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Food Safety Hazards from Food Fraud (EMA)

Updated 31st December, 2022

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 about hazards that may be in their products and must create and implement systems that will prevent, minimize or eliminate those hazards.  The systems 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.

The food safety risks 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$29.

*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.

 

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Saffron Fraud (Everything You Ever Wanted to Know)

What is Saffron?

Saffron is a spice made from the dried stigma (part of the flower) of the saffron plant (Crocus sativus). You can see the red stigmas in the pictures.

Saffron flowers showing the red coloured stigmas. Image credit: Lorenzo Lamonica

 

Why is Saffron Vulnerable to Food Fraud?

Genuine saffron is harvested by hand, highly prized for its colour and flavour and very expensive.  In fact, it is the most expensive spice and costs between USD $1,100 to $11,000 per kg.  The international saffron market was worth US $430 million in 2018.

Saffron trade is complicated.  Saffron’s most important growing areas are in Iran, Greece, Morocco and India. Afghanistan and Spain are also important sources of saffron.  Saffron labelled Spanish is mostly grown in other countries but packed in Spain. Iran accounts for most global production at 90% – 93% but only accounts for 40% of direct global exports, according to the report (confusing!), apparently because the Iranian saffron is resold by other countries.

With so much of its production in one country, and with a short harvesting season, saffron supply is extremely vulnerable to weather events.  For example, there was a tripling of prices from 2006 to 2009 because of heavy frost in Iran in 2007.  Climate change is a threat, with increased moisture in some areas leading to more fungal plant diseases, and drought in other areas limiting yields.

Saffron Fraud

Saffron is one of the most frequently adulterated foods.  Powdered saffron is more at risk than whole saffron.

The biggest food safety issue with saffron fraud is probably the use of synthetic dyes to boost the colour of fraudulent whole saffron and saffron powder. Sudan I-IV and Rhodamine B dyes have been found in saffron and are considered potentially genotoxic and carcinogenic.

Saffron threads. Photo by Syed F Hashemi

 

Adulterants in Whole Saffron

Here are some of the things that are added to saffron to fraudulently increase its value.

  • Parts of saffron flowers, including the yellow style and the white style.
  • Filaments from other plants, including corn fibres, safflower stigmas, calendula stigmas, pomegranate fruit fibres
  • Filaments from other sources including silk.  Adulterant filaments may be dyed with plant dyes including beetroot, pomegranate, fruit peel.
  • Liquids that are added to increase weight, including oils, glycerin and honey
  • Dyes and aroma compounds as listed below

Adulterants in Saffron Powder

Here are some of the things that are added to saffron powder to fraudulently increase its value.

  • Turmeric powder
  • Paprika powder
  • Ground seeds of sweet fennel, or annatto
  • Dried marigold flowers
  • Gardenia (Cape Jasmine) extract, for their crocetin esters which are also in saffron
  • Natural dyes from flowers and roots
  • Artificial dyes including erythrosine, ponceau 4R, tartrazine, Sudan dyes, magenta III and rhodamine B
  • Safranal, which is a synthetic aroma compound

Also, there are historical reports of fillers added for increasing the product’s weight, including chalk, gypsum and heavy spar (barium sulfate)

Other Types of Fraud (Non-Adulteration-Type Food Frauds)

  • Selling Philippine saffron or “saffron flowers” as if they are real saffron (C. sativus).  They are instead safflower or kasubha.
  • Exhausted saffron sold as whole saffron
  • Coloured paper shreds sold as saffron
  • Provenance fraud, in which the geographical origin of the saffron is misrepresented

Saffron testing

Testing is a challenge.  Microscopic inspections can be done on powdered as well as whole saffron, but they are time-consuming and expensive.  In addition, visual examinations won’t necessarily recognise adulteration with colourants or safranal.

Some DNA-based tests struggle to differentiate safflower from saffron, because they are closely related.  DNA tests also don’t find safranal or dyes.  Spectroscopic methods can be simple and quick but they are not very sensitive and won’t pick up all adulterants.   There are many other authenticity test methods, each with its own challenges.  It is recommended that a suite of complementary tests be used to cover all types of adulteration and fraud.  Provenance testing has been successfully done using stable isotope methods.

This piece was orginially published in The Rotten Apple, a weekly newsletter about food safety, food fraud and sustainable supply chains. 

Take a Look at The Rotten Apple Newsletter

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Oregano Fraud; six things every food professional needs to know

1. What happened?

Testing was conducted by the Australian consumer group Choice, mirroring tests conducted in the UK and published by the UK Consumer Group Which? in 2015.  A selection of packs of dried oregano were purchased from supermarkets (grocery stores), delis (specialty food stores) and grocers (produce stores) in three cities in Australia and a single sample of each was tested.  Seven of the twelve samples, over fifty percent, were found to be inauthentic, with the inauthentic samples containing between 10% and 90% of ingredients other than oregano, including olive leaves and sumac leaves.

2. Why test oregano?  

Herbs and spices are one of the rock-stars of food fraud; their complex cross-border supply chains, high price per kilogram and the fact that they are often sold in powder or particulate forms make them prime targets for adulteration, dilution and substitution with cheaper materials.  

oregano adulteration
Source: Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies

 

Why oregano in particular?  Professor Elliott, Director of the Institute for Global Food Security, and an international authority on food fraud conducted testing on oregano in the UK in 2015, the results of which were published by the UK Consumer group Which?.  It is possible that Prof Elliott used rapid evaporative ionization mass spectrometry (REIMS), a test method recently made available by Waters Corporation, although Which did not disclose the test method. REIMS makes use of a rapid sampling method that produces vapour which is analysed using time of flight mass spectrometry.  Sophisticated software compares molecular markers in the resulting spectrum with those in known materials in a database, allowing a sample to be quickly identified as belonging to a particular product type or not.  The method has huge potential for testing food authenticity, with one of the advantages being that unlike other tests for adulteration there is no need to specify which adulterants to seek.  A downside is that many hundreds or thousands of tests must be performed and compared to traditional analytical methods to create a database before the method can be used with confidence to determine the authenticity of any given material.

Professor Elliott recently revealed that Waters Corporation and Queens University, Belfast worked together to build a database of oregano samples (Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies).  This means that oregano is one of the few materials that can currently benefit from accurate authenticity testing using the REIMS method. 

3.  Are the results unexpected?

Global food fraud commentators attribute the presence of significant concentrations of adulterants or diluents in dried herbs to economically motivated food fraud in most cases, as opposed to seafood mislabelling which sometimes occurs due to unintentional errors in species identification.  Food fraud is estimated to cost the United Kingdom one billion pounds each year.  It is thought to be very common among some food types, including herbs and spices.

4. Who is responsible?

It is highly unlikely that any of the brand owners named in the Choice report were aware that they were selling adulterated herbs.  Most if not all of the brands included the Australian testing would have been sourced and packed under well-controlled systems that include vendor approval processes, formal specifications for incoming materials (such as bulk herbs) as well as certificates of analysis and declarations of conformity to specification.   The fraudulent tampering probably occurred further up the supply chain during drying, bulk packing, shipping or storage.  Interestingly, all seven adulterated samples contained olive leaves and two contained sumac leaves.  It is possible that tampering occurred in two different points within the supply chain for some products; perhaps one fraudster added olive leaves to bulk lots of the herb at a location close to the oregano growing area and sumac leaves were added by someone else at a later date.

5. What are the legal and financial ramifications?

The sale of misrepresented products is a breach of Australian consumer law and ignorance cannot be used as a defense.  The incidences were investigated by the Australian Competition and Consumer Commission (ACCC), an independent authority of the Australian government.  One company was fined a substantial sum for selling product that contained only 50% oregano leaves.  It is likely that other businesses that had been supplied with inauthentic herbs sought financial redress from their suppliers, either through purchasing contract penalties or through private legal action.

When a food business chooses to voluntarily recall or withdraw their products from the marketplace they may try to claim the costs against their business insurance. Insurance companies will seek to recover their costs from further up the food supply chain and this may have an impact on premiums in coming years.

6. What should food businesses do?

No food business is immune from economically motivated food fraud and preventing food fraud from affecting a business is a multi-functional task that should involve personnel from purchasing, finance and legal departments as well as food safety and quality personnel.  In the short term however, there are some things that can be done by food safety and quality personnel to help prevent, deter and detect food fraud without a lot of investment from other parts of a food business: 

  1. Update your purchasing specifications to include authenticity requirements.
  2. Review your vendor approvals systems and revise questionnaires and requirements if required.  Consider implementing more stringent requirements for those suppliers that provide vulnerable materials.
  3. Request certificates of analysis (CofA) from suppliers of vulnerable materials
  4. Begin a testing regime for vulnerable materials
  5. Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile
  6. Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials
  7. Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
  8. Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.

Want to learn more about food fraud mitigation in the spice industry?  This article in Food Safety Magazine provides an excellent insight. 

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About that “16 easy tests for fake food” video

A video about easy tests for food fraud went viral on Facebook on 1st Jun 2019.  It purports to show how consumers can test for real and fake foods at home.   Food fraud is estimated to affect 10% of all foods worldwide, so it’s a pretty big problem.  At Food Fraud Advisors we are in favour of increasing awareness about food fraud but that particular video is not a good way to do it; it’s full of scare tactics and misinformation.

Much of video in question, published by First Media under their banner Blossom is based on online articles published in India, where food fraud and unethical food business practices are a massive problem that presents both economic and public health risks.  In that country, it is not uncommon for powdered tea to be dyed with textile dyes and for ghee (clarified butter) to be adulterated with undeclared vegetable oil.  Likewise, there is a long history of adulteration of dairy products like milk with chemicals such as urea which is added to trick protein tests, vegetable oil and sugar.   Sadly, in that country, as in other developing countries, it is also common for some fruits, vegetables and dried pulses to be dyed with undeclared chemical dyes.

In India, consumers and government authorities are very aware of food fraud and there is much information online for consumer ‘fraud detection’ tests that can be done at home.   Many of the ‘tests’ in the Blossom video appear to be based on these methods.  Most of them don’t work, or show chemical characteristics that are not evidence of fraud or fakery.

Food fraud occurs more often in developed countries in North America, Europe and Australia, than many people might imagine.  However, it rarely occurs in the ways that are shown in the video Is your food fake or real? Find out with these 16 easy tests.   Lets take a closer look at each of the ‘tests’ in the video with Karen Constable, Food Fraud Advisors Principal Consultant, a food scientist and food fraud specialist.

Melting ‘plastic cheese’

The first part of the video shows a person holding a naked flame to processed cheese and claims this shows that it contains chemicals.  It’s tempting to imagine that all food manufacturers are evil multinationals full of mad, greedy scientists.  But the reason that food companies make and sell processed cheese is because it is convenient to use and it melts really beautifully, so people buy it.  Some people even buy it for the taste!  To achieve the pliable, smooth texture and perfect melting profile loved by consumers, manufacturers add emulsifiers when they make processed cheese.  The emulsifiers tightly bind the protein and fat in the cheese and this means that it behaves differently to non-processed cheese when exposed to a cigarette lighter.  No kidding.  This video by Kraft food scientists explains it perfectly: https://youtu.be/OTH11_oPT20.  Conclusion; processed cheese melts differently to unprocessed cheese and that’s why we buy it!  Conclusion:  this is not a test for ‘fake’ food.

Plastic rice

This part of the video shows a non-stick pan with rice grains interspersed with other white particles that turn clear as the pan is heated.  Rumours of plastic rice have surfaced in various developing countries a number of times since 2011, however none have been substantiated.  There have been credible reports of sacks of rice within large shipments being replaced with sacks of other materials, including paper pellets, sweet potato pellets or plastic resin, to increase the apparent value of the shipment, but there is no evidence that this ‘fake’ rice ever reached consumers.

Food scientists and government authorities in India have investigated but never found plastic rice.  However they acknowledge that rice in India has occasionally been adulterated with chemicals, including boric acid, to close its pores and make it appear shinier and brighter.  These chemicals could give the rice a strange texture or behave strangely when cooked.  This occurs only very rarely.

Rice-like granules made from plastic resins would be completely unchanged by cooking in boiling water, which does not match descriptions provided by consumers who claim to have cooked ‘fake rice’.  In the video, the melting crystals in the pan look like something you could buy in a see-through window art hobby kit.  Just sayin’.  Conclusion:  Reports of consumers cooking or eating plastic rice have never been substantiated.  This is not a test for ‘fake’ food.

Black calcium rocks in baby food

The ‘rocks in baby food’ part of the video is a great example of  how “a little learning is a dangerous thing” (Alexander Pope, 1709).  In the video, a person runs a magnet over a plastic bag of baby food and collects black particles.  Baby food manufacturers deliberately and legally add minerals like calcium and iron to their products, a practice which is called ‘fortification’.  Babies (and adults) need these minerals to grow and thrive.  The minerals used to fortify foods do ultimately come from the earth’s crust, so it’s probably fair – though somewhat disingenuous – to claim that they are ‘crushed up rocks’.  It is indeed possible to get tiny black particles out of fortified foods with a magnet, as you can see in this awesome food science experiment by Scientific American.  However, the magnetic particles are iron, not calcium; calcium is not magnetic.  (Food scientists around the world give a collective face-palm).  Conclusion:  Minerals added to baby food keep babies alive.  Black stuff in baby food is not calcium, it is iron and it is supposed to be present.  Conclusion:  this is not a test for ‘fake’ food.

Baking vitamins

My gosh where do I start with this one?  In the video, a person puts a collection of different coloured and shaped pills and capsules on a tray in an oven and shows some of them bubbling and melting.  Put any collection of different pills in the oven and they will behave differently.  That’s because they contain different things.  Legitimate, authentic vitamins and supplements contain fillers, active ingredients and casings that have both high melting points, low melting points and many different kinds of smoking, burning and bubbling behaviours when heated.  The video claims ‘Synthetic supplements burn; natural supplements don’t‘ but if I made a ‘fake’ pill with chalk or talcum powder it most certainly wouldn’t melt or burn in a domestic oven.

This video is the perfect visual ‘filler’; no real claims, no real evidence, I didn’t even find a historical or anecdotal basis for this one.  Having said that, there have been credible reports of supplements containing smaller quantities of authentic ingredients than they claimed to contain.  Worse, there have been cases of supplements that have been spiked with illegal and undeclared drugs to boost their efficacy.  Conclusion:  supplement fraud does occur, but the oven test in the video will not reveal ‘fake’ supplements.

supplements. authentic, ignite, burn, test
Supplements can be affected by fraudulent adulteration, but you cannot detect inauthentic supplements by baking them in the oven

Glue in meat

In most countries, it is legal to add binders, enzymes and edible ‘glues’ to processed meats and most of those ingredients must be declared on the package.   It is not legal to add chunks of ‘fake’ fatty substances to meat pieces and then sell them as if they were whole cuts.  The video shows what looks like a whole cut of meat, possibly lamb, with fat and connective tissue on and within the muscle.  (Yes, meat is animal muscle, people!)  The meat and fat is prodded and pulled by a fork to supposedly show ‘glue’.

Why on earth a food company would bother making fake, unappealing grisly, fatty bits to add to their ‘whole’ cuts of meat is beyond me; it would be expensive, technically difficult and result in an undesirable product.  Having said that,  there are legal and safe enzymes, including transglutaminase that can be used to bind muscle pieces to make larger pieces of meat.  Pulling such meat apart with a fork would not reveal enzymic binders like transglutaminase.  If binders are present, this ‘test’ would do nothing to reveal them.  Conclusion:  this is not a test for ‘fake’ food.

Bubbling ice cream

The Is your food fake or real? Find out with these 16 easy tests video shows ‘bad’ ice cream which bubbles if you douse it with lemon juice, supposedly because it contains washing powder.  The basis for this myth is probably the very sad situation in India in which local, small-volume suppliers of fresh cows milk have been caught adding detergent to the milk.  The adulteration makes the milk look fresh and foamy when poured from small milk cans into the larger containers used to collect local milk supplies in rural areas.  As for ice cream, I only found one obscure Indian post that suggests washing powder might be found in ice cream.  Perhaps instead, this is a nod to an incident in which noodles were adulterated with non-approved optical brighteners in Vietnam.  Optical brighteners make things look whiter and are found in washing powder.

When it comes to making bubbles with lemon juice, ice cream would need to contain a significant amount of washing powder to achieve the result shown in the video; a small amount of adulteration with washing powder is unlikely to be detectable with lemon juice while a large amount of washing powder would affect the product in other ways, including changing taste.  Let me assure you that of all the food frauds you might encounter in a developed country, washing powder in ice cream is not one of them:  I guarantee that even an unethical ice cream manufacturer is much too smart to feed their consumers washing powder.  Conclusion:  this would be a fun experiment.  It is not a test for ‘fake’ food.

Testing for rice in milk with seaweed

In this part of the video, seaweed is mixed into milk that is said to contain ‘rice water’ and the liquid turns blue.  In most – if not all – countries, it is illegal to add rice to milk without declaring it on the label.  As bizarre as this seems, this ‘test’ is actually plausible: rice starch would make a good adulterant for milk powder in developing countries and seaweed naturally contains iodine which forms blue-black-coloured reactants when exposed to starch, including the starch found in rice.  However I am not sure that seaweed contains enough iodine to produce the strong blue colour in the video.  Conclusion: if you had reason to believe that your milk contained a significant quantity of rice, this test might actually work.  But note that if you live in North America, Europe, Australia or New Zealand, the chances of your milk containing rice water is vanishingly small.

Floating coffee grounds

Ground coffee containing ‘additives’ is shown floating on water in this part of the video, which claims that pure ground coffee will sink quickly.  I don’t know enough about ground coffee to confirm or deny the claims that fresher coffee floats more than stale coffee due to its carbon dioxide content or not, however it sounds plausible to my food scientist brain, as does the claim that different degrees of roasting will result in different densities after grinding.   However I do know that there are many historical records of both coffee beans and ground coffee being adulterated with cheaper fillers like sticks, stones and corn husk to increase profits, most commonly in developing countries.

Coffee consumers in wealthy countries are unlikely to be affected by this type of food fraud.  It is possible that consumers in poor countries could detect adulterants like corn husks or undeclared chicory in ground coffee using a ‘float’ test but I can’t confirm that such a test would be accurate or repeatable.  Conclusion:  this test might be able to reveal certain unexpected contaminants in coffee grounds, however it is unlikely to be reliable.

Cloudy ‘fake’ salt

Sadly, there have been reports of industrial grade salt being repackaged as food grade salt in some African countries in recent years.  The video claims that if the water turns cloudy when you dissolve table salt that the salt contains chalk and is ‘fake’.  It’s true that chalky salt would be easy to identify: if salt contained chalk it would leave undissolved powder in the bottom of the glass when added to water.  On the other hand, you can get cloudy water with authentic, pure salt if the water is warm and contains dissolved air before the salt is added.  Chalk in salt is NOT a common type of food fraud, probably because chalk powder (calcium carbonate) is up to ten times more expensive than salt.  Conclusion:  this ‘test’ is a trick that can be done with pure salt.

salt chalk
Chalk in table salt? Unlikely!

Illegal dyes in tea, peas and sweet potatoes

Unfortunately, unscrupulous food sellers have been known to add undeclared, illegal colourants to food.  If you live in North America, Europe or Australia you are most likely to have encountered this type of food fraud in olive oil, green olives or chilli powder.  There isn’t a lot of evidence of it occurring frequently in dried peas, which are shown in the video being cooked in water that turns a pale green colour.   Tea that is claimed to be ‘impure’ is also shown leaching colour in the video.  In some countries, authorities have seized tea powder that contains illegal dyes or other materials such as brick dust.

As for rubbing sweet potatoes with cotton wool, which is done in the video to supposedly prove the presence of illegal dye, I’m not at all surprised to see red colour on the cotton after it has been rubbed on the sweet potato.  In my country (Australia) our tubers often have a reddish colour on their surface from the red-coloured soil in which they were grown.  Illegal dye-ing of fresh produce is thought to occur very rarely if ever in wealthy countries.  In poorer countries it does occur but is most frequent in produce for which quality and  price are determined by the intensity of colour of the fruit or vegetable.  Sweet potatoes are less frequently affected than table grapes or leafy greens.  Conclusion: this ‘test’ is a trick that relies on red soil found naturally on the surface of some sweet potatoes.

Turmeric adulteration

In this part of the video, two spoonfuls of ground turmeric are exposed to a naked flame.  One burns more readily than the other and the video claims that ‘pure’ spice burns more easily than impure spice.  It is interesting that the video makers chose turmeric to represent spices because it has been associated with numerous recalls due to adulteration with lead-containing colourants  in the USA.  This is very worrying given turmeric’s current popularity as a ‘health’ product in North America and Europe.  The lead colourant used to adulerate turmeric is bright yellow and enhances the colour of the turmeric, increasing its apparent value and hence its price.  This type of fraud is not common but does occur in developed countries as well as developing countries.

As for the test, it is possible, though unlikely, that adulterated turmeric powder would consistently burn in a different way to authentic, pure turmeric powder.  It is more likely that the moisture and oil content of each ‘batch’ or brand of powdered spice would result in different burning characteristics.   Conclusion:  adulterated turmeric might behave differently to pure turmeric when burnt however the test is unlikely to be a reliable indicator of purity.

Honey candle trick

I am sorry to say that adulterating honey by adding water, sugars and syrups is a practice that is as old as human trade.  Honey is valuable and adulterating honey, or diluting it with water is profitable, making it an attractive food fraud.  You can read more about the long and sordid history of food fraud in honey here.  In this part of the video, two samples of honey are applied to candle wicks and the wicks lit.  One candle burns properly while the other doesn’t.  I don’t know anyone who has tried burning honey on a candle wick, but it sounds fun (I’m beginning to wonder if the people who made this video are closet pyromaniacs!)

I have no reason to doubt that putting pure honey on a candle wick will result in a good flame.  Likewise if you put watered-down honey on a candle wick it seems very likely that the water in the honey will stop the wick from burning.   So this test seems somewhat plausible.  However, what we don’t know is (1) how much water do you have to add to pure honey for it to stop a candle wick from burning and (2) what about all the other types of honey fraud; the ones that don’t involve adding water?  Honey fraud can include the addition of other sugars, syrups and colours, rather than the addition of water.  Misrepresentation of variety, geographical origin and organic status are also common types of honey fraud.  These could not be detected using the candle wick test.  Conclusion: this test will show if your honey has lots of moisture in it but is not a reliable indicator of authenticity or adulteration.

Oil in butter test

In the video, it is claimed that if butter contains oil then adding sugar to the mix will result in a pink colour.  This is not true; try it yourself!  The claims are based on a test published in Indian media for checking the purity of ghee.  Ghee is clarified butter and used commonly in Indian cooking.  By law, ghee should not contain anything except butter fat.  Unfortunately there is a long history of ghee fraud in countries where it is popular.  Often the fraud occurs when an unauthorized manufacturer counterfeits an expensive brand which can be sold for a high price.  This ‘fake’ ghee isn’t really ‘fake’ but it does often contain vegetable oils, which are cheaper than butter fat.  There are articles published in Indian media that explain how to check ghee for the presence of vegetable oil by adding hydrochloric acid and sugar.  I haven’t been able to confirm or deny the efficacy of that test.  However, without the hydrochloric acid it most certainly won’t work!  Conclusion:  the test shown in the video is not a legitimate test and it wouldn’t work as a test for ‘fake’ food.

Wax on fruit

Have you ever bought an apple from the farm gate, or picked one yourself to take home and eat later?  Freshly picked apples taste great but if you keep them for more than a few days they soon lose their freshness and begin to shrink and become soft.  This is because apples, like many fruits and vegetables, start to lose moisture from the moment they are picked.  To prevent this, fruit growers apply a thin layer of edible wax to retain moisture and keep the produce fresh and tasty.  The wax is inert and safe to eat.  In the video a fresh, juicy bell pepper, also known as a sweet pepper or capsicum, is dipped into a bowl of warm water and a significant quantity of what looks like vegetable oil can be seen floating on the surface of the water afterwards.

I am not sure if the video is actually depicting fruit-coating wax, since I have never observed this much oily substance coming off any fruit or vegetable.  However it is true that bell peppers and many other fresh fruits and vegetables are routinely coated with wax.  And I am glad of it, since I don’t have time to drive to an apple orchard every time I want a fresh, crisp apple. Conclusion:  this is not a test for ‘fake’ food.

Food fraud does occur in both wealthy and developing countries, but almost never in the ways shown in the video.  When it does occur, unfortunately it is difficult for consumers to identify at home.

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Secrets of the horsemeat scandal

How did the enactment of an obscure transport law in Eastern Europe change the face of food manufacturing forever?  Karen Constable investigates the link between Romanian road rules and the horsemeat scandal.

More than six years after it first made headlines, the series of incidents that became known ‘horsegate’ continues to impact the global food industry.  It began in January 2013, when Irish authorities revealed they had discovered horsemeat in burgers that were supposed to contain 100% beef.  The discovery sparked a frenzy of testing and soon horsemeat was being discovered in dozens of different products in countries all over Europe and beyond.  The sheer scale of the contamination sent shock waves through the food manufacturing world.  Occurring five years after the melamine in milk powder scandal of 2008, which sickened over 300,000 babies in China, this incident was unfolding much closer to home for food manufacturers in Europe.  It was a wakeup call for our industry: we could no longer pretend that food fraud of a similar scale and impact as the melamine milk scandal could not happen in the western world.

Numerous massive recalls

The scandal resulted in market withdrawals of tens of millions of food products across Europe, millions of euros of lost business and multiple prosecutions.  Consumers’ trust in manufactured food plummeted and sales of frozen hamburgers and frozen ready meals dropped by 43% and 13% respectively in the United Kingdom in the month following the first product withdrawal.

Multiple investigations

Despite some media reports claiming that the first horsemeat discovery was the result of ‘routine’ testing, it is now known that the scandal was uncovered almost by accident.  As strange as it may seem to the wider community, it is unusual for food manufacturers and regulatory authorities to test foods for materials that are not expected to be present.  This is, of course, how the perpetrators of the Chinese melamine fraud could conduct their activities on such a large scale for what is thought to be a significant length of time.  The original horsemeat tests were conducted by the Food Safety Authority of Ireland because a sharp-eyed inspector had noticed a discrepancy between packaging and labelling of frozen meat.

As the investigations began it became apparent that law enforcement and regulatory authorities were ill-equipped to manage the complex cross-border issues that arose.  Supply chains seemed hopelessly complicated to unravel, with on-paper ownership of meat often disconnected from the physical whereabouts of the food.  By the time the scandal was declared over, investigators had identified at least three entirely separate supply chains involving different slaughterhouses, traders, processors and criminals.

Beef an easy target

Horsemeat and beef meat are similar in appearance, texture and flavour.  Yet the European market for horsemeat is relatively small compared with beef; it is not consumed by people in many Western European cultures. For unscrupulous merchants, however, horsemeat’s abundance and low price made it the perfect substitute for beef.   With access to a cheap, abundant adulterant, the criminals appeared to have an easy job of it.  It was so easy, in fact, that swapping horse for beef appears to have been a long-term business plan for at least one of the meat traders involved in the scandal, Jan Fasen.  Fasen had been convicted and jailed for a similar fraud in 2007.  The name of his company, Draap, is the Dutch word for horse spelt backwards.

In 2019, Fasen and his partner Hendricus Windmeijer were convicted of false labelling by a court in Paris for their role in the supply of 500 tons of meat to ready-to-eat meal-maker Comigel in France in 2012 and 2013.

Complex supply chains

Much of the horsemeat found in the affected products originated in Romania, the by-product of a unique set of circumstances which affected the availability and price of horse meat in that country.  Six years prior to the scandal, a law had been passed banning horse drawn vehicles from the streets of cities and towns in Romania.  Within a few years there was a surplus of unwanted horses, with abandoned animals roaming city streets and parks.  The horses were rounded up and exported to slaughterhouses in neighbouring countries where they were slaughtered for legitimate human and pet food.  By 2007, however, concerns about the spread of equine infectious anaemia, a disease which was endemic in Romania, resulted in a ban on the trading of live Romanian horses.  With live exports stopped, there was nowhere for the horses to go.  Enterprising local businessmen built their own slaughterhouses in Romania and began to export horse meat to Europe.

Draap Trading, a company operated from Belgium and registered in Cyprus, was among those that purchased Romanian horsemeat.  It shipped the meat to the Netherlands where it was re-labelled as beef.  From there it was sold to legitimate meat processors, including one in France who supplied the factory in Luxembourg that manufactured lasagne and spaghetti bolognese for Findus and Aldi.

Separately, a French meat processing company, À la Table de Spanghero was also purchasing horsemeat from Romania and selling it to food manufacturers labelled as beef.  The former director and manager of Spanghero were convicted for their crimes in Paris in April 2019, with the former director being jailed for his role in the saga.

Romania was not the only source, however: the burgers at the centre of the initial discovery in Ireland contained horsemeat that came not from Romania but from Britain, Germany and Poland, via another Dutch trader, Willy Selten.  In 2015 Selten was jailed for 2.5 years for crimes related to the fraudulent supply of horsemeat in 2011 and 2012.  In November 2016 he was ordered to pay €1.2m – the estimated proceeds of his crimes – to the Dutch government.

A long history of horsemeat adulteration?

Given the history of Selten and Fasen, it seems likely that undeclared horse was present in the European food supply for many years, remaining undetected and causing no apparent harm to consumers.  We will never know whether those responsible considered the safety of consumers when planning their crimes.  We do know that unsafe adulterants are more likely to be detected, which makes them less attractive to fraudsters.  Certainly, in the melamine scandal in China, just a few years prior, consumer harm played an important role in the detection of the fraud.  In that case, it is likely that low levels of melamine had been added to milk powder and other products for many months or years without causing any immediate or obvious harm to anyone.  It is thought that the concentration of melamine in baby formula increased in 2007 and 2008 and it was the higher levels that caused kidney problems in babies.  The fraud was uncovered by authorities investigating the illnesses.  Perhaps the extra melamine had been added by mistake, or perhaps the fraudsters got greedy.  Either way, the adulteration was costly for the criminals as well as their victims: two of the people responsible were executed by firing squad in China in 2009.

During the horsemeat fiasco, and to the relief of the entire industry, no person was sickened or injured by the presence of horse in ‘beef’ products.  There was, however, a major health scare: horsemeat can contain veterinary drugs, including phenylbutazone – “bute”, which can be harmful to human health.  It was a lucky coincidence that the overwhelming majority of the contaminated products proved not to contain phenylbutazone.

From horse and beef to chicken, donkey and buffalo

As investigators worked behind the scenes, public events in the European food industry took on the appearance of collapsing dominoes: first was the withdrawal of 10 million burgers by Tesco, Lidl, Aldi, Dunnes Stores and Iceland in United Kingdom.  Tesco lost £300m in market value overnight.  In the following weeks, Asda also removed tens of thousands of products from its shelves; Tesco and Aldi extended their withdrawal from burgers to ready meals; Waitrose withdrew meatballs because of fears they might contain pork; slaughterhouses in Yorkshire and Wales were raided by regulatory authorities; the scandal spread to France and multiple arrests were made on both sides of the English Channel.

By the end of March 2013, authorities had found horse labelled as beef in three Polish factories; equine DNA had been found in chicken nuggets in Greece; water buffalo and donkey had been found in South African burgers and more big brands, including Ikea, Birdseye and Nestle had been affected with their products withdrawn from markets in Cyprus, Belgium, Spain and Czech Republic.

By year’s end, Tesco’s annual profits had fallen by 52%.  Consumer trust in large food manufacturers and retailers was at an all-time low: British consumer organisation ‘Which?’ reported that sixty percent of consumers had changed their shopping habits because of the scandal.

Standards updated

The British government commissioned Professor Chris Elliott to review and report on the implications of the horsemeat contamination for the British food industry.  The Elliott review, as it became known, resulted in the creation of a special food fraud crime unit in that country and the development of a range of other collaborative enterprises across Europe including special functions within the European Joint Research Council (JRC) and food-focussed operations by Interpol known as Operation Opson, now in its sixth year.

The food safety community, initially shocked and alarmed at the potential safety implications of the adulteration soon began a period of discussion and introspection, which often centred around the unspoken question ‘What if the meat had been dangerous?’.  The scandal broke at a time when the GFSI food safety standards were consolidating their revered positions at the pinnacle of ‘best practice’ manufacturing: the standards were being strengthened, lengthened and broadened.  Audit durations were increasing, auditor qualifications and certification systems had become more stringent and standards for packaging, storage and distribution had been upgraded.  And yet these GFSI-endorsed food safety management systems, considered to be the gold-standard for food manufacturing and administered with the strictest oversight, had revealed an Achilles heel the size of Bucharest.   The GFSI promptly created the ‘Food Fraud Think Tank’ to address the gaps and suggest solutions.  This resulted in changes to GFSI’s guidance for food safety standards, with GFSI-endorsed standards being updated to reflect the updated guidance.  The new guidance requires food businesses to formally address the risks from fraudulently adulterated ingredients when they design their food safety management systems.

The food safety landscape had changed, seemingly overnight, from one that was focussed almost exclusively on unintentional or natural contamination to one that requires food manufacturers to consider, control and prevent more unpredictable and sinister events.

In the wake of these changes, a new discipline of food study has appeared.  It is now possible to study food fraud at prestigious educational institutions, attend international conferences devoted to the topic and tune in to webinars conducted by specialists in compliance, legislation and testing.  Analytical chemistry researchers are developing ever-more sophisticated test methods for detecting adulterants.  Food businesses large and small are developing better systems to prevent, deter and detect economically motivated adulteration within their supply chains.

Food manufacturers are slowly regaining the trust of consumers, helped by the visible presence of enforcement operations and government initiatives such as the United Kingdom’s Food Crime Unit and Interpol’s Operation Opson in Europe as well as the Food Safety Modernisation Act (FSMA) in the United States.

And what of the adulterated beef?  We can only guess at how many tonnes of it was eaten by unsuspecting consumers in countries all over Europe before the scandal broke.  Contaminated product that was withdrawn from the market – tens of millions of units – was destroyed; either buried in landfill or used as animal feed.  It seems a sad and wasteful journey for the unwanted horses of Romania; a journey conceived by men who wanted to be rich and one that ultimately changed the face of food manufacturing forever.