Food Fraud Advisors

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From the food fraud desk

Happy New Year!

Last year was a busy year for Food Fraud Advisors.

Detection and enforcement actions increasing

Food fraud remains a hot topic in the food industry and is garnering stronger interest from the international anti-counterfeiting industry as well as international crime prevention groups like Europol and Interpol.  Recently, the international media have been discussing the role of organised crime syndicates in the food industry, particularly in the produce sector in Italy and in tuna trading in Europe.

Detections of food fraud and seizures have increased: almost a quarter of the 31 m counterfeit items seized by EU customs agents in 2017 were food stuffs.

In 2018 we were pleased to witness a number of serious law enforcement actions across the globe.  This is a trend which I hope will continue.  As an example, the people responsible for a long-running, fraudulent organic grain scheme in the USA were charged and pleaded guilty.  In Pakistan, the authorities have used new laws prohibiting the sale of unpackaged spices, which were created to reduce food adulteration, to seize 165,000 kg of spices and shut down 400 spice processing facilities.

Rising consumer awareness

Meanwhile, consumer awareness of food fraud is also rising.  Nearly three quarters of UK consumers think there is a serious problem with food fraud in their country and one quarter of consumers think they have experienced it first hand.

food fraud worries shoppers

Test method developments

In academia, new test methods for food fraud detection continue to be created and refined.  As exciting as it is to read headlines in journals about the latest scientific breakthrough, many of the research papers report on testing methodology that won’t be ready to be used by food manufacturers, wholesalers and retailers for some time.  One such exciting headline recently gushed that scientists have found a new ‘simple’ method to distinguish organic milk from conventional milk.   The headline did indeed to turn out to be too good to be true, with more work on a larger sample size needed to validate the method.   However, with organic products at very high risk of food fraud and detection being difficult, it’s great to see the analytical community working on these problems.

Our year working for you

Within Food Fraud Advisors we have been focussing on keeping up to date with our customers’ needs for the latest versions of SQF, BRC and IFS food safety standards.  Food fraud documentation is one of the top sources of non-conformities in food safety audits so many of our customers have been seeking help to boost their programs.

SQF’s standard in particular caused a few headaches for our clients.  SQFI did not publish any guidance for food fraud until after the implementation date for Edition 8.  As a result, many SQF-certified facilities needed our help to understand and implement programs to meet the new food fraud requirements before their first audits.  Within the  SQF guidance document there is a recommendation for senior managers to be trained in food fraud awareness and we were pleased to launch a short, practical on-demand training course to meet this requirement.   We’ve had great feedback about this course, and for only $59 it’s a great way to meet your continuous improvement and training requirements for 2019.

Also in 2018, our one-stop, deep-dive food fraud training course was re-launched, with new lessons, more downloadable templates, new content for food fraud teams and step-by-step instructions for creating and implementing a food fraud prevention program from scratch.   Check it out today. 

We look forward to working with you in 2019 and beyond.

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Five things every food safety professional should know about food fraud

1. Food fraud is in the spotlight

Food fraud has been around for thousands of years but has become more prominent in the food safety and food certification industry in the last few years, following the European horse meat scandal of 2013.  Although no food safety problems arose during that incident, it was realised that similar incidences could have serious impacts on food safety.  For that reason, food fraud prevention requirements were introduced into all major food safety management system standards between 2017 and 2020.

2. New terminology

Definitions related to food fraud and food integrity have been refined in the last five years and there is now consensus on the four key terms below, although the term food security still causes confusion.

food fraud,defense,safety,security

  • Food safety relates to issues of unintentional contamination, with the aim of reducing exposure to naturally occurring hazards, errors and failures in food systems.
  • Food fraud was defined by  Spink and Moyer (2011) as “a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.”  More recently that definition has been updated to capture all types of food crime: Food fraud is deception, using food, for economic gain (Food Fraud Initiative, Michigan State University).  Within food fraud there are types of fraud that involve tampering with the food by adulterating or diluting the food.  This type of fraud is sometimes called ‘economically motivated adulteration’ (EMA).  Other types of fraud that do not involve adulteration are also deemed to be ‘food fraud’.  These include black market and grey market sales, theft, illegal importing, avoidance of tax and counterfeiting.
  • Food defence is a term that has come to be defined as the effort to prevent acts of adulteration that are intended to cause harm to a food business or to consumers, such as acts of terrorism or attempted extortion.
  • Food security is unrelated to food fraud but is instead an issue of food supply and food access for populations who are under threat from food shortages.

Other terms to know:

  • Vulnerability assessments are assessments of vulnerability to food fraud, either at the raw material, product or facility level.  Within the USA the term vulnerability assessment can also refer to a food facility’s vulnerability to malicious tampering of product on its site, either by its own employees or external forces.   Learn more about vulnerability assessments.
  • Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  Within the food industry, horizon scanning means the act of collecting information about current trends and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to reduce coffee production which could drive up prices and increase fraudulent activity in that sector.
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Coffee harvests are being affected by climate change

 

3. Food safety standards have become more rigorous

Food fraud prevention and mitigation measures are now a requirement of all major food safety management system standards.  The Global Food Safety Initiative (GFSI), a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe, sets guidance for food safety standards.  Well known GFSI standards include BRC, FSSC 22000 and SQF.  Between 2015 and 2017, all GFSI food safety standards were updated to include requirements for food companies to perform a food fraud vulnerability assessment and have a food fraud mitigation plan in place.   Click here for the GFSI Food Fraud Position Paper.

The new requirements for vulnerability assessments and mitigation plans require more resources for most food businesses, particularly those with large numbers of raw materials and suppliers.

4. There are new regulatory requirements for food businesses

The Food Safety Modernization Act (FSMA) in the USA has been implemented for most food businesses in the previous few years.  Within the FSMA rules, food businesses are required to address hazards from adulterants introduced for the purposes of economic gain.  These must be included in food safety hazard analyses and if hazards are found, preventive controls must be implemented.  This means that economically motivated adulteration (EMA), a subset of food fraud, must be addressed under the new FSMA rules.

The Food Safety Modernization Act (FSMA) also includes specific requirements for ‘food defense’ which are aimed at preventing malicious adulteration and tampering as well as fraudulent adulteration.  This is known as the Intentional Adulteration (IA) rule.  The IA rule is being progressively implemented in the USA.  FSMA rules for IA will also be enforced internationally for all food facilities that manufacture food for export to America.  Click here for US FDA’s food defense guidance

food defense,vulnerability assessment,FSMA,
All American food companies will be required to have a food defense plan

 

5.  Detection of food fraud remains a challenge, despite new lab techniques

Our ability to detect food fraud has improved over the last few years, but challenges remain.  There are many technologies available, from traditional ‘wet’ chemical tests to spectroscopy and chromatography to modern forensic DNA methods.   Protein isoelectrofocusing (a type of electrophoresis) is a conventional test that provides information about the source of various milk proteins in a cheese and can be used to detect cows milk in “buffalo milk” mozzarella, for example.  PCR (polymerase chain reaction) techniques, in which a cow milk-specific gene is amplified and detected are being developed for cheese testing and they are claimed to be more specific.

Coffee variety testing has traditionally been done using Fourier transform infrared spectroscopy, a method that exploits the different amounts of chlorogenic acid and caffeine in robusta and arabica varieties.  However, a new method that exploits the different mitochondrial genetic markers in the two varieties will soon be able to achieve the same results quickly and easily in the field with ‘lab on a chip’ technology.

Researchers looking for fraudulent aloe vera can exploit its distinctive NMR (nuclear magnetic resonance) profile, due to the position of acetate groups within a key polysaccharide in the plant.  The NMR profile represents a ‘fingerprint’ for aloe vera.

Another type of ‘fingerprinting’ is based on the spectra created by different ratios of stable isotopes.  For example, it is possible to tell the difference between corn-fed and wheat-fed chicken, using stable isotope ratio mass spectrometry by comparison with databases of reference samples.  This method has also been used to check provenance claims for meat and wine products.

Authentic beef mince
What meat is that?

 

Despite the surge in technology surrounding food fraud detection, it remains difficult to detect fraudulent adulteration unless you know what you are looking for.  As an example, DNA testing can be used to determine if beef mince has been made from a cow but can’t tell me whether it has been adulterated with undeclared beef offal.  Olive oil that is suspected of having been adulterated with other edible oil can easily be tested for such adulteration in a lab test, but verifying its country of origin is more difficult.  Adulteration of ‘arabica’ coffee with the cheaper robusta variety can be detected with a simple test but that same test will not disclose whether ground coffee has been adulterated with cheaper fillers such as corn, soybean or wheat, a practice which is common in some markets.  There are now a number of ‘fingerprinting’ techniques that are designed to ‘flag’ any sample that is not authentic, no matter what the adulterant, however they can only be used if there is already an extensive database of authentic samples with which to compare the suspect sample.  Australian honey brand owners who were caught with supposedly inauthentic honey in an NMR-based fingerprint test claimed that the database used in the testing, which was done in Germany, was not suitable for testing Australian honeys.  Read more about the Australian honey scandal.

We have a lot of tools in our arsenal to answer questions about fraudulent food but those tools are only useful if we ask the right questions.

Need to learn more?  Want practical advice from expert food scientists? Click here for a free introductory consultation.

 

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September food fraud update; trade wars, fruit scares and spuds

The ‘trade war’ between the USA and China is really hotting up, with China having imposed import tariffs of up to 25% on US lobsters and other food products in the previous 2 months.  The presence of tariffs greatly increases the risk of fraudulent cross-border activities; Food Fraud Advisors predicts that the new China tariffs will lead to significantly more food fraud within the Chinese-American trade sector as well as having a knock-on affect on food trade internationally.

There have already been allegations of fraud related to the tariff imposition in the North American lobster market.  Canadian lobsters can be imported to China without incurring the tariffs imposed on lobsters from the United States.  It has been alleged that lobsters grown in the USA are being shipped to Canada, re-labeled as Canadian lobsters then exported to China.  Canadian lobster growers fear damage to the ‘Canada’ brand from these activities.

The strawberry scandal in Australia has hit local consumers, retailers and growers hard.  It started with two consumers in the state of Queensland finding metal needles inside fresh strawberries.  The affected brand and its sister brand from the same grower were pulled from shelves.  Within days another needle-like object was found in strawberries from a different brand in a different state; the fruit source was completely different and the incident was labelled a ‘copycat crime’.  In Australia strawberries are typically sold to consumers in clear clam-shell containers with four air holes in the top surface.  The air holes are large enough to allow access to the fruit inside with a small sharp object like a needle while the strawberries are displayed on a supermarket (grocery store) shelf.  Public response has been confusion; why would anyone want to do such a thing?  Since then, other fruits, including apples and bananas have been similarly affected, again, in what appear to be completely independent occurrences.  The food safety sector in Australia is at a loss as to how to prevent this type of incident; fruit is by necessity displayed and accessible for consumers to touch prior to purchase, leaving it vulnerable to malicious adulteration.

Meanwhile, strawberry growers in Australia, who were already struggling to get good prices for their bumper harvest, have seen demand for their fruit plummet.  Media outlets have published reports about farmers who are dumping tonnes of unwanted fruit because the wholesale price has fallen below the cost of production.

Whole potatoes are generally thought to be at low risk of food fraud because of their relatively low value and because of their easily recognisable form.  However, like all fruit and vegetables, they are at risk of being misrepresented with respect to their geographic origin and their variety.  Growers groups have demanded that government authorities investigate allegations of potato fraud in Ireland, after a successful campaign to encourage consumption of locally-grown Queen potatoes.  It has been alleged that imported potatoes and potatoes of other varieties are being re-labelled as Irish Queen potatoes, providing an economic gain for the perpetrators of this fraud.

 

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Food testing checklist

Like many other food safety and quality professionals, perhaps you are thinking about implementing a testing program for food fraud detection.  Are there vulnerabilities in your supply chain? Maybe you are buying products or raw materials that are on our food fraud hot list, or perhaps your food fraud vulnerability assessments identified materials that might be affected by food fraud.

Food authenticity testing laboratory lab

Testing is an important tool in the fight against food fraud, but it’s not always easy to get it right. Are you prepared for testing? Before you begin to contact laboratories, make sure you can answer these questions:

  • Do you need a ‘snap-shot’ of a product at a single point in time or are you aiming to build a longer-term picture of authenticity?
  • Are you acting on any specific information, such as a tip-off or allegation from a competitor?
  • Is there a particular adulterant you need to look for?
  • Are you a brand owner checking possible counterfeits or diverted products to determine if they are legitimate?
  • Do you need the test results to stand up in a court of law or other legal scenario?
  • Is the test material a single agricultural product or a processed multi-component food?
  • Is the material shelf stable or will it need special sample storage/transport conditions between sampling and testing?
  • Is the testing needed to check on credence claims, for example, organic, free-range, country of origin?
  • Do you need qualitative or quantitative results? For example do you need to know if an adulterant is present or absent in the tested material or do you also need to know the amount of the adulterant that might be present?
  • What level of certainty do you require?
  • How much time have you got?
  • What’s your budget?

And finally…

  • Are you prepared for what you might find; do you have a plan of action to take if food fraud is detected?

There are many laboratories that perform some type of food authenticity testing, but few that perform many types. Expect to speak to a number of different laboratories before you find one that can meet your needs.

Read this next: How to design an authenticity testing program

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Fraudulent practices cost chicken processor £37m

A large chicken processing business, 2 Sisters was the biggest supplier of supermarket chicken in the United Kingdom with a turnover of £1.1 billion in 2017.  During that year, an undercover investigation revealed poor hygiene practices and tampering with date codes was taking place at one of the firm’s processing plants in West Bromwich.  Investigators also alleged that products returned from distribution centres that should have been destroyed were repackaged as if they were fresh, and that the ‘kill dates’ for chickens were deliberately misrepresented so as to extend the expiry date of the finished products.

The Food Standards Agency investigated and in addition found fraudulent practices within the Salmonella testing of the carcasses.  Salmonella testing is a regulatory requirement in the United Kingdom.  In the wake of the investigations, operations at one plant were suspended for 2 weeks, while another was closed permanently.  In April, it was announced that another plant, in Scotland will be closed later this year.

This week, 2 Sisters reported losses of £38 million for the year, a figure that was reported to have ‘ballooned’ by 80% after the fraudulent practices were uncovered.