for businesses wishing to meet the requirements of British Retail Consortium (BRC) Food Safety Standard Issue 7 and Issue 8 (clause 5.4.2).  The BRC method does not address the risks from all types of food fraud; it only addresses the risk from adulteration and substitution of raw materials and ingredients.  Therefore it is not recommended for businesses that need to meet the requirements of other GFSI food safety standards such as FSSC 22000 Version 4 (clause 2.1.4.6) or SQF Edition 8.  What are these acronymns?

For more information about how to conduct a vulnerability assessment, take a look at Vulnerability Assessments; What? Why? How?

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When organic foods are not what they seem

This piece started life as a good news story; results released by the USDA (United States Department of Agriculture) in January show that more than 99% of tested foods contained either no detectable pesticide residues or residues below the allowable limits. The USDA has been quick to share these results and assure consumers of the safety of the American food supply.  But there are some disturbing results within the raw data, results that are not mentioned in the official report.  In fact, for one industry sector, the results are very bad news indeed.

The tests were conducted by the USDA as part of its pesticide data program (PDP) during the calendar year of 2014 and the results were published in January 2016.  During 2014, testing was conducted on 10,619 samples of food (mainly fresh produce), and each sample was tested for about 200 pesticides.  That’s a lot of data, over two million test results in total, and the USDA does not include all of the results in their public reports, although they do share their raw data with anyone who wants to download it.  One aspect of the testing that is not discussed in the official report is that each of the ten thousand samples was categorized according to its marketing claim.  While the overwhelming majority of samples were categorized as ‘no claim’, there were 416 samples of products claiming to be either pesticide free or organic.

organic produce pesticide authentic fruit vegetable

A closer inspection of the raw data shows that of those 416 samples, 22% of them returned a positive result for at least one pesticide, often more than one.  That is, almost one quarter of all ‘organic or ‘pesticide free’ products contained pesticide residues.  And 10 of the 416 samples actually contained pesticide/s at levels denoted by the USDA as a violation or presumptive violation of allowed limits.  Approximately 2% of products that claimed to be ‘organic’ or ‘pesticide free’ in fact contained unsafe levels of pesticides.

The worst offenders were ‘organic’ frozen cherries.  Every sample of organic frozen cherries contained residues of at least one pesticide.  The results were similar for conventional frozen cherries.  Within both types, there were also a number of samples with violations or presumptive violations (unsafe levels) of pesticide.  Disturbingly, the organic frozen cherries had a much higher proportion of samples with unsafe levels of pesticide than the conventional frozen cherries.

Tomatoes also gave disturbing results; 75% of ‘organic’ and ‘pesticide free’ tomatoes contained at least one pesticide and 25% of them had unsafe levels of carbendazim (MBC) pesticide.  By comparison, only 18% of the tomatoes marketed without claims were found to be in violation of the pesticide limits.

Grape juice was another commodity that fared poorly for organic claims; of the 531 conventional and organic samples that were tested, there was only one that had pesticide levels deemed to be unsafe… it was labelled ‘organic’ and made in the USA.

Pesticide residue in food

What does this mean for organic foods?

Are organic foods free from pesticide residues?  In a word: no.  A significant proportion of organic foods contain pesticide residues and some contain pesticides at levels that have been deemed unsafe.  The pesticides detected on organic foods in the PDP study were almost entirely synthetic chemical pesticides that are not approved for use on organic crops.  The study did not include testing for commonly used organic-approved pesticides.

Do organic foods contain less pesticide and are they safer than conventionally grown foods?  Yes and no… the PDP data presents a complicated picture, with huge differences between commodity types, but on the whole, there were less detections of pesticide residues within the organic and pesticide free samples than the conventional samples.  However, the proportion of samples that were in violation of pesticide limits was comparable.  That is, if you live in the USA, the chance of consuming a product with levels of pesticide deemed unsafe by the Environmental Protection Agency (EPA) is similar, whether you purchase organic food or not.

Organic peas vegetable pesticide

Are some foods better than others?

The 2014 PDP testing regime included 26 food types.  Most were fresh or processed (canned or frozen) fruit and vegetables but testing was also performed on oats, rice, infant formula and salmon.  Carrots and nectarines were two foods for which the organic samples had better results than their conventional counterparts.  Both of these foods types had many samples that contained residues; for example, almost 100% of conventional nectarines and 96% of conventional carrots contained at least one pesticide. There were samples with violations or presumptive violations (unsafe levels) of pesticides for both conventional and organic carrots and nectarines, however the organic produce had lower proportions of samples with detectable levels of residues and lower numbers of samples with unsafe levels.

Organic summer squashes also fared well compared to their conventional counterparts, with less samples containing residue at any level and also less samples with unsafe levels.  Other organic foods, including blueberries, celery, canned green beans and fresh peaches, had lower proportions of samples with detected residues, but unfortunately, for those foods the proportion of samples with unsafe levels was similar for both conventional and organic types.

Both organic and conventional samples had excellent results for dairy-based infant formula and salmon.  Neither of those foods contained residue of any kind in any sample of either conventional or organic types.  Salmon samples included fresh, frozen, wild-caught and farmed salmon of different varieties from ten countries.

apples pesticide

Where can I get more information?

The USDA has published a fact sheet and a document entitled “What consumers should know” in the Agricultural Marketing Service section of the USDA website.

Download a copy of the official report from the USDA website by clicking here

The raw data is available to download here

Sensible information and discussion of organic and conventional farming methods from Scientific American.

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