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6th September 2022 by Karen Constable

Food Fraud in Food Additives

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

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

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

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

Fraud in food colourings

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

 

Image: Pawel Czerwinski on Unsplash

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Filed Under: Food Fraud

5th September 2022 by foodfraudadvisors

Important Announcement About the Food Fraud Risk Information Database on Trello

On 1st September 2022, there was a major change to Food Fraud Advisors’ Food Fraud Risk Information Database on Trello.

Changes to the Database

After five years of providing free, 100% open-access food fraud information to the international food community, in August 2022 we made the difficult decision to change the content we publish on the Trello board.

From 1st September 2022, users of the Trello board will see a major change.  The database will continue to be updated with information for individual foods/ingredients, but we will no longer be providing (close-to) real-time food fraud incident news.   This means that separate cards for each individual food or raw material will continue to be updated when new risks or new emerging food fraud trends become known, but lists of incidents of food fraud will no longer be published on the board.  The “Recent Incidents” columns have been discontinued and the final column was August 2022.

 

Changes to the Food Fraud Trello Board

 

What to do Now

Keep using the Trello board to research food fraud risks for foods, ingredients and materials.  Click on the cards for individual food types to see the risks.

For recent food fraud incidents, find a new source of up-to-date information:
1. Sign up to a paid food fraud/food safety alert service like FoodChainID’s HorizonScan; or
2. Perform your own searches online; or
3. Sign up for a free service (the JRC Food Fraud Monthly Reports are good);
4. Or, to retain access to our expertise in food fraud incident reporting, you can subscribe to Karen Constable’s newsletter, 🍏 The Rotten Apple 🍏.  It’s full of awesome food safety and supply chain news, and (for paying subscribers), food fraud incident reports, just like the ones that were previously published on the Trello board.

Food fraud incident reports will also be appended to the downloadable offline ‘snapshots’ of the database, which you can purchase from our website for US197.  We publish a new downloadable ‘snapshot’ six times per year.

Summary

❌ Recent Incidents Columns (Lists) have been discontinued

✅  Individual cards continue to be updated with information about food/ingredients/materials when new information becomes available

✅  Get recent food fraud incidents from 🍏 The Rotten Apple 🍏 newsletter, or by purchasing a downloadable, offline snapshot of the database, or by signing up for an alternative source of food fraud information, such as HorizonScan.

If you’ve got any questions, contact us.

 

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Filed Under: Food Fraud

11th August 2022 by Karen Constable

Food Safety Standards Compared (2022)

 

food vulnerability assessment

 

When it comes to food fraud, each food safety standard has slightly different food fraud requirements. For example, some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t; some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on finished products.

Confused? We are here to help.  Read on to find out which standards have what requirements, and get recommendations for creating a great food fraud prevention (VACCP) program.

Background

Food safety standards are standards that describe requirements for food and related businesses.  The requirements aim to ensure that food and food-related goods are safe for consumers and customers.  The correct term for such standards is food safety management systems standards (FSMS).

There are food safety standards for all types of operations within the food supply chain, including:

  • growing and packing fresh produce;
  • manufacture of food and food ingredients;
  • buying and selling food (“brokers”);
  • storage and transport of food;
  • manufacture or converting of packaging materials;
  • manufacture of animal feed or pet food;
  • services such as cleaning, laundry, or pest control for food businesses.

The over-arching aim of all food safety standards is to keep consumers safe, but most standards also have secondary aims. Some of the most popular food safety standards were developed by food retailing groups, and these standards were written to protecting the retailers’ brands as well as keeping consumers safe. Other standards were developed to help food businesses understand best practices and gain a way to demonstrate their excellence through independent certifications.  Some standards include quality parameters, while others only address food safety issues.

There are dozens of internationally accepted food safety management system standards, each with slightly different requirements.  This can make it difficult to know which standards are ‘better’ or more suitable for your food company.

To solve this problem, a standard for food safety standards was created by the GFSI (Global Food Safety Initiative).  The GFSI assesses and approves food safety standards using a process called benchmarking. The aim of GFSI benchmarking is to define best practice in food safety standards and provide a way to compare and align different food safety standards.

Among the dozens of food safety standards, some are benchmarked by the GFSI (Global Food Safety Initiative), while others are not.  Benchmarked standards usually have more requirements and more rigorous expectations than non-benchmarked standards.  The auditing and certification processes for benchmarked standards are typically more time-consuming and often more expensive than for non-benchmarked standards.

Food Fraud in Food Safety Standards

Food fraud prevention activities are an important part of all food safety management systems because food fraud can pose a risk to food safety.  Some food safety standards have separate, stand alone requirements for food fraud prevention activities, while others do not.  Standards that are GFSI-benchmarked all include explicit, separate food-fraud-related requirements. Other standards rely on the hazard analysis elements of the food safety system to identify and control hazards from food fraud.

The GFSI requires all benchmarked standards to require food companies to do a vulnerability assessment for food fraud and create a mitigation plan for food fraud prevention.  Most GFSI-benchmarked standards also include details about which materials should be assessed and which types of food fraud need to be managed.

Non-GFSI standards vary in how they require a food company to approach food fraud.  Some specify or recommend a VACCP program, which is based on food fraud vulnerability assessment activities. Others, like AIB, require that food fraud risks be considered in the supplier approvals processes.  The regulations of the USA Food Safety Modernization Act (FSMA) require that food businesses identify hazards from economically motivated adulteration type food fraud and implement preventive controls to minimise the risks.

Among the most well-known standards there are some notable differences. For example, the SQF Food Safety Code requires food businesses to assess and manage risks from counterfeit-type food fraud, while the BRC Food Safety Standard only requires businesses to assess the risks from adulteration or substitution activities. BRC requires horizon scanning activities, while the SQF and IFS standards explicitly mention food fraud training.

Below you will find a table that compares the current food fraud requirements of each of the major food safety standards.

Table 1.  Food fraud requirements of major food safety standards, 2022. 

Click here to open or download a pdf version of this table

  AIB* BRC* FSSC* GlobalGAP* IFS* SQF*
Food types to include in food fraud prevention activities Ingredients (implied)

 

 

Raw materials

 

 

Products and processes

 

 

Unclear

 

 

Raw materials,

ingredients,

packaging,

outsourced processes

Raw materials,

Ingredients,

finished products

 

Food fraud types

 

 

 

Economically motivated adulteration (only)

 

 

Adulteration,

substitution

(only)

 

 

Any type where consumer health is at risk (in definition, Appendix A)

 

Unclear, however counterfeit or non-foodgrade packaging or propagation materials are included as examples

 

Substitution, mislabelling, adulteration, counterfeiting

 

 

Substitution, mislabelling, dilution, counterfeiting

 

 

Vulnerability assessments explicitly required? Risk assessment (implied, Appendix A) Yes Yes Risk assessment Yes Implied (Edition 9)
Mitigation plan required?

 

 

– Mitigation activities are to be included in the vulnerability assessment Yes Yes Yes Yes
Does packaging need to be included in the vulnerability assessment? Yes

(implied)

 

Yes

(see 3.5.1.1)

 

Yes

(as per food fraud definition, Appendix A)

Yes

 

 

Yes

 

 

Implied

(primary packaging is a ‘raw material’)

Is a separate food fraud procedure explicitly required? – – Yes – Implied

(“responsibilities shall be defined”)

Implied

(“methods and responsibilities shall be documented”)

Is training in food fraud explicitly mentioned? – Implied

(Clause 5.4.1)

– – Yes

(Clause 3.3.4)

Yes
Is an annual review explicitly required? – Yes – – Yes Yes
Other

 

 

– Horizon scanning for developing threats must be done (Clause 5.4.1) – – Criteria for vulnerability assessments must be defined

(4.20.2)

Food safety risks from food fraud must be specified (2.7.2.2)

*  The full names of the standards are as follows:

AIB International Consolidated Standards for Inspection of Prerequisite and Food Safety Programs, 2023 (NEW!)

BRCGS Food Safety, Issue 9 (NEW!)

FSSC 22000, Version 5.1

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

IFS Food, Version 7

SQF Food Safety Code, Edition 9

Takeaways

Among the major food safety management system standards, there are small but significant differences between food fraud prevention requirements.  Key differences include whether finished products or ingredients are to be assessed, which types of food fraud must be included and the presence/absence of requirements related to horizon scanning and training.

If that all seems confusing, don’t despair…

Recommendations for a robust and compliant food fraud prevention program (VACCP)

At Food Fraud Advisors we have been working at the intersection of food fraud and food safety since the very beginning!  Creating a robust and compliant food fraud program can take time and effort but it isn’t complicated.  Follow the steps below to get started:

  1. Carefully read the food fraud clauses of the standard you are/will be certified to.
  2. Pay attention to the food types and the food fraud types that are mentioned in your standard. HINT: you may need to check the definitions or glossary.
  3. Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
  4. Whether or not it is explicitly required in your standard, we recommend you create a food fraud prevention procedure that defines the methods, responsibilities and criteria for food fraud prevention.
  5. You should also conduct training for all relevant staff and ensure that the food fraud system is reviewed at least annually.

Get a complete guide to the food fraud requirements of all the major food safety standards from us, the food fraud experts, here.

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Filed Under: Consultancy, Food Fraud, Learn, Vulnerability Assessments Tagged With: 2.5.4, 2.7.2, 4.20, 5.4.1, 5.4.2, AF16.1, AF16.2, audit, BRC, BRC Issue 9, economically motivated adulteration, food fraud consultant, food safety standard, GFSI, HACCP, SQF Edition 9

26th June 2022 by foodfraudadvisors

Investigating Susceptibility to Food Fraud

Updated 26th June 2022

Some foods are more susceptible than others to economically motivated adulteration, substitution and dilution.  Understanding the susceptibility of an ingredient or raw material type is an important part of every food fraud vulnerability assessment process.

A TWO PART PROCESS

Susceptibility is investigated in two parts.

(1) General Susceptibility (is this type of food often affected by food fraud or not?)

You can estimate a foods general susceptibility using publicly available information.

(2) Specific Susceptibility (is the food we purchase likely to be affected by food fraud?)

The specific food fraud attributes depend on your supply chain, management of the supply chain and testing and auditing activities.

STEP 1. GENERAL SUSCEPTIBILITY

To investigate the general susceptibility of a food or ingredient to food fraud, use publicly available information about incidences of fraud that have occurred in the past and that might occur in the future.

There are a few different ways to access information about previous incidences and emerging issues with a raw material type, as shown below.

1. Online databases – access to historical data:

A food fraud database provides a way to access historical information about food fraud.

A food fraud database is a collection of information about food fraud incidents and food fraud risks. There are a number of free and paid databases operated by governments, not-for-profits and private companies available worldwide.  The type of data varies from database to database, as does the cost and the features.  For a current list of food fraud databases, check out our post Food Fraud Databases Compared.

2. Email alerts via subscription service:

Email services provide near-to-real-time information about food fraud incidents as they occur. This can be a good way to keep on top of developing food fraud risks.   Below is a list of email subscriptions that can provide information about food fraud.

  • Food Forensics, a laboratory located in United Kingdom, offer a monthly horizon scanning risk newsletter to members.
  • FoodChainID Horizon Scan is a paid subscription service that provides alerts on adulteration and fraud, as well as food safety contamination events.
  • Some trade associations provide email services to members.
  • The Rotten Apple, by Karen Constable (of Food Fraud Advisors), is a weekly newsletter that includes trends and analysis as well as a summary of updates made to the Trello Food Fraud database each week.
  • Government-run food safety and food regulatory bodies in some jurisdictions send emails to interested parties.  Contact your local authority for more information.

3.  Direct intelligence:

Direct intelligence is another means of gathering information about the occurrence of food fraud for a given food or ingredient.

  • Information can be obtained by asking law enforcement officials and government departments.
  • Suppliers can provide information about their material types.
  • Trade associations can be approached for information on food fraud and emerging issues.
  • Conferences and webinars about food fraud and food defence are held regularly and these can be a good source of information.

STEP 2. SPECIFIC SUSCEPTIBILITY

In step one you considered the general likelihood of food fraud occurring for the food or ingredient you are assessing.

In step two you must consider the characteristics of your specific material as it is purchased by your food business.

Characteristics that should be considered include those associated with your supply chain, purchasing policies and the format of the material, for example whether it is a powder or liquid or solid.

Each characteristic should be considered with regards to how it could affect the degree to which a person may be motivated to fraudulently adulterate the material and how it could allow a person to:

a) gain access to the material,

b) commit fraud by adulterating, substituting or diluting the material or

c) avoid detection.

To ensure that all relevant characteristics are considered it is best to use a checklist

Checklists help to ensure that all relevant information has been considered.

You can create your own checklist or use a checklist prepared by experts such as those found in a proprietary Vulnerability Assessment Tool.

There are a number of fraud assessment tools available on-line, with differing degrees of usefulness (some are really annoying to use!).  The most comprehensive checklist for food fraud vulnerability assessments can be found in Food Fraud Advisors’ Vulnerability Assessment Tools.

Need more help?  Get easy-to-use, comprehensive downloadable templates in our online training course.

Visit our training academy today

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Filed Under: Food Fraud, Learn, Vulnerability Assessments Tagged With: likelihood, VACCP

8th June 2022 by foodfraudadvisors

Top 5 Food Frauds of 2022 (so far)

Food Fraud Advisors’ Principal, Karen Constable, shares her top five food frauds for 2022.

At the time of writing, we’re almost halfway through 2022.  This year we have discovered some interesting frauds, and unfortunately also plenty of food frauds that occur over and over. Due to the criminal nature of food fraud, each of the examples shared here represents just a tiny proportion of the food fraud that is being perpetrated on a daily basis across the globe.

The incidents and fraud types in this list have been chosen because they pose food safety risks to consumers or are likely to be affecting large numbers of products.

Traditional Guatemalan candies on street stall during Lent in Antigua, Guatemala

 

  1. Counterfeit Wonka chocolate bars in the United Kingdom

Counterfeiting is a type of food fraud where a well-known brand of food or drink is produced by an unauthorised manufacturer and passed off as the real thing.  In the case of Wonka bars, the brand owner is Nestle.

A man was caught in March 2022 for supplying counterfeit Wonka bars to retail outlets in the United Kingdom.

To make the counterfeit chocolate bars, the fraudster would have had to use heavy industrial food manufacturing machinery, which is expensive, and order custom-printed packaging, which is also expensive and can usually only be purchased in large quantities.  That’s a significant financial investment.

Because of the high costs to manufacture the fake products, we can infer that the fraudster must have expected to make significant profits.  We know that the risk of getting caught did not deter him because he was prosecuted for doing the same thing in 2016.  In April 2022 he pleaded guilty to doing it again.

One source says that Nestle, the legitimate brand-owner, no longer makes Wonka bars.  However, at least three online candy stores in my home country (Australia) are selling them today, which makes me think that there are counterfeit Wonka bars in many countries.  This could be quite a big operation.

The British authorities said that some of the counterfeit bars found in the United Kingdom contained undeclared hazelnuts, which makes them seriously dangerous to allergic consumers.

  1. Secret tank in milk tanker fraud in Italy

This fraud is unusual.  Or perhaps it happens a lot but is rarely exposed.

In this fraud, a truck used for transporting milk had been modified so that the milk could be diluted with water just prior to unloading.  This allowed for milk to pass quality tests, and then to be diluted after passing the tests but before being pumped into the purchasers holding tanks.

Like the counterfeit chocolate bars, this type of fraud requires significant financial investment; it is expensive to make major modifications to stainless steel tanks.  Only two shipments of milk were confirmed to have been affected, but it is likely that the fraud was intended to be done on a much larger scale.

This fraud poses risks to food safety because the water used to dilute the milk could be contaminated, and the tanker might not be able to be properly cleaned because of the extra hardware inside the holding tanks.

Listen to the whole (fascinating) story of how the fraud was discovered here:

  1. Seafood smuggling

Seafood smuggling is a ubiquitous food fraud.  It happens a large scale, all the time.  It is happening now, in 2022.

Seafood smuggling results in traceability problems that go right through the supply chain.  It’s estimated that at least 10% of seafood in any retail outlet has been affected by food fraud at some point between harvest and store.

Governments lose money from seafood smuggling because taxes, tariffs and duties are avoided when seafood is smuggled.

Smuggled seafood is significantly more likely to have originated in illegal catch areas, or caught in excess of fishing quotas, so it puts a strain on the environment as well as having an economic cost.  Smuggled seafood can also be affected by species fraud, where the fish is mislabelled.

When frozen seafood is smuggled it may also be affected by expiry date fraud too.  Expiry date fraud is when old frozen seafood is relabelled so it looks ‘younger’ than it actually is.

A large seafood smuggling ring was discovered by authorities in China in February of 2022, and this is probably the tip of the iceberg when it comes to seafood smuggling.

Seafood fraud is more common than you might think

 

  1. Organic fraud with grains and cereals from Eastern Europe

False claims about the organic (or ‘bio’) status of grains and cereals is a type of food fraud we call misrepresentation.  Organic fraud in bulk commodities is probably happening frequently in 2022, exacerbated by supply chain issues from the Ukraine war.

With this type of fraud, the grains or cereals are conventionally-grown, but their documentation is forged to make it look like they are organic.

Example: a shipment of oats was seized by authorities in Italy in January 2022 because they were alleged to have been falsely labelled as organic.

  1. Country of origin fraud

This type of fraud occurs commonly and affects packaged retail products across many food product categories.

In Europe in 2022, there have been quite a few incidences of country-of-origin fraud and protected designated origin (PDO) fraud, including:

  • A market operator in Italy was accused of country-of-origin fraud in relation to dried fish, legumes and spices which were claimed to be from Africa and Japan but which were instead from countries deemed ‘at risk’, meaning they require official clearances before being sold.
  • Products including fresh fruit, vegetables, mushrooms and honey in France displayed rates of up to 30% “anomalies” in the way the origin of the food was declared.  The survey focussed on food from outside of France being incorrectly declared as being French.
  • Significant quantities of bulk wine and bottled wine was seized by Italian authorities who allege the wine was labelled or was going to be labelled with false claims regarding its geographical provenance.

***

Want the inside scoop on frauds like this?

Become a paying subscriber of The Rotten Apple for weekly food fraud updates.

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Filed Under: Food Fraud

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