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Olive Oil Fraud Update – Is the Crisis Over?

When it comes to fraud-vulnerable foods, olive oil is a rockstar.

When Food Fraud Advisors began in 2015, olive oil was considered one of the most fraud-affected foods on earth, with reports of fraud dating back to the first century AD.

And then things got worse – much worse – for olive production and fraud rates in olive oil skyrocketed.

Olive groves in some of Europe’s major growing areas were decimated by the bacterial disease Xylella fastidiosa, which infects the xylem of olive trees and other trees. The disease, which is native to the Americas, has a mortality rate of up to 100% in susceptible olive cultivars. It is spread by insects that feed on sap, such as the meadow spittlebug (Philaenus spumarius).

Since its discovery in Italy in 2013, more than 21 million olive trees have been destroyed by the disease in Southern Italy, devastating local olive oil production.

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.

 

In addition to tree losses from Xylella fastidiosa, droughts and heatwaves in the 2022-2023 season affected key growing areas in Spain, the world’s largest producer, causing harvest volumes to plummet. Similar losses were experienced in Morocco, after annual production dropped to less than half of 2021 levels following two years of drought in the country.

However, things may finally be looking up for olive production and for olive oil. The olive oil industry has been predicting strong harvests and a return to more typical prices for oils since early 2025.

Wholesale commodity prices are currently at just 65 percent of their all-time high, which was reached in January 2024.

Wholesale commodity prices in July 2025 are just 65 percent of their all-time high in January 2024. Image: YCharts, with data from the International Monetary Fund (https://ycharts.com/indicators/olive_oil_price)

 

Frauds in olive oil include false claims about geographical origin, ‘extra virgin’ status and ‘organic’ (bio) status, counterfeiting of premium brands, theft of oil, theft of olives, clandestine manufacturing, blending with undeclared oils, replacement with other oils and addition of colourants.

 

The 2024 olive oil crisis

In 2024, I captured an unprecedented number of reports of olive oil fraud in public media, more than double any previous year since 2015. There were 15 incident reports in 2023 and more than double that number in 2024. In 2025, the numbers are trending back towards 2023 levels, with 7 incidents recorded in the first half of the year.

While an increased number of media reports does not necessarily mean more fraud, the fact that both wholesale and retail prices were very high in 2024, and significant enforcement operations were reported frequently, gives me confidence that the increased number of reports is a true reflection of more fraud activity.

 

An unscientific tally of food fraud incidents, 2015 – 2025, by the author, with the dotted region denoting an extrapolated count for 2025.

 

Note: the counts I’ve described are indicative at best because they only capture incidents and survey results that have been reported by mainstream media outlets or scientific journals, AND discovered by me and my software systems during my weekly searches for food fraud intelligence.

Did we see the crisis coming?

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 rose by significantly more than that, more than doubling between 2022 and 2024.

In October 2023, I warned that due to the shortage of olives in Europe, non-European-grown oils could be fraudulently misrepresented as European oils.

Olives in Europe became so expensive and scarce in 2023 and 2024 that criminals were chainsawing off fruit-laden branches of olive trees, and even taking whole olive trees from orchards by night. Some growers resorted to microchipping their trees in response to the spate of thefts.

Spanish law enforcement agencies responded to the crisis by undertaking 300 different operations in olive growing areas in 2023, stopping vehicles full of stolen fruit, raiding oil mills, and arresting mill operators who were processing stolen fruit.

In Greece, the government warned consumers of increased fraud risks and recommended they only buy oil from reputable vendors.

Is the crisis over?

The most recent European harvest was strong, 12% higher than the five-year average, due to favourable growing conditions in key European growing regions.

In Spain, which accounts for 50 percent of global olive oil production, the most recent crop was almost double what was grown in the 2022-2023 season.

Wholesale prices began falling for consumer olive oils earlier this year and a spokesperson for a major Spanish olive oil supplier said in February 2025 that the price drops could be expected to reach supermarket shelves with a three-month lag.

While various pests and diseases are still a risk to olive trees that are stressed by climate change, Xylella fastidiosa is currently contained in Europe. The European Commission has declared the outbreak in Puglia closed.

Portuguese and Spanish outbreaks are similarly declared over, while in Corsica (France) the disease is considered to be contained. Countries continue to monitor for the presence of the disease.

The Xylella fastidiosa containment zone of Puglia, Italy, depicted in orange. The buffer zone (zona cuscinetto) is blue. Source: European Commission (https://food.ec.europa.eu/plants/plant-health-and-biosecurity/plant-health-rules/control-measures/xylella-fastidiosa/latest-developments-xylella-fastidiosa-eu-territory_en)

 

Unexpectedly, some groves that were thought to have been completely destroyed by Xylella fastidiosa have recovered, with a complete restoration of the crown of trees observed in 2024 in some areas of Italy, even among susceptible cultivars. The recovery phenomenon has been observed in young, old and even centennial groves, with some trees once again yielding commercial quantities of fruit.

In the past year, Greek production has rebounded significantly, with the most recent harvest almost double that of the previous year, which was the worst many had seen.

“Last year’s [Greek growing season] was probably the worst period I’ve seen in 20 years,” Prokopios Magiatis, olive production scientist at the University of Athens, who says this year is significantly better.

But the longer-term outlook remains challenging due to our rapidly warming climate.

In Greece, 130,000 olive trees were lost to fires in Evros in 2023, and wildfire burned 11,000 acres of olive orchards in 2024.

Climate change is causing rains to fall at the wrong time of year, leaving the trees with little moisture during winter. Warm winters also cause havoc with the trees’ reproductive cycles – if the nights do not get cold enough, the trees don’t enter the winter dormancy that helps them prepare for the following season.

In 2023, the European Union’s largest wildfire on record burnt olive groves near Alexandroupolis, Greece. Photo: Konstantinos Tsakalidis (via The Greek Herald,https://greekherald.com.au/news/greece-wildfires-burn-60-percent-of-evros-olive-groves/)

 

So, although some industry sources report things are looking up for olive production in Europe in 2025, other sources say extreme heat during flowering and the first fruit set period has already imperiled next season’s crop in some parts of Spain. The Andalusian region of Spain is predicted to have a small harvest for 2025-2026, due to heavy pest pressure, including praying olive blight.

And although Turkiye’s olive industry had a bumper season in 2024-2025, this year’s harvest is predicted to be just 60% of last year’s.

What about olive oil’s food fraud vulnerability?

As supplies of oil improve and prices ease, the motivating factors behind food fraud decrease – or to put it another way, when olives and their oils are not outrageously expensive, it’s less profitable for criminals to fake them, steal them and engage in illegal trading.

An increased focus by authorities in Spain and Italy has likely also caused some criminals to think twice about olive oil crime. In the coming months, I’m expecting to see many more reports of convictions and sentencing for crimes committed in 2021 and 2022, as investigations are brought before the courts in Europe.

In June 2025, four people were sentenced to prison in Spain for their roles in a multi-year-long fraud in which low-quality oils and sunflower oils were sold as extra virgin and organic olive oils, using a false geographical origin in the brand name. The crimes were discovered in 2021.

But while things are probably going to be slightly less crazy for olive oil fraud in the second half of this year and into 2026, I still consider olive oil to be particularly vulnerable to food fraud, because there has been no change to the characteristics that have made it a target since the earliest days of agriculture.

The oil is valuable, has multiple grades and variations that are difficult for most consumers to differentiate, carries significant price premiums for organic versions and certain provenances, and has a relatively short shelf life compared to other edible oils. Its liquid form makes it easy to dilute with cheaper oils, with the large price differential making such dilutions very profitable and the addition of colourants making it hard to detect without expensive analytical tests.

There is also a large pool of independent eateries and grocers in Europe which are sometimes willing to purchase from informal supply chains. Together, these characteristics make olive oil particularly vulnerable to food fraud.

Takeaways for food professionals and consumers

If you or your business purchases 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;
  • 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 ancient times 🍏 Experts have been warning of impending supply problems for olive oil due to the climate crisis since 2016 🍏 Tree diseases decimated harvests in major olive growing regions, and drought also had a severe impact on the 2022-2023 harvest, precipitating huge price increases for olive oils in 2023 and 2024 🍏 Reports of olive oil fraud were significantly more numerous in 2023 and 2024 compared to previous years 🍏 Harvests have recovered somewhat, although threats from climate change remain 🍏 Fraud activity and the number of reports of fraud in olive oil is expected to be significantly lower in 2025 compared to 2024, however olive oil remains highly vulnerable to food fraud 🍏

Sources: Links to all sources are hyperlinked within the text.

🔹 Many of the sources used for this article were discovered using iComplai’s AI-powered food fraud risk prediction system 🔹

This post originally appeared in The Rotten Apple.

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Paprika, Chilli Powder and Sudan Dye Contamination

Can paprika and chilli powder be “too red”?

This post was originally published in The Rotten Apple newsletter.

 

In 2016 an inspector from the New York State (NYS), Department of Agriculture and Markets visited a food market looking for suspicious spices. There had been a spate of adulteration incidents with paprika and related spices such as chilli powder and curry powder internationally and the New York authorities were surveying local supplies.

The inspector was Audrey, a colleague of Tom Tarantelli, now retired. Tom recently sent me an intriguing photograph of some products from the same brand that Audrey spotted that day.

In one store, Audrey noticed some packages of paprika that looked “too red”. This was, perhaps, a sign the paprika had been adulterated with unauthorised colourants.

She purchased the paprika and took it back to the lab for testing.  It was, indeed adulterated. Tom told me they found 2,400 ppm Sudan 4 and 850 ppm Sudan 1 in the product. It was one of the highest concentrations of Sudan 4 ever found, as high as the worst European case that had been reported up to that time.

The results were so remarkable that Tom purchased more packages to keep. “Realizing this product would be thrown away, I went to the store and obtained more. Such a great sample!” Tom told me.

That was in 2016, eight years ago.  Today, the products Tarantelli purchased are still a brightly-hued, fresh-looking red.

Paprika samples purchased in 2016 retained their “too red” colour for almost 8 years. This photograph was taken in December 2023. Paprika from this brand contained very high concentrations of the illegal, carcinogenic dyes, Sudan I and Sudan IV. Photograph: Thomas Tarantelli

 

The photograph above was taken just a few months ago, more than seven years after the samples were purchased. The colour is bright. Pure paprika, on the other hand, loses its red colour over time and ages to a dull brownish colour.

This is the challenge for spice traders: old paprika doesn’t have an attractive colour. Dull-coloured paprika is perceived to be of lower quality and to have less flavour, and therefore must be sold for a lower price.

One solution is for traders to add colouring agents to their wares. Since pure spices are not allowed to contain even food-grade colourants, the traders do not bother to use colourants that are safe or legal. Instead, they use colourants that are cheap, easy to obtain and easy to handle.

Sudan dyes seem to be popular with unethical spice traders who want to enhance the colour of the spices they sell. The dyes are industrial colouring agents, much cheaper than food-grade colours, and sold for use in industrial oils, waxes and shoe polish. Sudan I has an orange colour and  Sudan IV is a blueish red. Sudan dyes have been found in paprika, chilli powder and curry powder many times over the past decade. They are also a common adulterant in unrefined palm oil, which has a bright red colour when fresh.

Sudan dye adulteration was first detected in food in 2003, and was the cause of a huge recall in the United Kingdom in 2005, which affected 570 foods. Alerts and notifications for Sudan dye contamination continue to this day. Last month Italian authorities rejected palm oil from Ivory Coast because it contained Sudan 3 and Sudan 4 dyes and German authorities recalled cheddar cheese powder from Syria which contained multiple Sudan dyes.

There were 39 notifications for Sudan dyes in foods between 2014 and 2024 in the European Rapid Alert System for Food and Feed (RASFF), and 12 in the US FDA Import Alerts records. Many of the alerts are for adulterated palm oil, but in Europe, paprika, seasoning and spice blends, barbeque rub, chilli pepper, sumac and sweet and sour sauce were also affected. In America, barbeque flavoured snacks were affected in addition to palm oil.

FT-NIR spectra of a pure sample of paprika and the same sample after adulteration with Sudan II, III, IV and Congo red at 5 % (w/w). Source: Castell, et. al (2024)

 

The incident in 2016 wasn’t the only time Tarantelli and his colleagues found Sudan dyes in spices. In fact, they found sixteen commercially available spices containing such dyes in less than two years. The spices included turmeric, curry powder, malathy and chilli powder in addition to paprika.

Chemists from the New York State (NYS), Department of Agriculture and Markets found Sudan dyes in sixteen samples in less than two years. Source: Thomas Tarantelli in Food Safety Tech (2017)

 

The New York State inspectors reported their results to the US FDA, prompting a series of recalls. Unfortunately, the recalls were classed as less serious Class 2 recalls because of the assumption that spices like paprika are consumed in only small quantities.

However, as Tarantelli pointed out in an article he wrote in Food Safety Tech in 2017, assumptions about serving sizes can be wrong. In fact, when he compared the amount of spice consumed by some ethnic groups to the reference serving size used by the FDA they were 20 times higher.

“In the Code of Federal Regulations (CFR) Title 21, the serving size per meal for spice is referenced as ½ gram. However, certain ethnic groups may consume a daily amount of 20 grams of spice per person.”

Takeaways for food safety professionals

  • Foods that appear fresher, tastier or of better quality when their colour is more intense are vulnerable to adulteration with undeclared colourants.
  • Red-coloured foods such as paprika, chilli powder and palm kernel oil are sometimes adulterated with Sudan dyes to enhance their colour and increase their apparent value.
  • Sudan dyes are not approved for use in food, they are industrial dyes with carcinogenic properties.
  • Despite a long history of recalls, safety alerts and import alerts for Sudan dye adulteration, food fraud perpetrators continue to adulterate foods with this dangerous group of chemicals.
  • Although some food regulators consider adulterated spices to present a lower risk to consumers than other foods, because many people consume them in small amounts, some sectors of the population consume significant quantities of spices and are therefore at higher risk.
  • Food businesses that purchase red-coloured foods including spices and unrefined palm oil should consider such foods vulnerable to Sudan dye adulteration, and implement mitigations.

Main sources:

Castell, A., Arroyo-Manzanares, N., López-García, I., Zapata, F. and Viñas, P. (2024). Authentication strategy for paprika analysis according to geographical origin and study of adulteration using near infrared spectroscopy and chemometric approaches. Food control, 161, pp.110397–110397. doi:https://doi.org/10.1016/j.foodcont.2024.110397.

‌Tarantelli, T (2024), correspondence with author.

Tarantelli, T. (2017). Adulteration with Sudan Dye Has Triggered Several Spice Recalls. [online] FoodSafetyTech. Available at: https://foodsafetytech.com/feature_article/adulteration-sudan-dye-triggered-several-spice-recalls/.

‌There are ‘protected origin’ paprikas in Europe (more correctly known as Protected Designation of Origin (PDO)).  These protected paprikas are from specific regions and are known for their unique regional characteristics.  For example, there is a special paprika from a certain part of Spain called Pimentón de La Vera and one from Hungary called Kalocsai fűszerpaprika-őrlemény.  Source: Castell et al (2024)

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Is Food Fraud to Blame for the Cinnamon-apple Recall (Video)

Our Principal, Karen Constable, explains how high levels of lead may have got into applesauce (video audiogram).

For sources and a transcript, click here.

 

 

 

 

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Fraud in Botanical Products and Dietary Supplements

Fraud in dietary supplements and herbal medicines is dangerous and costly

 

Fraud is estimated to affect around 10% of food products and dietary supplements are almost certainly affected at levels of at least 10% as well.

Supplement fraud surfaces often in my food fraud searches. Food supplements and additives were the second most seized food type, by quantity, after alcoholic beverages in Interpol’s annual food fraud operation, Operation Opson X in 2021.

Just last month, I shared the stories of how two supplement brands were working to prevent online counterfeits of their products after finding fake versions of their products in the market.

In May, NOW Foods explained how to spot fake versions of their supplements on their website

Fraud in supplements comes in at least eight different ‘flavours’

(1) Fraudulent, misleading or unsubstantiated claims of efficacy. For example, glucosamine, a supplement marketed as effective for reducing osteoarthritis, may work no better than a placebo. In fact, one study was halted because the group taking glucosamine reported worse joint pain than the placebo group! (source)

(2) False claims of potency and purity, such as listing more active ingredient on the label than is actually in the product. For example, a survey of curcumin supplements in France in 2022 found that less than half of the products contained as much active ingredient as was declared on the label. (source)

(3) The addition of materials to trick analytical tests, making an ingredient seem authentic when it is not. For example, pigments from black rice added to elderberry to boost the amount of anthocyanins (source);

(4) The use of undeclared fillers and bulking agents. This is sometimes legitimate and sometimes fraudulent, depending on the filler, product labelling and regulations.

(5) Adulteration with undeclared pharmacological ingredients such as sildenafil (Viagara) and stimulants. Weight loss products and sexual function products are most often affected. For example, a pre-workout booster supplement from the USA was found to contain DMBA by German authorities earlier this year. DMBA is a stimulant that is an unauthorised substance in Germany (source).

(6) Misrepresentation of synthetic ingredients as ‘natural’. For example, 70% of “all-natural” turmeric extract supplements purchased in the USA in 2021 contained curcumins from non-natural sources (source).

(7) Addition of unsafe or unauthorised colourants. For example, powdered turmeric is adulterated with unsafe colourants lead chromate, metanil yellow, acid orange 7 and Sudan Red G (source).

(8) Counterfeiting, in which an entity that is not the brand owner creates and sells products that resemble the brand’s products. For example, a review of supplements that contained insufficient active ingredients found that most of them carried ‘fake’ barcodes, that either belonged to fictitious, unregistered companies or to companies that do not supply supplements (source). In Hungary, forty percent of young people reported that they had encountered counterfeit dietary supplements (source).

Fraud in Botanicals

A ‘botanical’ is a part of a plant, extract or essential oil that is traded for its therapeutic properties, flavour(s), or aroma(s)

If you want to know about fraud in botanical ingredients like herbs and complementary medicines, there is a fabulous resource provided by the American Botanical Council’s Botanical Adulterants Prevention Bulletins (BAPP bulletins).

Each Botanical Adulterants Prevention Program (BAPP) bulletin provides detailed information about a single material. Take the saffron bulletin, for example. It is seventeen closely written pages about saffron, its adulteration and the detection of such, including the molecular structure of its most important chemical compounds, its common name in a multitude of languages, its geographical distribution, the size of the market and, most importantly, a deep dive into the known adulterants for saffron and the methods for detecting them.

The Botanical Adulterants Prevention Bulletins are seriously detailed. This is an extract from the Saffron bulletin.

Fighting Adulteration in Botanicals

Earlier this year, the team behind the BAPP bulletins published an ambitious paper that sought to combine all the knowledge from all the previously published bulletins into a single, peer-reviewed journal article, in the Journal of Natural Products.

It is a truly remarkable article, with thousands of words of detailed information about every reasonably foreseeable adulterant for dozens of botanical ingredients used in complementary medicines, food supplements, functional foods, and cosmetics.

I was delighted to get a chance to talk with its lead author, and Director of BAPP, Stefan Gafner, PhD about the paper and the program last month.

KC: Is the BAPP an independent program? How is it funded?

SG: BAPP is funded by direct financial support, predominantly from industry sponsor members of the American Botanical Council. Memberships and endorsements for the ABC come from not just manufacturers and suppliers but from analytical laboratories, law firms, research centres and media companies from about 80 countries worldwide.

KC: Can you tell me about your recently published Botanical Ingredients Forensics paper: why did you create it and who was it made for? What do you hope it will be used for?

SG: The inspiration for the paper was to combine the knowledge from multiple past [BAPP] bulletins so that all the information is in one place. We wanted to make the knowledge more accessible to a larger audience. The main target is QC people in industry labs.

The paper discusses three main adulteration types and how to test for them in dozens of botanicals:

  • Bulking agents, such as undeclared starches or fillers;
  • Addition of extra marker compounds to trick the analytical tests, such as pigments from black rice added to elder berry to boost the amount of anthocyanins;
  • Removal of valuable constituents, such as ginger or cinnamon with the essential oils removed before being ground up and sold as ginger powder or cinnamon powder.
Three classes of fraud in botanicals: fillers, undeclared marker compounds, removal of valuable components

KC: Do you worry (like I do) that sharing too much information about adulteration and adulterants that can evade detection is helpful to the bad guys?

SG: I am concerned that BAPP work may provide some information on adulteration to bad actors. Some people tell me that I help unethical people learn how to adulterate, rather than how to prevent adulteration. But there are other ways for fraudsters to figure it out since most of the information we summarise is already publicly available. However, there is a risk that some of the less sophisticated adulterators could become more sophisticated; that’s my main concern.

I know that some of our documents have been translated into other languages, and I’ve been told they are available in Chinese via WeChat so I can imagine that other countries may have that information and may try to see how to get around [the tests].

But we know the BAPP information is making a positive impact. When we surveyed ABC members and asked if they had changed their quality control procedures, specifications or suppliers based on the information provided in BAPP, twenty to thirty percent said “Yes”, they did change specifications or suppliers based on the information, so the program has had a very good impact [in preventing fraud].

KC: How much fraud is occurring in botanical ingredients every day?

SG: We don’t know. There are too many unknowns. No one has done a comprehensive analysis of the market. While it is possible to summarise results from various papers there are many potential confounders. For example, you do end up counting duplicate samples this way and the sampling is often not designed to have been representative of the geographic market.

However, there have been two papers that attempted to get these figures, and came up with approximately 25% of samples being adulterated based on DNA with similar results for chemical analyses*. However, it is very variable between different products. For example, Gingko leaf extract could have an adulteration rate as high as 57% (this is from soon-to-be-published research reviewing tests of 533 samples).

Europe and North America had very similar results in the Gingko study, about 60% [of samples adulterated] for both.

We think there is less fraud in Europe in regulated herbal medicines, compared to food supplements which are less regulated.

KC: Wow so fraud in botanicals is a pretty big problem. How does the food supplement industry cope with fraud in botanical ingredients?

SG: Reputable suppliers are doing a good job of mitigating fraud. They know their own supply chain well, and some even grow their own ingredients. That is, they have vertically integrated supply chains. For example, during my time at Tom’s of Maine, a significant portion of the herbal ingredients, including echinacea, chamomile, thyme and calendula were grown at its farms in Vermont, USA.

Ingredient suppliers that grow their own botanicals are also less likely to supply fraudulent materials to their customers. Being vertically integrated obviously has its benefits.

However, there is more fraud when the supply chain is less well-controlled. An example is liquorice root, which is typically grown in small quantities on individual farms in China and India, and sold on to intermediate persons, aggregators and traders who grade and blend the root from all different places. This makes it impossible to really ‘map’ the supply chain or keep control of the quality or authenticity.

Another big problem is that consumers in the USA have been taught to expect to pay prices that are too low for quality herbal products. American consumers think about some herbal extracts like a medication like paracetamol (‘Tylenol’) or ibuprofen… they think it’s all the same and so it’s fine to just buy the cheapest. However, not all Echinaceas are the same. That is one of the biggest issues we have at the moment. The high-quality herbal supplements are usually more expensive.

KC: Are you seeing any new and worrying trends in fraud in botanicals? Any good news?

SG: The good news is the BAPP program has gained good support in its twelve years, with a substantial percentage of industry now supporting it, including from Europe, Asia and Australasia. The program is having real impact.

My biggest concern is the spiking of supplements with prescription drugs, followed by fortification with marker constituents, for example, ellagic acid added to pomegranate peel extracts (Punica granatum, Lythraceae) and synthetic curcumin used in place of genuine turmeric extract.

A new vulnerability is the increasing popularity of products containing mixtures of botanicals, say six or seven ingredients. These can include ingredients that are only present in sub-therapeutic doses, and that contain excipients instead of adequate levels of the labelled botanicals.

KC: Thank you Stefan, that was a fascinating insight into the industry and the important work you do to prevent adulteration in botanicals.

🍏🍏🍏🍏🍏

*Ichim, M.C. (2019). The DNA-Based Authentication of Commercial Herbal Products Reveals Their Globally Widespread Adulteration. Frontiers in Pharmacology, [online] 10. doi: https://doi.org/10.3389/fphar.2019.01227 and Ichim, M.C. and Booker, A. (2021). Chemical Authentication of Botanical Ingredients: A Review of Commercial Herbal Products. Frontiers in Pharmacology, 12. doi: https://doi.org/10.3389/fphar.2021.666850.

Main source:

Gafner, S., Blumenthal, M., Foster, S., Cardellina, J.H., Khan, I.A. and Upton, R. (2023). Botanical Ingredient Forensics: Detection of Attempts to Deceive Commonly Used Analytical Methods for Authenticating Herbal Dietary and Food Ingredients and Supplements. Journal of Natural Products. doi: https://doi.org/10.1021/acs.jnatprod.2c00929.

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Food Safety Hazards from Food Fraud (EMA)

Updated 28th June 2023

Are you confident in your FSMA preventive controls for hazards from food fraud?

This post is for you if your company manufactures food in the USA or exports food to the USA.

Food companies in the USA must comply with food safety regulations that require them to identify and address hazards from economically motivated adulteration (EMA), a type of food fraud.

In this post you can learn what EMA is and how to identify food safety hazards from EMA.  You can also discover what type of preventive controls are best for EMA hazards.

Definitions

EMA is short for economically motivated adulteration which is a type of food fraud.  Other types of food fraud include counterfeiting, making false claims (for example, fake ‘organic’ food) and species substitution (for example, selling cheap white fish labelled as snapper).

“Economically motivated adulteration (EMA) occurs when someone intentionally leaves out, takes out, or substitutes a valuable ingredient or part of a food. EMA also occurs when someone adds a substance to a food to make it appear better or of greater value.” (US FDA)

FSMA denotes the Food Safety Modernization Act (USA). is a set of rules for food manufacturers. Under the rules, food manufacturers must assess food safety hazards and implement preventive controls. The US Food and Drug Administration (FDA) is responsible for the enforcement of the rules.  If your company is outside the USA but exports to the USA, you must also comply with the FSMA rules.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food.  (Find the official FDA definition here)

Preventive controls are procedures and systems that are designed to ensure that food safety hazards are prevented or minimized to an acceptable level.

Rules for food fraud (USA)

FSMA requires that preventive controls are implemented by food manufacturers to prevent hazards to human health.  The relevant regulation is called the FSMA Final Rule for Preventive Controls for Human Food, and is commonly known as the Preventive Controls Rule.

The Preventive Controls Rule requires food manufacturers to identify and control hazards that could arise from:

  • natural occurrences (for example, some raw meat products naturally contain certain human pathogens);
  • unintentional contamination (for example food may be accidentally contaminated with a pesticide during a pest control treatment), and
  • economically motivated adulteration (EMA).

After food manufacturers have identified the hazards, they must minimize or prevent the hazards by creating and implementing preventive controls in their food manufacturing operations. These are procedures and systems that are documented and that include monitoring, corrective actions systems and verification activities.  The preventive controls form part of the food manufacturer’s food safety plan.

Learn more about the preventive controls rule on the FDA’s preventive controls guidance webpage.

A separate part of the FSMA rules also requires food manufacturers to create and implement systems to prevent intentional, malicious adulteration.  The FDA calls this type of adulteration Intentional Adulteration (IA). It is different from economically motivated adulteration.  Intentional adulteration prevention is also known as food defense.  Click here to learn more about food defense.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food

Examples of hazards from economically motivated adulteration (EMA)

Economically motivated adulteration (EMA) is a subset of food fraud.   Food fraud includes many types of deception carried out for the purposes of economic gain.  It includes activities such as mislabeling (for example, making false claims about the geographical origin of a food product) and other fraudulent activities that do not involve the adulteration of food.

Economically motivated adulteration is a type of food fraud in which a person has added a substance to food to enhance its apparent value or profitability.  Often the added substance will boost the apparent quality or appearance of the food, other times the substance will be a diluent, which dilutes or replaces the genuine material with a cheaper material, thereby increasing the profitability of the resulting mix.

Food businesses are required by law to

  • understand food safety hazards that may be in their products;
  • create and implement systems that will prevent, minimize or eliminate those hazards;
  • systems for preventing, minizing and eliminating hazarsd  must be documented in a food safety plan.

Economically motivated food fraud (EMA) happens when food fraud perpetrators add materials to increase the apparent value of the food or to extend its shelf life in an undeclared or unlawful manner.  Materials that are added to make food or ingredients seem bigger, or heavier include water and other liquids, or fillers and bulking agents, such as starches, husks or sawdust.  Adulterants that are added to make food look better include unauthorised colorants, glosses and glazes.  Adulterants that extend shelf life include non-approved preservatives.

Food safety hazards can arise from EMA.

The food safety hazards from such adulterations include acute or chronic chemical poisoning, allergenic reactions, and microbial illnesses from pathogens introduced during the adulteration processes.

Example: Unauthorized color in turmeric

A significant proportion of powdered turmeric traded worldwide contains unsafe levels of lead.  Researchers in Bangladesh have confirmed that the lead is added to the spice in the form of toxic lead chromate which has an intense yellow-gold color, the color favoured by turmeric traders and buyers as an indicator of freshness and quality.  Curry powder, cumin and cinnamon have also been affected.  A survey of more than 1496 samples of 50 spices from 41 countries found that 50% of the spice samples had detectable lead, and more than 30% had lead concentrations greater than 2 ppm, a level that is 200 times higher than the recommended maximum lead content of candy in the USA.  Lead is a potent neurotoxin that damages organs including the brain.

Example: Undeclared peanuts in chopped hazelnuts

Peanuts are cheaper than most other nuts which makes them an attractive ‘filler’ or bulking agent in chopped nuts, powdered nuts and nut pastes.  When a food fraud perpetrator adds peanuts to a tree nut product, they gain more profit than if they sold a pure paste or powder.  In Germany in 2017, authorities found bulk quantities of chopped hazelnuts adulterated with 8% chopped peanuts.  The chopped hazelnuts were sold as ‘pure’ hazelnuts and did not declare any peanut ingredients on the label.  Because peanuts are a regulated human food allergen, their presence in the hazelnut product presented a serious food safety hazard.

 

How to identify hazards from economically motivated adulteration (EMA)

Follow the five steps below to identify hazards from EMA food fraud for your food manufacturing preventive controls plan.

  1. For each raw material that your company purchases to use in the food manufacturing process, investigate whether economically motivated adulteration is likely to occur within the supply chain.  Ask yourself: could adulterants be present in the raw material when it is purchased?  Learn how to investigate susceptibility to food fraud here.
  2. For each raw material and each finished product your company makes, also investigate whether economically motivated adulteration could occur inside your manufacturing facility or storage areas.  This is sometimes known as ‘insider activity’.
  3. After you have understood whether adulteration is likely to occur for each raw material, make a list of adulterants that could be added to each of the susceptible foods.   Historical records of past incidences of food fraud provide the best indication of the types of adulterants that can be expected in different foods and ingredients.  This page has a list of databases you can use to find historical records. .
  4. For each possible adulterant, make a note of whether it could be hazardous to human health if present in the food.  As an example, olive oil is commonly adulterated with (non-olive) vegetable oils.  That type of adulteration is unlikely to be hazardous and as such it would not require a preventive control under the FSMA rules*.   Document your decisions and justifications for such.
  5. Add the economically motivated hazards you have identified to your company’s food safety plan.  Implement preventive controls for each hazard.  Supplier approvals programs are commonly used for control of economically motivated hazards in incoming raw materials.

Need to learn more about food fraud prevention?  Visit our online training school.  Courses start at just US$59.

*Even if not strictly required under FSMA rules, it is always a good idea to prevent any type of food fraud from affecting your products.  This will protect your company and brand as well as your consumers’ health.