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Fake (Counterfeit) Health Supplements

Two US supplement companies share their food fraud stories

Photo by Mika Baumeister on Unsplash

Supplements are supposed to be good for you, but two major brands in the USA have recently gone public over their challenges with counterfeits… and the counterfeits are not at all healthy.

Some of the counterfeit products contained plain rice flour instead of the labelled active ingredients. Some contained undeclared allergens like gluten and soy. One even contained traces of a scheduled pharmaceutical.

The brands NOW Foods and Fungi Perfecti recently went public about their discoveries of unauthorised copies (‘counterfeits’) of their products on Amazon, the online store platform. A third leading brand is said to also be affected.

The NOW Foods counterfeits were discovered after the brand owner received information from loyal consumers who noticed problems with products they had bought online and realised their purchases were not genuine.

One consumer reported that the product did not have the correct smell, colour or capsule size. The company has released images to educate consumers about how to identify genuine and fake versions of their products. Their vice president of global sales and marketing says the brand has experienced significant problems with counterfeits internationally for “years” and says the company is “looking into” anti-fraud measures.

Amazon reported that the fake NOW Foods products had originated in Kenya and contacted consumers who had purchased the product, telling them to throw it away and issuing refunds. Together, the brand owner, Amazon and the Department of Homeland Security plan to pursue and prosecute the supplier.

NOW Foods explains how to spot a fake on their website.

NOW Foods explains how to spot a fake on their website

 

The Fungi Perfecti counterfeits were discovered by the brand owner, which continuously monitors its sales channels to protect its brand. During recent monitoring, the company discovered packages with “irregularities” in one Amazon store and went on to find 23 separate Amazon storefronts all selling counterfeit versions of its products.

Adulterants and allergens

One counterfeited NOW Foods product was labelled as a herbal supplement but turned out to be simply capsules of plain rice flour.

When Fungi Perfecti tested their ‘fake’ products they were alarmed to learn that they all contained the allergens gluten and soy, while the genuine products do not.

Amazon has notified the Fungi Perfecti (fakes) purchasers and removed the products from their site. The brand owner has published the names of the storefronts that were selling counterfeit versions of their products and issued an allergen warning on their website.

Like NOW Foods, they also published images and descriptions showing consumers how to identify counterfeits, as well as a list of authorised sellers of their genuine products.

Amazon reportedly removed 6 million counterfeit items from its online sales platform in 2022, including food, fashion and electronics.

Sources:

https://www.newhope.com/news/now-foods-fungi-perfecti-still-investigating-counterfeit-products-sold-amazon

https://hostdefense.com/blogs/press-releases/fungi-perfecti-makers-of-host-defense-mushrooms-discovers-counterfeit-products-with-known-allergens-being-sold-on-amazon

This story was originally published in The Rotten Apple, a weekly newsletter for food professionals, policy-makers and purveyors. Subscribe for free for weekly insights, latest news and emerging trends in food safety, food authenticity and sustainable supply chains.

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Food fraud hot list

The products below are those that appear to be most commonly affected by food fraud, which includes economically motivated adulteration, substitution and dilution.

A high quality vulnerability assessment includes an in-depth investigation into the incidences of food fraud that have occurred for the particular raw material or ingredient type, so using the list below is just a ‘quick and dirty’ option.  Click here for information about how to investigate previous occurrences using food fraud and food crime databases.

Food Fraud Hot List

  • herbs and spices
  • olive oil
  • organic foods
  • honey and maple syrup
  • seafood
  • milk
  • coffee and tea
  • wine and spirits
  • some fruit juices
assortment of herbs and spices
assortment of herbs and spices

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Food Safety Standards Compared (2023)

 

food vulnerability assessment

There are many different food safety management system standards (FSMS), and they all have different requirements.  So how do you know which standard is the best one for your food company?

When it comes to food fraud, the food safety standards have minor differences in their 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.  Some explicitly require training in food fraud awareness, while others do not.

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 protect the retailers’ brands as well as keep 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 practices for 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 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 (EMA) 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, 2023. 

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 activitiesIngredients (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)YesYesRisk assessmentYesImplied (Edition 9)
Mitigation plan required?

 

 

–Mitigation activities are to be included in the vulnerability assessmentYesYesYesYes
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?––Implied (“method shall be defined”)–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––YesYes
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

BRCGS Food Safety, Issue 9

FSSC 22000, Version 6 (NEW!)

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

IFS Food, Version 8 (NEW!)

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 first days of food fraud requirements in food safety standards… and we’ve been helping businesses since day one.

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. 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. 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. 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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Honey Fraud – Much Worse Than We Thought?

From the desk of Karen Constable, principal consultant at Food Fraud Advisors.

My daughter loves honey and eats a lot of it. She spent a few months in Europe last year – mostly in Spain –  and told me the honey there had no flavour.  She said it tasted like sugar water.

‘Honey’ that doesn’t taste like honey may have been diluted with water and adulterated with non-bee sugar syrups: food fraud.  Honey is one of the most fraud-affected foods on the planet, so perhaps it shouldn’t be surprising to hear that “honey in Europe just doesn’t taste like honey”.

But I was surprised. Europe takes its honey seriously.  And it takes food fraud seriously, too.  I wouldn’t have been surprised to hear about flavourless probable-fraud-affected ‘honey’ in other parts of the world, but I was surprised to hear my daughter say it was “everywhere” in Europe.

Listen to this post on YouTube by clicking the preview below.

 

The last time I saw Europe-wide honey fraud results they were quite good.  For example, a honey-checking operation that was part of the famous Europol/Interpol anti-food-fraud activity, Operation Opson X, in 2021, found that of the  495 honey samples tested, 93% were compliant.  Separately, a European honey fraud survey in 2015 – 2017 reported only 14% ‘suspicious’ samples.Seven percent, fourteen percent, as non-compliance rates, they are hardly fantastic but they don’t match my daughter’s claim that all the honey she tasted in Europe was affected.

But new results have just been published for a multi-year European anti-honey-fraud operation and they are pretty bad.  Of the 320 samples tested in the operation, almost half were suspected of being non-compliant with the provisions of the European honey standard (the Honey Directive).

What is going on here? Why are these results so much worse than past surveys?

Firstly the samples that were tested do not represent the European-wide honey market.  The sampling focussed only on imported honey and only on adulteration with sugar syrups.

Secondly, the methods used in this most recent round of testing are almost certainly different from previous European surveys.  The test methods are only suitable to identify “suspicions of fraud” by looking for chemical markers of extraneous sugars (presence/absence only) and they are different from the officially-approved honey test methods.

The European Joint Research Council (JRC) says these methods are “the most sophisticated methods” currently available but they have not been validated and they are not part of the regulatory framework.

For this enforcement activity, the analytical results were used only as a tool to decide whether further investigations were needed to uncover fraud in the honey supply chain.  Further investigations included on-site inspections, examination of documents, computers and phone records.

Investigators reported that fraudsters appear to be deliberately adjusting the levels of adulterants so that they can evade border control checks.  The European Union’s Food Safety Commission says that officially-approved honey authenticity test methods are not keeping up with the fraudsters, claiming that analytical methods used for border control checks “lack sufficient sensitivity to detect low and intermediate levels of sugar adulterations”.

Something is just not right with honey in Europe

The investigations began more than eighteen months ago, but it appears likely that there are still high levels of fraud-affected honeys in the European market now. More than sixty percent of importers were found to have imported at least one suspicious consignment.

In fact, the European Food Safety Commission, last week reported that “there is a strong suspicion that a large part of the honey imported from non-EU countries and found suspicious by the JRC of being adulterated remains present and undetected on the EU market” (source).

Takeaways

Honey fraud is difficult to detect and expensive for government agencies to investigate.  Fraud perpetrators have been shown to use sophisticated systems to evade detection, and these investigations appear to show that importers and exporters are working together to defraud customers and governments.

If your business purchases honey, food fraud mitigation activities must go beyond checking documents or relying on letters of guarantee.

As a consumer, it is impossible to tell whether honey is fraud-affected or not, but if you suspect honey of being fraudulent, contact the brand owner as a first step and share your concerns.

…. Or you could seek out incense honey, a premium mono-floral honey from the incense flower in Portugal, for which all samples in a recent analytical test were found to be authentic 😊.

🍏 Source: https://food.ec.europa.eu/safety/eu-agri-food-fraud-network/eu-coordinated-actions/honey-2021-2022_en 🍏

 

*** This post originally appeared in Issue #81 of The Rotten Apple Newsletter.  Subscribe to The Rotten Apple to get unique, helpful food safety and food fraud information direct to your inbox every Monday  ***

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5 Food Fraud Trends to Look Out For in 2023

Our Principal Karen Constable has been following food fraud news since 2015.  Every week she personally reads, watches and listens to hundreds of articles, posts and journals about food fraud.

Here’s what she is predicting for food fraud for 2023:

  1. Organic fraud in USA – (a little) less likely
  2. Waste disposal fraud
  3. Document fraud as a new area of concern
  4. Sustainability claims ‘fraud’ – more likely
  5. Authenticity testing – improving

1) Organic fraud

Awareness of organic fraud has been increasing rapidly everywhere in the world. In the USA, that increased awareness has been accompanied by growing recognition of problems with the National Organic Program (NOP). These problems are related to enforcement and coverage.  The NOP includes standards that define what can and cannot be labelled as ‘organic’, and it requires that products meet certain requirements in order to carry the USDA Organic seal.

There were a number of multi-year, very high volume frauds in the organic grain sector in the USA that have been discovered and prosecuted in recent years, including one perpetrated with corn grown in the mid-West and fraud in imported ‘organic’ soybeans. With some of those large operations exposed, the amount of fraudulent ‘organic’ bulk commodities should be reduced in the USA. The prosecutions may act as a deterrent to other would-be perpetrators.

The NOP rules have been strengthened so that they will apply to imported commodities and importing companies like brokers and traders.  They also require that the organic status of bulk food in non-retail containers is correctly identified with respect to its organic status. There have also been updates related to the qualifications of organic inspectors and the rigour of on-site inspections.

Although the new rules are at least one year away, the market for organic commodities has been ‘put on notice’ and this should reduce the amount of organic food fraud in the USA.

organic produce pesticide authentic fruit vegetable

2) Waste disposal fraud

Waste disposal fraud has (probably) been happening for decades, but we are becoming more aware of the risks.  Waste fraud takes many forms but a typical scenario is one in which a food company contracts a waste company to securely destroy and dispose of goods that do not meet quality or safety parameters so that they cannot be diverted back to consumers.  However when fraud occurs, the waste company sells the sub-standard food, or otherwise allows it to return to consumers.

In one recent example, damaged jars of food were diverted back to the legitimate marketplace by the company that had promised to destroy them (and issued a disposal certificate to the brand owner).

This type of fraud is not new, but awareness of potential fraud in the waste supply chain has increased.  At the same time, food companies’ supplier approvals programs are more likely to include waste contractors than previously.  This means that there could be less waste disposal fraud than before (hopefully!)

 

3) Food safety document fraud (a bigger worry than we first thought?)

Document fraud is nothing new. It is a key element in many types of food fraud.  Falsified laboratory reports, fake organic certificates and even fake disposal declarations are all examples of document fraud.

In the context of food fraud, document fraud is most likely to support a profitable fraud, such as passing off conventional soybeans as ‘organic’ so they can be sold for a much higher price.

In ‘normal’ food frauds, then, the document fraud is just part of the package, and the documents do not directly make the food vulnerable.

There is one class of food, however, that has a special – and perhaps easily missed – food fraud vulnerability.  These are foods that are not usually thought of as ‘high risk’ for food fraud, but that rely on authentic/true documents for critical food safety criteria.

An example is ready-to-eat cold, cooked chicken purchased by a sandwich manufacturer.  A faked expiry date or falsified microbiological result on the certificate of analysis would place the sandwich company and its consumers at risk of serious consequences.  Because the faked, forged or falsified documents in that scenario provide subtle economic advantages to the supplier, this type of scenario could be considered food fraud.

Such vulnerabilities could easily slip through the net of traditional food fraud assessments. For suppliers whose economic circumstances are getting tougher, the motivation to perpetrate ‘minor’ document frauds like falsifying microbiological tests could be getting stronger, potentially increasing the likelihood of such frauds occurring.

 

4) Problematic sustainability claims

Claims about the sustainability credentials of foods are on the rise, as consumers increasingly value such claims.  Unfortunately, many green claims made about consumer goods have the potential to be misleading.

A United Kingdom government survey found 40 percent of such claims were problematic because of either non-accredited, own-brand logos; non-disclosure of environmentally harmful practices or ingredients; vague language; or lack of evidence to support claims such as ‘eco’, ‘sustainable’ and ‘natural’.

Vague claims and own-brand logos do not necessarily constitute food fraud, however food businesses need to be careful about the integrity of the data they use to support claims they intend to make about their products or operations.

Claims about carbon neutrality, carbon net-zero and greenhouse gas emissions reductions need to be evidenced using data from the whole supply chain.  This is where food companies can be vulnerable.

If a food company’s supplier provides incorrect data related to the carbon footprint of the material or service being purchased, the outcome of any emissions calculations done by the purchasing company will be incorrect.  The result?  The food company could be guilty of accidentally misrepresenting its sustainability status.

Other fraud pitfalls for food companies include fraudulent certification schemes and logos used by their suppliers, and errors in interpreting or complying with the varying green claim regulations in different markets.

Read more about the risks that come with carbon-neutral claims in Issue 61 of Karen’s newsletter The Rotten Apple and about consumers’ confusion with sustainable seafood claims in Issue 63.

 

5) Authenticity testing – more accessible, better expertise

Laboratories continue to improve their authenticity testing services to support medium-sized food businesses with food fraud detection. The level of food fraud knowledge and expertise in the food testing industry is getting better and more tests are becoming available.

The Food Authenticity Network’s (FAN) Centres of Expertise Program is making valuable contributions to the expertise and accessibility of food fraud tests.  A FAN centre of expertise is a laboratory or academic institution with expertise in one or more types of authenticity tests.

 

This article originally appeared in The Rotten Apple newsletter on 20th February 2023.