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What is a food fraud team? (and what to do if you can’t get one)

A food fraud prevention team is a group of employees in a food business that is responsible for creating, implementing and supervising food fraud prevention activities in the business.

Food fraud teams are ideally made of representatives from various departments of the food business, such as Food Safety, Quality Assurance, Procurement, Production, Marketing, Site Security, Legal, Warehousing and Laboratory.

Members should be trained in food fraud awareness.

Typically, a food fraud prevention team would meet on an as-needed basis as determined by the food fraud team leader or as directed by senior management, with at least one full meeting every 12 months.  Meetings should also be held in the event of a food fraud crisis or if there have been major changes to supply chains or operations.

Attendance and minutes of the meetings should be recorded and filed within the food fraud prevention section of the food safety management system.  Action items from each meeting should be noted in the minutes, and subsequent meetings should address action items from previous minutes.

Agenda items for food fraud team meetings

  • Action items from the previous meeting – status of actions.
  • Discussion/report on new products in development and/or launched since the last regular meeting, with respect to food fraud vulnerabilities.
  • Discussion/report on changes to raw materials, suppliers.
  • Discussion/report on new raw materials, new suppliers and contract manufacturers.
  • Review of current food fraud procedures – do they represent current best practice, are they being followed?
  • Discussion/report on any food fraud incidents or new risks emerging in relevant supply chains.
  • Review of the composition of the food fraud team; any changes needed?
  • Discussion/report on changes or upcoming amendments to certification requirements or customer standards.
  • Review of audit results (internal, external and customer audits), with respect to food fraud elements.  Improvement suggestions and/or status of corrective actions.
  • Review of mitigation plans and/or testing results; any new mitigation activities needed, new tests available?
  • Report to senior management re. food fraud vulnerabilities and status of mitigation activities, request for further resources if needed.

What to do if you can’t get a food fraud team

Handling food fraud prevention activities is a tough task – tougher than senior managers may realise. So if your company doesn’t have a food fraud team, it’s important to ask loudly, and often, for cross-disciplinary help with food fraud matters.

Food fraud poses financial and reputation risks to businesses, and a single person should not be expected to understand every vulnerability across the business. The consequences of missing a vulnerability can be severe, and this must be explained to senior managers when requesting resources for a food fraud team.

Even in a very small company, a food fraud team containing a senior manager/owner, food safety representative, purchasing officer and production manager is best practice. The cost of man-hours used by a food fraud team is far lower than the cost of any serious food fraud event.

However, if you are responsible for food fraud prevention and you haven’t succeeded in getting a food fraud team, there are a few things you can do to reduce the risks. Firstly, you can approach members of other departments informally and ask them for their thoughts about specific products, ingredients or processes. You can also engage the services of an external food safety consultant if the budget allows. They can bring a fresh perspective, new knowledge and may even be able to persuade senior management of the importance of forming a team.

Finally, you could borrow the food safety hive mind in a forum or professional group to assist with tasks such as identifying or prioritising vulnerabilities. Try the forums of the International Food Safety and Quality Network (IFSQN) which are free and can be used anonymously, LinkedIn groups or professional food science associations such as IFST (UK), IFT (USA) or AIFST (Australia).

Food Fraud Advisors has food fraud awareness training for your team, and a downloadable template for food fraud team SOPs, agendas, minutes and personnel lists.  Learn more by clicking the icons below.

online training food awareness senior management food fraud teams
Food fraud awareness training is recommended for senior management and food fraud team members by SQF, FSSC, IFS and other food safety standard owners. Our training is cost-effective and convenient. Certificate included.

 

Food fraud teams are an important component of a food safety management system. Our ultra-popular template has everything you need to form a food fraud team for your business.

 

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Food Fraud Databases Compared

Updated 30 April 2025

A food fraud database is a collection of information about food fraud incidents and food fraud risks. There are paid and free databases operated by governments, not-for-profits and private companies.  The type of data varies from database to database, as does the cost and the features.

Pay-To-Use Databases

There are a number of pay-to-use food fraud databases.  The four best-known commercially operated databases are listed below.

(1) HorizonScan (FERA).  This tool was developed by the UK government’s Food and Environment Research Agency (FERA). It includes alert systems and information about food safety, food fraud and suppliers.  In the U.S., it is distributed by FoodChain ID.  https://horizon-scan.fera.co.uk/

(2) FoodChainID Food Fraud Database (formerly the Decernis Food Fraud Database, which was previously the United States Pharmacopoeia (USP) Food Fraud Database).  This database includes scholarly articles on testing and detection methods as well as food fraud incidents.  https://www.foodchainid.com/products/food-fraud-database/

(3) Agroknow’s FoodAkai uses sophisticated computer modelling to analyse data from global food safety agencies to offer insights into hazards in raw materials, ingredients and products.  Like HorizonScan, it includes food safety as well as food fraud issues and incidents.  https://agroknow.com/foodakai/

(4) MerieuxNutriSciences’ Safety HUD monitors official agencies and other sources for alerts on food safety and suspected fraud incidents. Safety Hud 2.0 | Food Compliance Solutions (mxns.com)

Costs

There is a notable lack of transparency in the pricing of food fraud databases.  Fees to access the databases are usually levied on a subscription basis.  The cost varies depending on the number of users and whether you are a consultant, a small food company or a multi-site organisation.

All the databases listed above offer either a free trial or a guided demonstration, so you can compare them to decide which might be best for your company’s needs.

Affiliation

Food Fraud Advisors has no financial relationships with the products or companies listed above, though we do have contacts at each organisation, so if you would like a no-obligation introduction, just ask. We do not earn a commission from such introductions.

Free Databases

(1) Food Fraud Advisors’ Food Fraud Risk Information Database (hosted on Trello) is a free and open-access online database of food fraud incidences and emerging threats, organised by food type.  No log-in required.  https://trello.com/b/aoFO1UEf/food-fraud-risk-information

(2) FoodSHIELD is a US Government-Academic partnership.  Access to the FoodSHIELD food fraud and food defense database is limited to representatives from local, state, and federal governments, the military and laboratories that perform analyses.  https://www.foodshield.org

(3) Food Protection and Defense Institute (USA)’s Food Adulteration Incidents Registry. Access by special request only. https://incidents.foodprotection.io/about

(4) Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.

(5) US FDA’s Recalls and Food Safety Alerts, has a searchable database and includes incidents arising from food fraud.  http://www.fda.gov/Safety/Recalls/

(6) MEDISYS for Food Fraud (MEDISYS-FF) is a food fraud media monitoring system that uses information from the Europe Media Monitor to collect media reports related to food fraud.  The reports can be filtered by country of origin, keyword and date.  You can request access to the system by submitting a form.  https://bigdata-wfsr.wur.nl/2020/09/18/medisys-for-food-fraud/ 

Which Database Should I Use?

How do I know which database will meet my needs?

 

What are your needs? Check the headings below to see which best describes your company’s needs for food fraud information. 

 

Low budget and/or need information infrequently

If you have a low budget and don’t need real-time monitoring, use Food Fraud Advisors’ free Food Fraud Risk Information Database.

Custom alerts for specific ingredients or foods

Custom alerts and real-time monitoring is offered by the four paid databases listed at the top of this post.

Food safety and food fraud alerts

HorizonScan, FoodAkai and FoodSafety HUD all include food safety hazards as well as food fraud hazards in their reporting and alert systems.

Analytical test methods information

FoodChainID’s Food Fraud Database includes test method information and research papers.

Large number of users across multiple sites

If you have a high number of users who want to access the database or a very large number of products, HorizonScan, FoodChainID and FoodAkai have enterprise-level subscriptions so users on different sites can set up their own reports and alerts.

Predictions about future hazards

FoodAkai promises early warning of emerging risks, which are predicted using AI technology. The makers of FoodAkai say their software predicted the multi-country, multi-product ethylene oxide in sesame recall disaster of 2020-2021.

Students, occasional needs, non-food professionals

The Food Fraud Information Database hosted on Trello is a great place to start your food fraud journey if you are a student or new to the food industry.  It is free and contains summaries of the types of food fraud that affect various foods.  However, it is not easily searchable (you can buy a searchable ‘snapshot’ in Excel form) and it does not provide custom alerts.  Incidents added to the database are mostly drawn from international media and are heavily weighted to English language media, so are not suitable for accurate counting or mapping of incidents.

Other free information about European and North American foods

RASFF (Europe) and FDA Recalls and Food Safety Alerts (USA) mostly contain food safety incidents, with few food fraud incidents.  Much of the data derives from cross-border food movements, especially in RASSF.  They are both free and searchable and can be a useful adjunct to the free food fraud database on Trello.

 

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What to do About Food Fraud (USA)

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

What should they do, they asked.

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

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

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

Example: hazelnut oil

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

1. Establish whether food fraud has occurred or not

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

2. Categorise the fraud into one of two types

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

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

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

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

 

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

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

4. Review the evidence

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

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

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

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

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

6. Choose who to tell, and in which order

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

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

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

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

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

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

7. Choose how to progress after initial responses

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

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

8. Inform interested parties

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

9. Follow up

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

10. Further actions

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

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

Want help with a situation like this?

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

Get in touch with me

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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.