Food Fraud Advisors

You are here: Home / Archives for Food Fraud

by

Influence of the COVID pandemic on food fraud

Is food fraud going to increase because of the pandemic?

Karen Constable of Food Fraud Advisors, thinks that it probably will.  Here’s why.

Food fraud is driven by the desire for economic gain.  Always.  That is the definition of food fraud. Someone who tampers with food for other reasons – say by adding poison to scare consumers – is not committing food fraud.  In the food industry we consider tampering for malicious purposes an issue of ‘food defense’ not food fraud.

So, food fraud perpetrators seek economic benefits when they commit fraud, which most commonly manifests as an attempt to receive more money when a food is sold.  As an example, if a seller of ground turmeric adds a small amount of bright yellow lead chromate to a sack of poor quality turmeric, the brighter colour might mean that he receives more money than he would for a sack of pure, low-grade turmeric.  He gains a direct financial benefit when he commits that type of food fraud.

In addition to direct economic gains, there are less direct methods that criminals use to derive financial rewards from food fraud, such as by avoiding taxes and duties, or by acting dishonestly to fulfill customer orders so as not to lose their business.

One such fraud occurred in Canada in 2013 and 2014 when a fresh produce supplier was unable to source locally-grown cucumbers for their customers.  They instead purchased cucumbers from Mexico and relabelled the cartons with ‘Product of Canada’ before dispatch.  The company was later fined $1.5 million by the Canadian Food Inspection Agency and a further $3.2 million by the The Ontario Greenhouse Vegetable Growers association.

In addition to the desire for economic benefits, for fraud to occur there also needs to be opportunity.  Current events in the global food market and in the wider economy are increasing both the desire for economic gains and also the number of opportunities to commit food fraud.

Direct economic pressures on food sellers

In 2020, most parts of the world are facing extreme economic downturns.  The economic situation arising from the pandemic can reasonably be expected to increase criminals’ motivation to commit food fraud for the purpose of increasing profits directly.  In addition, we are already experiencing shortages in supply chains that will result in food suppliers experiencing extra pressure to deliver products to their customers.  As a result, it is reasonable to expect that there may be an increase in frauds committed for the purpose of retaining existing customers, or even gaining new ones, by supplying goods that are not easily available.  Companies may be tempted to take short cuts or turn a blind eye to things that do not appear quite right when they source food and ingredients.

Food manufacturers are under pressure during the pandemic

 

Increased opportunities for criminals

Disruptions in food supply chains caused by the pandemic have provided new food fraud opportunities for criminals.  These new opportunities can be organised into three loose groups; excess products, reduction in oversight and changed buying patterns.

Local oversupply of certain food types

Unusual excesses of supply have affected numerous food types and sectors since the pandemic began.  Examples include an overabundance of keg-beer in Australia, that was not consumed because bars were closed;  a glut of live pigs in the United States after pork processors shut down; excess quantities of milk that had to be dumped by dairy farmers.  In the United Kingdom, suppliers are concerned with an oversupply of expensive cuts of meat that would usually be consumed in restaurants or special family events; consumers are instead buying cheaper cuts to cook at home, leaving the more expensive parts of the animal unpurchased.

Wherever there are unusual patterns of oversupply, there are opportunities for fraud perpetrators to make use of the cheap and readily available excess foods for fraudulent purposes.  One such fraud of this type has occurred in the United Kingdom in recent years, where cheap, abundant beef has been used to replace some or all of the lamb in dishes sold by food service outlets.

Challenges with oversight

The pandemic has, to date, had a massive impact on the ability of governments and private entities to inspect, audit and test food for authenticity and safety.  Lockdown and social isolation rules have prevented audits and inspections, while economic factors have led to cuts in funding and staffing levels in inspection agencies.  In Europe, there have been changes to food, veterinary and phytosanitary inspections.  In the United States a consumer group has claimed that the Department of Agriculture’s new rules for swine fever inspections are inadequate to protect humans.  There have also been reports of problems at ports in Europe that have affected inspection protocols.

Within the food manufacturing sector, businesses are struggling to operate properly due to stay-at-home rules, which have affected staffing levels.  Reductions in on-site staff numbers can hamper a manufacturer’s ability to inspect incoming materials or to properly assess new suppliers for their food fraud and food safety risks.  In the longer term, cost-cutting measures in economically impacted businesses may reduce their ability to perform food authenticity testing, which can be expensive compared to other food tests.  Together, the reduction in personnel resources and authenticity testing leaves manufacturers more vulnerable to inadvertently purchasing and using fraudulent food ingredients.

Purchasing behaviour

The pandemic has resulted in significant changes to purchasing behaviour across the whole food supply chain.  Online retail food purchases have increased sharply in the first half of 2020.  Food sold online has frequently been accused of being less safe and subject to less oversight than food sold in ‘brick and mortar’ stores.  In May 2020, online-sold curry was recalled in Britain after it was found to be adulterated with an illegal dye.  In the same month, consumer group Which reported that it had found banned childrens’ foods for sale on Amazon.

Some food types have experienced a sudden and unexpected jump in demand.  In March 2020, Nestle reported its best sales growth in five years, as more people purchased food to cook and eat at home.  Hersheys reported a doubling of its e-commerce sales for March 2020.  The defence forces in South Africa experienced an unexpected demand for soldiers’ ration packs, which were needed as personnel were deployed to assist with infection control efforts.  That sudden demand might have contributed to a reported incidence of expiry date tampering that affected ration packs for South African soldiers.

There is evidence that the pandemic’s effect on global supply chains has already changed attitudes to importing and exporting food, with local food being favoured by both consumers and governments.  This has been termed ‘food trade nationalism’.  Such nationalism might provide more incentive for criminals to fraudulently mis-represent imported produce as being locally grown or produced.

Food trade nationalism is a risk to importers and exporters and may increase the likelihood of fraudulent mis-representation of geographical origin of some foods

 

It is also reasonable to expect that the current economic and trade environment will result in governments expanding food subsidy schemes to help protect staple foods in developing countries.  Subsidy schemes can be defrauded by corrupt food producers, such as occurred with some fruit growers in Sicily in 2017 and with shrimp export subsidy scams in China in 2015 and 2016.  Investigators have already uncovered corruption related to the pandemic in Uganda, where government officials were arrested over fraudulent activities related to procurement of maize flour and beans for COVID food relief.

What’s the good news?

The good news is that producers, governments and not-for-profit organisations are working together to get excess food to people who need it.  Ohio dairy farmers are turning their excess milk into cheese for charities; the USDA is purchasing unwanted vegetables from farmers for donation to food banks and New York has donated money to food banks to purchase cheese, yoghurt and butter made from excess milk.   In Boston, a brewery is using its unwanted beer to make enough ethanol-based hand sanitizer to clean five-hundred thousand hands every week.

Hand hygiene awareness has improved dramatically and food safety experts hope that this will result in long term improvements in hand washing compliance in the food and health care industries.

There are now improved online training options and technology-enabled remote audit options for businesses located outside of major cities and towns, making life easier for our country colleagues.

Finally, food safety culture leaders have been applauding the renewed calls for rules that grant paid sick leave for food handlers, in those jurisdictions where such protections are not yet in place.

What can you do?

Food businesses are at increased risk from food fraud in these difficult times.  Food fraud criminals are more likely to target businesses that have less checks and systems in place, seeking out the ‘low hanging fruit’.  Therefore, even a small amount of increased vigilance and care can reduce the risk.  Now is the time to review food fraud vulnerability assessments and update mitigation plans.  Try these activities to help protect your business from food fraud:

  • Seek out (and properly check) extra approved suppliers for critical raw materials, ingredients and products.
  • Consider sourcing commodities that are used in your key ingredients; they could be used to provide to your suppliers if the suppliers experience problems with procurement.
  • Wherever possible, do not use the pandemic as an excuse to avoid performing internal audits or supplier audits.
  • Reassess your supply chain in light of the new economic climate, focussing on the people in the supply chain as well as the business entities. The aim is to identify suppliers that might be under financial pressure and people with a history of questionable business dealings.  Check business registers and publicly available information such as old newspaper articles for any mention of fraud, bankruptcy, court cases or prosecutions.
  • Consider creating a system that allows your employees to anonymously report suspicious activities within your business. This can help reduce the likelihood of theft of finished products or materials from within your own facility or the downstream supply chain.

Are you struggling with teleconference training?  Learn how to get your company’s old face-to-face training online, fast here.

by

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. 

by

2019; the year in review

Happy New Year and welcome to 2020.  Last year included many pleasing, positive developments in food fraud prevention.  More and more people from within the international food industry are becoming aware of the prevalence of food fraud and becoming better educated about the risks it poses to consumers and businesses.  There were new developments in technology and more enforcement activities, plus awareness has continued to spread to peripheral industries and unconventional marketplaces.   Food Fraud Advisors and our sister company Authentic Food launched new products and continued to serve our growing customer community across the globe.  Thank you for your support in 2019.  I look forward to serving you in 2020.

Karen Constable, Principal Consultant, Food Fraud Advisors

Better assessments and tests

Food safety professionals are becoming more comfortable with performing food fraud vulnerability assessments and I have seen the quality of assessments improve markedly in the past year.  Food laboratories are also gaining more expertise in food authenticity testing.  Better test methods have been developed, and this is helping the labs to do their jobs more easily,  but for me I think the most important thing is that laboratory sales personnel are becoming better at understanding the needs of their food business customers when it comes to food fraud detection.

Food testing labs have better tools to meet the needs of their food industry customers

 

New food fraud prevention strategies

The past year saw significant increases in proactive prevention initiatives that extend beyond typical anti-counterfeit tools.  As an example, a famous Scottish salmon brand has recently implemented a chemical ‘fingerprint’ system to allow them to pursue suppliers of inauthentic product across their growing global supply chain.  BeefLedger is a new provenance verification product, which supports Australian beef exporters through the use of blockchain technology.

International enforcement

In India, there has been an ongoing effort by the media to publicise food adulteration problems in that country.  In response, government authorities are tackling the problem head on, with the aim of increasing trust in the food supply.  Indian news outlets feature stories of seizures and shutdowns of illegal food outlets on an almost daily basis.  Tea, spices, ghee, jaggery, cooking oil and milk are often affected.  The Food Safety and Standards Authority of India has promised to reimburse the cost of food fraud testing for consumer samples tested by credible consumer organisations.

The food crime unit in the UK benefitted from more funding last year, which increased its investigative capacity and its ability to train people in other agencies on food fraud awareness and intelligence handling.

In Europe there appears to be a growing acceptance that some organised crime groups are actively choosing to include food fraud operations within their money-making portfolios.  Although this type of operation may not be the norm, it does occur and acknowledgement of the problem is an important step in the fight to intercept and control such crimes.

Operation Opson, a joint operation between Interpol, Europol and national law enforcement agencies was run again in 2019, for the eighth year.  Operation Opson sees fraudulent food, drink and supplements investigated, located and seized by authorities across the globe, from sub-Saharan Africa to South America.  The categories of items seized most often in 2019 were illicit alcohol, cereals (grains) and condiments.  This year also included targeted actions that focussed on organic foods, coffee and 2,4-Dinitrophenol (DNP), an illegal fat-burning supplement that has caused multiple fatalities in recently years.

Grain was the second most-seized food type in Operation Opson VIII

 

In the USA, enforcement activities are also on the rise.  In 2019 there were a number of high profile prosecutions of business owners in the seafood, beef and pet-food industries.  The implementation of the Food Safety Modernisation Act (FSMA) has improved the standard of knowledge about food safety hazards and controls across the food industry in that country.  Also in 2019, many USA food companies were required to meet the International Adulteration (IA) rule of FSMA for the first time.  The rule is designed to prevent malicious threats to public health from food adulteration.  While the IA rule is not technically related to food fraud, it has made an important contribution to the concept of food safety.  As the new decade unfolds, I predict we will continue to expand our understanding of food safety; from our historical focus on natural and accidental contaminants to wider awareness of the risks posed by deliberate, human-mediated hazards.

Marketplace improvements

The good news continues, with 2019 witnessing a small but subtle shift in the willingness of online marketplace owners to talk about the problem of counterfeit goods in general, and counterfeit foods, drinks and supplements in particular.  There has been a change in the discourse around counterfeit products which increasingly addresses safety issues in addition to financial costs.  While many consumers and retailers continue to tolerate, or even seek out, counterfeit fashion items, more businesses are becoming aware of the prevalence of unsafe counterfeit supplements, foods and electronic components in online marketplaces.  And as awareness grows, I expect enforcement and preventive activities to follow; resulting in gradual improvements to the way we source and supply goods online.

Beyond food and drink

The food industry’s anti-fraud crusade has spilled over into related industries, including agricultural chemicals and packaging materials.  These two global heavy-weights are benefitting from the food industry’s food fraud awareness and prevention strategies of recent years.  As an example, the British Retail Consortium (BRC) included raw material fraud prevention activities in its most recent Packaging Materials Standard.   In pesticides, Operation Silver Axe resulted in the seizure of 550 tonnes of illegal or counterfeit pesticides across Europe.

The packaging materials industry has benefitted from lessons learned in food fraud prevention

Our year in review

Last year Food Fraud Advisors passed the 2000 downloads milestone for our tools and templates.  We continue to receive wonderful feedback and rave reviews for  our tools, templates and downloads.

We have customers in 48 countries, from large multinational food conglomerates to small start-ups, and everything in between.  While most are food manufacturers, this year we have had more customers from businesses peripheral to food production, such as brokers, logistics businesses and packaging manufacturers.  Students and consultants continue to make up a small but significant proportion of our online learning community.

 

New products

With our sister company, Authentic Food, we developed and launched the Intentional Adulteration Vulnerability Assessment Tool in June.  It filled an important gap for businesses in the USA, as there are few resources to help meet the requirements of the new FSMA IA rules and regulations.

Our vulnerability assessment tool for packaging materials was launched in November.  This tool is designed specifically to meet the requirements of BRC Packaging Materials Issue 6 which, for the first time, includes requirements to address food-fraud-like issues within the supply chain of packaging materials.  Purchasers of the packaging vulnerability assessment tool also receive a free threat assessment tool that generates a product defense plan for site security and product safety.

Our free Food Fraud Risk Information Database continues to grow.  It currently contains more than sixty five thousand words.

My favourite thing about 2019 was having the opportunity to interact with so many intelligent and resourceful food safety professionals from all over the world, as we work together to make our food supply safer for everyone.   I look forward to more of the same this year.

 

by

Latest news in food fraud

US beef sellers behaving badly and new information about lead in turmeric

In September 2019, four men from the United States beef industry were accused of food fraud by authorities. The men were owners and executives at two unrelated companies; one a beef wholesale company in New York, the other a Texan supplier to the US government.

Why would any person perpetrate food fraud? It is alleged that the New York men were struggling to make a profit in their business, even going so far as to successfully audition for a business makeoever reality TV show. They are alleged to have systematically removed United States Department of Agriculture-approved meat quality labels from cuts of beef and replaced them with counterfeit labels of a higher grade, enabling them to sell the beef at a higher price.

The men in Texas, who plead guilty for their role in a scheme to illegally add cow hearts to ground beef and who admitted to hiding the cow hearts from government inspectors, were almost certainly doing it for the money. The courts have heard that they sold the more than $1m worth of the adulterated meat to the Federal Bureau of Prisons.

In both of these cases, the frauds resulted in customers receiving food that was not true to label, and those customers proceeded to unknowingly sell and serve it to un-suspecting consumers. In one case, the meat was mislabelled but not physically modified, in the other case, the meat itself was adulterated with unauthorised material. When food is adulterated or otherwise modified, processed or (re-)packed in a fraudulent manner, the result is a product that can present significant food safety risks to consumers.

Texan meat processors have pleaded guilty to adding beef heart to $1m of ground beef.

 

Food fraud perpetrators generally wish to avoid causing serious or obvious food safety issues; after all, they do not want to be caught.  As a result, not all food frauds result in food safety incidents.  In a terrifying exception to this rule, however, it was alleged that a group of at least five people who adulterated black pepper in Vietnam in 2018 were aware that the adulterants were toxic.  The weight of the pepper was fraudulently increased by the addition of home-dyed gravel and coffee bean skins.  The dye was made by breaking open batteries to extract black-coloured manganese dioxide powder.

Another example of a toxic adulterant and one that has caused widespread illness and suffering is the industrial chemical melamine.  Melamine, which contains nitrogen atoms, can be used to trick some protein test methods which calculate protein content of food based on nitrogen within the food.   Melamine adulteration can therefore be used to boost the apparent protein content of foods such as milk powder, that are priced according to their protein content. Three hundred thousand babies became ill after drinking milk adulterated with melamine in China in 2008.  Six babies died and tens of thousands of other infants, who are now teenagers, received irreversible kidney damage, condemning them to a life of renal dialysis and ongoing surgeries.

Melamine has also been used to fraudulently adulterate wheat products, meat products and animal feed.  In the United States, melamine adulteration of dog and cat food caused the deaths of up to 3600 pets in 2007.

One of the scariest food safety issues to arise in connection with food fraud in recent years affects a food product favoured by some wealthy western consumers for its health-giving properties.  Turmeric has been lauded as a wonder-food; with properties that are said to cure joint pain, reduce inflammation, improve mood, brain function and protect against heart disease.  But powdered turmeric also presents real food safety risks to consumers because a significant proportion of powdered turmeric traded worldwide contains unsafe levels of lead.  Lead is a potent neurotoxin that damages organs including the brain.  Research released in September 2019 confirmed that the lead in turmeric is added to the spice in the form of toxic lead chromate which has a beautiful, intense yellow colour, the exact colour favoured by turmeric traders and buyers as an indicator of freshness and quality.  Curry powder, cumin and cinnamon have also been affected.  Another 2019 study, which surveyed 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 200 times higher than the recommended maximum lead content of candy in the USA.

While not all food fraud represents a risk to food safety, fraudsters who adulterate food to make extra money for themselves put consumers lives at risk.  Stay up to date with new food fraud incidents on our free, open-access food fraud database.

by

Authenticity testing – recommended frequency

Part 3 in our series about food fraud testing

Part 1: Food testing checklist

Part 2: How to design a food testing plan

Guidance on test frequencies:

When developing a food fraud testing plan, one of the biggest challenges is choosing the frequency of testing.  Food Fraud Advisors has developed these guidelines to use as a starting point.   They are not a definitive guide, always follow the advice of your analytical laboratory and specialists.

For any given material, the frequency of testing should be based on its susceptibility to food fraud.  Suggestions for five different types of materials (A, B, C, D) are described below. Test frequencies should be reviewed and adjusted on a regular basis. Frequencies can be decreased if results are consistently acceptable and increased if problems have occurred or if there are changes to the product or the supply chain.

Type A: a material known to be very susceptible to food fraud (eg. honey, white fish fillets) but for which no specific incidences have occurred within your supply chain and for which no intelligence related to your supply chain has been received.

Phase 1: test a sample from 5 out of 5 incoming batches from every supplier and/or geographical source. For agricultural materials, this sampling protocol should be repeated on a seasonal basis across the year. The aim is to build a picture of authenticity across the year for your suppliers. Progress to phase 2 if all the results from phase 1 have been satisfactory. If test results have revealed problems with authenticity, phase 1 should continue for the affected suppliers or places of origin. Suppliers with satisfactory results can progress to phase 2.

Phase 2: reduce the frequency of testing to one sample per 5 to 10 incoming batches, with the frequency based on your estimate of the ongoing risk. As in phase 1, materials with seasonal supply fluctuations should be tested over various seasons. Use the results from phase 2 to continue to add to the overall picture of authenticity for this material type within your supply chain. Continue until you have at least 10 results. Progress to phase 3 if all results are satisfactory.

Phase 3: is an ongoing maintenance phase. Aim to test one sample per 10 to 20 incoming batches as an ongoing protocol.

Type B: Material for which you have received specific intelligence related to authenticity that pertains to your supply chain.

Phase 1: focussing on the implicated products or ingredients, take samples from at least 5 incoming batches. If the material is non-homogenous – for example if it is in individual packages, or individual pieces rather than being a bulk liquid or powder – consider taking duplicate or triplicate samples from each incoming batch, if budget allows. If all of these samples ‘pass’ the tests, consider trying alternative test methods or test types. Move to phase 2 if all test results are satisfactory.

Phase 2: reduce the frequency of testing to one sample per 5 incoming batches. Continue this frequency of testing until your intelligence information and your test results are sufficient to suggest that the risks within your supply chain have passed. If the risk has abated, reduce the frequency to that of phase 3 for type A.

Type C: Moderately susceptible materials

Phase 1: test a sample from 1 of 5 to 10 incoming batches from every supplier and/or geographical source. For agricultural materials, this sampling protocol should be repeated on a seasonal basis across the year. The aim is to build a picture of authenticity across the year.  Continue until you have at least 5 results per supplier or geographical source. Progress to phase 2 if all the results from phase 1 have been satisfactory. If test results have revealed problems with authenticity, phase 1 should continue for the affected suppliers or places of origin. Suppliers with satisfactory results can progress to phase 2.

Phase 2: test one sample per 10 to 20 incoming batches with the frequency based on your estimate of risk. As in phase 1, materials with seasonal supply fluctuations should be tested over various seasons. Use the results from phase 2 to continue to add to the overall picture of authenticity for this material type. Continue until you have 5 results. Progress to phase 3 if all results are satisfactory.

Phase 3: If all results from phases 1 and 2 are satisfactory, the frequency of testing can be significantly reduced. One test per year per supplier should be adequate for most materials and suppliers.

Type D: Food products at risk of counterfeiting or suspected of being from illegitimate sources

A market surveillance sampling plan should be devised. Retail and/or wholesale sources in high risk markets should be targeted in addition to online marketplaces. Anonymous market ‘buyers’ could be engaged to obtain the samples. Buyers can be instructed to purchase a specific number of items per batch per outlet, or they can be instructed to inspect or photograph samples in situ. The amount of surveillance will depend on the brand owner’s tolerance of counterfeiting and the testing budget.  Products at high risk of counterfeiting are likely to need ongoing surveillance.  Food products that have been found to have entered marketplaces through theft, diversion or grey market channels can have their risk reduced by implementing controls within distribution chains.

Type E: low risk materials. If a food ingredient or product has been shown to be low risk in a food fraud vulnerability assessment then authenticity testing should not be required. If the material or supply chain has changed such that the material requires authenticity testing then its food fraud vulnerability should be re-classified to medium or high risk.