Food Fraud Advisors

You are here: Home / Blog

by

Tip-truck to table: waste diversion fraud

Organised crime groups are funnelling relabelled food back onto shelves

I’ve been wondering … what exactly happened to the 160,000 pounds (72,600 kg) of frozen shrimp that were recalled in the US in mid-2025 in relation to the radioactivity scare? Yes, it was recalled, but what happened to it after that?

What did the recalling companies and retailers actually do with each of the hundreds of thousands of 1.25 lb (570 g) bags of product? Did they empty the contents of every one and shred each package so it couldn’t be reused? Did they arrange for secure disposal with a trusted waste company and require a certificate of destruction? Or did they just dump them in a skip bin and let a contractor take them all away?

And why does this matter anyway?

It matters because the results of Operation Opson XIV have just landed. And they show that waste diversion crimes are at “unprecedented levels”.

Reminder: Operation Opson is an annual law enforcement initiative coordinated by INTERPOL and Europol with the aim of detecting and removing counterfeit, substandard, and fraudulent food and beverages from the market, and dismantling organised crime groups linked to such activities.

What are waste diversion crimes?

Waste diversion crimes in food involve illegally redirecting food, drink, or feed that is marked for disposal—such as expired, rejected, or unsafe goods—back into the human food supply chain through acts like relabelling or repackaging.

Photorealistic landscape image of identical cans with altered expiry labels in a warehouse.
Operation Opson XIV uncovered criminal-network- linked waste diversion crimes at unprecedented levels.

What do waste diversion crimes look like?

Here’s a hypothetical…

What if a seafood distributor involved in the recent US recalls decided the frozen shrimp was too valuable to throw away? What if senior management decided to make a few extra dollars by relabelling the cartons of product that had been returned to them rather than destroying them as required?

Could the distributor simply rebrand them or oversticker the cartons, add new expiry dates and keep them in the freezer until everyone has forgotten about the recalls, then sell them months or years later?

The short answer is yes.

It’s illegal and immoral, of course, but, with the shrimp worth $4 to $10 per pound, even a small quantity handled in this way can generate meaningful profits out of thin air – especially if the distributor received credits or refunds for the recalled stock.

Frozen seafood lasts many years – a man in Singapore was sentenced in 2023 for crimes related to storing frozen seafood that was almost 10 years past its expiry date – so there is plenty of scope for crime here.

In a different scenario, let’s imagine the seafood distributor does the right thing and sends the recalled shrimp for disposal.

In this scenario, what if the waste disposal company somehow had links to organisations that could relabel or repackage the shrimp and sell it back into legitimate supply chains later?

What if the waste disposal company didn’t just have links to criminals but was actually owned by an organised crime group that also owned repackaging facilities, warehouses and legitimate food distribution companies – a vertically integrated (mostly) legitimate supply chain? In this case, diverting the recalled shrimp back to retailers and restaurants would be easy.

But surely that’s too far-fetched, I hear you say. Sorry, I’m afraid it isn’t.

And anyway, Operation Opson is mostly in Europe. Surely this sort of thing isn’t happening in places like the USA? Sorry, I’m afraid it is.

The following story is not a hypothetical, but a real incident that happened in the United States.

The roadside spilling of a truckload of Skittles confectionery on its way to a cattle ranch, where it was destined for animal feed, made news headlines in 2017. When people protested that cows should not be fed Skittles, the brand owner, Mars, told reporters that the confectionery had been sent for destruction, saying they had no idea how the candies ended up on their way to a farm1.

Waste disposal crimes today

Things have changed since 2017. The price of food has increased dramatically, food security has fallen significantly, even in wealthy countries. There is also a growing body of evidence that documents the involvement of organised crime groups in food, in addition to typical crime sectors such as drugs and guns.

Today’s global landscape has made waste diversion crimes more attractive, not less.

In 2023, European law enforcement agencies dismantled two large crime groups that were reselling expired food after re-printing expiry dates or applying new labels, with 27 people arrested for their roles in a million-euro operation based in Lithuania, and selling food across multiple countries. They also arrested 3 people in Italy. In total, the agencies confiscated more than 1.5 million food and beverage items in the operations. The Lithuanian operation had been active since 2021.

At the time, Europol told reporters, “The phenomenon [of waste diversion crime] is new in its scale and diffused across several EU member states,”

Europol assured the industry that the criminals were working in food disposal, not food production, saying “There is no involvement of food producers, as intermediate suppliers or other entities working in food disposal are used as facilitators in this particular criminal activity.”

“Entities working in food disposal are used as facilitators in this particular criminal activity.” Europol (2023), via Securing Industry

In 2025, the situation seems worse. The most recent Operation Opson, Opson XIV, has just concluded, with 13 organised crime groups disrupted, 101 arrest warrants issued and €95 million worth of food and beverages seized.

One of the major trends for Opson XIV, said Europol, was finding waste disposal companies infiltrated by organised crime groups, which were using the waste companies to gain access to food destined for destruction.

This is not a new phenomenon, but this year, says Europol, the scale is “unprecedented”.

Examples everywhere?

Have you ever seen food that’s been through the waste diversion chain? You probably have, without even knowing it.

I can think of three incidents that could be linked to organised crime in waste providers.

1. Dodgy Diet Coke

‘Not right’-tasting Diet Coke discovered in London in 2025 could be expired product fraudulently reintroduced to the market – artificial sweeteners in diet soft drinks lose their sweetness, rendering old drinks tasting like soda water. Read more on the Fake Coke scandal.

2. Jars of herbs containing glass

In 2023, I reported on a waste disposal company in the Netherlands that was selling food products it had promised to destroy. The crimes were uncovered after a consumer was injured by glass in a jar of herbs from a batch sent for destruction.

The waste company was providing declarations of destruction which were false. A key person at the waste company had previously been convicted of environmental crimes.

3. Spaza shop mystery deaths

In January, I wrote about the thousands of unexplained deaths in South Africa attributed to food purchased from spaza shops (small, independent and lightly regulated retail outlets).

A key complaint about the food from these shops is that it is often expired. Much of it appears to have been illegally imported by foreign nationals operating the stores without proper immigration status.

Video footage of a raid on one shop showed foods such as savoury crackers in transparent inner packs without their outer packaging or labels. Because they are missing traceability elements such as outers and labels, these foods could be from non-legitimate supply chains.

Officially, it’s said that Spaza shop owners use collective purchasing practices to keep prices low; however, it’s possible that groups of spaza shop owners source their products from overseas suppliers with links to waste disposal companies.

Takeaways for food professionals

Enforcement agencies are discovering the presence of organised crime groups in food waste disposal operations at unprecedented levels. Food that is intended for destruction and disposal is being diverted back into the human food supply chain after expiry dates or entire labels are altered or replaced.

Purchasers of packaged foods, such as grocery stores, independent retailers and food service outlets like takeaways, restaurants and cafes should obtain their supplies from legitimate, authorised stockists and wholesalers.

Manufacturers should be vigilant when disposing of packaged or branded materials.

Supplier approval processes should include the vetting of waste disposal contractors. Background checks are recommended – for example, have key personnel got a history of criminal convictions (as was the case in the Netherlands example)?

Certificates of disposal/destruction should be verified where possible.

As a former-soft-drink-company-employee told me in response to my Diet Coke story, “The correct disposal of branded waste and reject materials is a key factor for limiting the opportunity for these crimes.”

When purchasing food as a business or consumer, be on the lookout for:

  • Food that seems too old, despite being within date
  • Outer cartons and individual packs that are more scuffed, damaged or worn than expected
  • New suppliers that appear unexpectedly and offer products from multiple disparate brands, sometimes at lower-than-usual prices
  • Corner shops/spaza shops/tuck shops selling food in inner packs marked ‘not for retail sale’, or without exterior packages that would carry the batch codes or date markings
  • Packages with foreign language labels and no local information.

If in doubt about any such food, keep a sample and contact enforcement agencies and the brand owner to describe your concerns. Big food companies will investigate and take action against waste disposal crimes affecting their brands.

… and be on the lookout for suspicious frozen shrimp in the US for the next year or two…

In short: The involvement of organised crime groups in waste disposal operations was found at unprecedented levels in the latest Europol anti-food crime operation, Operation Ospon XIV 🍏 Food intended for destruction is being diverted back into the human food supply chain, often with altered expiry dates or new labels 🍏 Purchasers are warned to be aware and to report suspect products to the brand owner and enforcement agencies for investigation 🍏

Main source:

Europol (2025) Counterfeit and substandard food worth EUR 95 million seized in global operation (Operation Opson XIV). Available online: https://www.europol.europa.eu/media-press/newsroom/news/counterfeit-and-substandard-food-worth-eur-95-million-seized-in-global-operation

 

This article was originally published at The Rotten Apple – a weekly newsletter for food professionals

by

Case study: Double brokering leads to disappearing tequila

A food fraud case study

In the past, I’ve told you that food-waste-diversion crimes are being detected at unprecedented levels in Europe, and described how enforcement actions coordinated by Europol had dismantled 13 organised crime groups in their most recent anti-food-fraud operation.

This week’s case study explores diversion-style crime from a North American perspective. This case doesn’t involve the diversion of waste back into the supply chain, but, like those discovered in Europe, it does involve an organised crime group.

When: November 2024

What: 24,000 bottles of Santo Tequila worth more than $1 million.

How: Criminals used non-existent trucking companies and a process called ‘double-brokering’ to gain access to the goods, ensuring they were never delivered to their intended destination.

Details:

In November 2024, a shipment of premium Santo Tequila left Mexico on its way to a warehouse in Pennsylvania, via Texas. The shipment comprised the entire batch of a special lot of tequila that had taken 3 years to make, especially for the 2024 holiday season.

After crossing the border into Texas, the consignment was moved to two semi trucks and entrusted to a logistics company hired by Santo Spirits to deliver the tequila to its warehouse in Pennsylvania, a 2.5-day drive north.

The logistics company hired a trucking company to make the delivery. It outsourced the job to two other trucking companies through a bidding process called double brokering. Drivers hired by the second companies collected the trailers and drove away with the tequila.

In Pennsylvania, the tequila did not arrive as scheduled, and Santo was told there had been a mechanical problem with a truck. A few days later, the shipment still hadn’t arrived. Santo was told the mechanical problem had been worse than first believed, but the delivery would arrive soon, around 5 days later than scheduled.

GPS tracking provided by the logistics company showed the truck was definitely en route. A few days later, Santo was told the truck’s GPS showed it was near the warehouse in Pennsylvania.

But the truck – and the tequila – never arrived.

Investigators discovered the trucking companies had told the drivers to take the trucks to Los Angeles. The trucking companies were fake businesses, with fake online profiles, phoney letterheads, email addresses and phone numbers, and possibly operated by people outside the USA.

The emails about the mechanical issues were falsehoods, and the GPS tracking had been faked.

The drivers, however, were genuine, hired by the fake trucking companies.

The bigger picture:

This type of cargo theft, involving redirection of goods to other locations by remote operators, has increased by more than 1,200% in four years, according to a cargo theft investigator who assisted with the Santo Tequila case.

The Los Angeles Police Department (LAPD)’s special cargo theft unit says that in such cases, the goods are usually sold online or in stores. A recent ‘bust’ found $4.5 million worth of stolen goods in a warehouse.

The outcome:

Santo Spirits was luckier than most. The LAPD cargo theft unit tracked down one of the drivers, who told them he had been directed to drop the cargo in the San Fernando Valley. One truckload – eleven thousand bottles – of the missing batch were found at a warehouse in southeast Los Angeles two weeks after the heist. The other truckload was never found.

Source:

Alfonsi, S. and Chasan, A. (2025). Two truckloads of Guy Fieri’s tequila vanished last year. It shed light on a growing new crime. [online] CBSnews.com. Available at: https://www.cbsnews.com/news/double-brokering-guy-fieri-tequila-heist-60-minutes/.

🍏 Want more case studies? Check out the Food Safety Knowledge Vault on The Rotten Apple🍏

This article was originally published at The Rotten Apple – a weekly newsletter for food professionals

by

Tomato paste scandal: Chinese origins in ‘Italian’ products exposed

In December 2024, allegations of forced labour in the tomato puree supply chains of major British retailers caused shockwaves in Europe.

On the surface, the allegations appeared massively shocking. Firstly, the purees were portrayed as the products of the torture and abuse of Chinese religious minorities. Secondly, the news coverage implied large-scale fraud with respect to the origin of the purees, many of which were marketed with the word ‘Italian’ on the pack.

It seemed that British and German supermarkets were selling ‘Italian’ tomato purees that contained Chinese tomato puree supplied by companies that relied on forced labour.

Shocking.

But when I sat down to share the news with you in Issue 168, I found the legal situation was so murky that I actually couldn’t pin a definite ‘food fraud’ label on any of it.

The BBC, reporting on the issue, used very careful language when referring to the allegations, saying “[some products] are likely to contain Chinese tomatoes” and asserting that “most Chinese tomatoes come from the Xinjiang region, where their production is linked to forced labour by Uyghur and other largely Muslim minorities.”

Most of the details that would have helped to reveal whether this was a case of food fraud were not shared publicly or were not known to the BBC at the time. For example, we weren’t told how much Chinese puree was in any of the products – were they 100% Chinese or only 50%, for example?

We could not decipher the degree of fraud (or not) related to the ‘Italian’ claims, since the BBC did not share the exact claims on the packs of products that were found to contain some Chinese tomatoes.

And finally, while the BBC published interviews with workers who had picked tomatoes under forced labour conditions in China, the information it published was not direct evidence of forced labour in the supply chain of any of the puree products mentioned in the story.

Aside: The most compelling part of the 2024 story, for me, was that one of the Italian manufacturers that supplied some British supermarkets, the company that made ten of the seventeen samples which contained Chinese tomatoes, had previously been accused of fraud by Italian authorities for falsely claiming its products contained ‘100% Italian tomato’.

That’s right, the Italian company supplying ‘Italian’ tomato puree that allegedly contained Chinese tomatoes had been accused of fraud by Italian food authorities three years prior.

Background checks, anyone? A simple Google search of the company name followed by the word tomato revealed instant red flags: two of the top three search results were stories about the company’s 2021 brush with Italian food fraud investigators.

After the BBC report, all seemed quiet on the tomato paste front.

Not so.

The tomato paste market underwent a huge upheaval following the BBC investigation. Suddenly, everyone was paying attention to the origin of their tomato paste. No one wanted tomato paste from China and the Italian paste suppliers who had been importing it for use in their products stopped buying it.

In the months that followed, Italian processors reduced imports of tomato concentrate from China by 76%, according to the CEO of Mutti, a leading Italian maker of tomato purée and passata, leaving China with a huge stockpile of 600,000 to 700,000 tonnes of tomato paste, equivalent to around 6 months of exports.

Tomato News reports that while Chinese tomato exports to Western Europe and Italy have fallen dramatically, the surplus is being taken up by countries in Eastern Europe, Central America, and the Far East. Production in China has also fallen dramatically, with less than half the volume of tomatoes expected this year compared to 2024.

So, with China no longer supplying major markets in Western Europe, where will those markets get their tomato paste – that all-important ingredient for pizzas, pastas, ready meals and soups?

Can Italian tomato growers step up production to meet demand? Or will the supply-demand gap be so large that fraud becomes almost inevitable?

Tomato paste production in Xinjiang ramped up rapidly to 11 million tonnes in 2024 and is projected to fall to 3.7 million tonnes in 2025

 

Food authenticity expert Professor Chris Elliott believes the current situation is ripe for fraud, suggesting the following scenarios are possible:

  1. The large stockpile of tomato paste in China could be transhipped or reprocessed in third countries to conceal its Chinese origins, making it palatable for Western European markets.
  2. Other false claims of origin could be made about tomatoes from other major growing areas such as Spain, Portugal, Chile and Iran.
  3. Lower-quality paste may be blended into higher-value pastes (noting this is not fraud unless accompanied by deceptive claims about quality or origin).
  4. Undeclared fillers and diluents, such as starches or sugars, could be used to extend the volume of scarce non-Chinese tomato paste.
  5. Undeclared and unauthorised colourants could be added to enhance the appearance of low-quality, diluted or age-degraded pastes.

With tomato paste having a long shelf life, these fraud risks will remain for as long as surplus stock remains in China and while European market demand is unsatisfied. And that could be for years to come.

Key takeaway

We are currently in a perfect storm for tomato paste fraud. There is an oversupply of Chinese-made tomato paste and an undersupply of genuine Italian tomato paste. This creates vulnerabilities, particularly for products marketed with specific country of origin claims. Possible frauds include transhipping and reprocessing to disguise the true origin of Chinese pastes, other false origin claims, blending, dilution, addition of fillers and other adulterants to extend the volume or enhance the apparent value of low-quality pastes. Also note that Chinese-origin tomato pastes have been linked to labour violations and modern slavery.

 

Read more:

🍏 Tomato Puree Fraud by Big Name Retailers? | Issue 168 🍏

This article was originally published at The Rotten Apple  – weekly newsletter for food professionals.

by

Fraud Risks for Cocoa and Confectionery Businesses

Chocolate’s supply chain is vulnerable to changes in weather, farming practices, and global trade networks. It is a truly global product, with the beans mostly grown in developing nations and processed into chocolate in wealthy nations.

Supply chain challenges include problems with cultivation, trade, sustainability, and compliance.

Threats to production

In recent years, the combined effects of extreme weather events, tree diseases and climate change in the world’s biggest cocoa-growing regions have severely impacted yields.

Cocoa farmers are reportedly abandoning their trees or choosing not to replace ageing trees as the crop becomes less profitable due to rising production costs and declining yields.

In Côte d’Ivoire, for example, prolonged droughts, unpredictable rainfall, and increased plant diseases like swollen shoot disease have made cocoa farming unprofitable for many, leading farmers to leave their plantations or switch to alternative crops.

In Ghana, the world’s second largest cocoa producer, gold mining is now impacting cocoa production and taking over fertile land once used for cocoa growing.

The area of land used for growing cocoa is decreasing in Ghana. Data source: FAO.org

 

The Swiss media outlet Swissinfo reported in 2022 that cocoa farmers were selling their land to illegal gold miners, with swathes of farmland transformed into wastelands dotted with piles of clay contaminated with mercury, a by-product of gold extraction.

In the same year, a survey by the Ghanaian cocoa board revealed that 19,000 hectares of cocoa plantations had been lost, taken over or damaged by illegal gold mining.

With recent large increases in the price of gold and more problems with cocoa production due to disease and climate change, there is increasing recognition that more cocoa farmland will be lost to mining in 2026..

Cocoa futures (in USD per tonne) reached an all-time high in April 2024 and remain at more than 3 times the average price in 2023. Chart: Tradingeconocmis.com

 

With production declining, cocoa prices are rising. They increased by 25% in the two years to 2024.

Prices have since stabilised somewhat, but cocoa futures today are still more than three times higher than they were in 2021 – 2023.

Read more: 🍏The surprising link between illegal gold mining and chocolate 🍏

Threats to trade and compliance

Chocolate has always been considered an at-risk product for unethical labour practices, particularly in West Africa, which supplies around 60 to 70% of the world’s cocoa. Structural poverty, low farm-gate prices, and lack of bargaining power among farmers create conditions where forced labor, debt bondage, and child trafficking can occur to meet demand and maintain profitability.

Estimates indicate that over 1.5 million children are involved in child labor on cocoa farms in Ghana and Côte d’Ivoire, with many engaged in hazardous work, and there have been documented cases of both child and adult workers being subjected to exploitative or slave-like conditions in other cocoa-producing countries as well.

In 2023, the commodities trader Cargill was ordered to pay more than $120,000 by a Brazilian court after prosecutors alleged it did not know the extent of child labour in its Brazilian cocoa supply chains because it purchases from hundreds of producers, co-operatives and merchants. Cargill denied the allegations.

In 2021, Hershey and the Rainforest Alliance were sued for false advertising in the US, with Hershey accused of turning a blind eye to child labour in their supply chain and the Rainforest Alliance accused of being unable to prevent or even account for it.

Certification schemes like Rainforest Alliance and FairTrade are supposed to give assurance of ethical work practices in the production of the certified foods, but their efficacy has been questioned.

Researchers who reviewed the ability of schemes like FairTrade to assure child-labour-free processes in 2018 were told by a certifier “We are working with around 11,800 cocoa farmers, so we have not been able to visit any farms as of now”. Instead, they relied on farmers’ cooperatives to verify the working standards at farms.

The cooperatives receive a premium for certified cocoa, compared to uncertified cocoa, so self-reporting about their farmers’ compliance with certification standards for labour practices is problematic.

In 2025, the bigger concern with compliance and sustainability in cocoa is related to the coming enforcement of the European Union Deforestation Regulation (EUDR). Under these rules, due to be enforced from December 2025, cocoa and chocolate products imported into the EU must be proven to be deforestation-free, meaning the land used for cocoa production has not been deforested after 2020.

The importer must provide geolocation data, traceability to farm level, and comprehensive documentation at multiple points in the supply chain.

In West Africa, the major growing region, there are significant differences between the way beans are regulated and priced between the two largest producers, Cote d’Ivoire and Ghana.

Some cocoa farmers in Côte d’Ivoire sell their beans to traffickers who smuggle them out of the country to be resold in places such as Guinea and Liberia, where they can fetch a higher price than the government-mandated prices in their country. In 2024, 150,000 tonnes of Ivorian cocoa beans were said to have been illegally exported in this way.

Threats to forests

In 2024, a media outlet in France reported that rules and checks implemented by the Côte d’Ivoire government and designed to prevent deforestation had resulted in cocoa farmers leaving the country and setting up plantations in neighbouring Liberia instead.

Liberia, they say, has “an almost total lack of monitoring”, making it attractive for farmers who grow beans on newly deforested land there, before moving the beans back into Cote d’Ivoire to avoid traceability checks. Tens of thousands of cocoa farmers have reportedly crossed the border already, threatening thousands of hectares of virgin forest.

Chocolate and food fraud

With supply chains both complicated and threatened by multiple supply-demand imbalances and uncertainties, it’s no surprise that cocoa is extremely vulnerable to food fraud, with cocoa beans claimed to be organic, fair trade and ethically or sustainably sourced the most at-risk for fraud.

Fraud in cocoa beans can take the form of theft, smuggling, misrepresentation of fairtrade/rainforest status, false organic claims or misrepresentation of geographical origin; as well as simpler frauds such as adding rocks or sticks to bags of beans to increase their weight.

The EUDR, which includes significant traceability requirements and penalties for cocoa beans from recently deforested land, creates significant pressure on cocoa bean producers and traders to falsify bean origin and traceability data to make beans appear to have originated in non-deforested or ‘low-risk’ designated areas.

There is significant smuggling of cocoa beans between West African countries, due to price differences between countries, and this confounds traceability attempts.

In addition to fraud in cocoa beans, manufactured chocolate also has food fraud challenges.

Counterfeit chocolate – chocolate products packaged to look like premium brands but made without the permission of the brand owner – is perhaps the most commonly reported type of fraud in chocolate.

A notorious example of counterfeit chocolate is ‘Wonka’ bars, which periodically resurface in the United Kingdom. The Wonka brand is owned by Ferrero, which hasn’t sold Wonka chocolate bars in the United Kingdom for years.

The fake bars are produced or repackaged by unregistered businesses or individuals with no regard for hygiene or labeling regulations, making them potentially unsafe to eat, particularly for people with food allergies due to undeclared allergens. Incidents have included unhygienic manufacturing conditions, incorrect or missing ingredient lists, and the use of fake business addresses on packaging.

Dubai-style chocolate products have also been counterfeited, including some that had to be recalled due to the presence of undeclared peanuts, almonds, cashews, and walnuts.

Chocolate confectionery has been affected by counterfeit-style food fraud

 

Other frauds that have been unmasked include an ‘artisan’ producer in Italy who was allegedly buying industrially produced Easter chocolates, discarding the wrapping and then reselling them as ‘own production’ (i.e., artisanal); and smuggling operations.

In January 2025, a woman was caught in Germany with 460 bars of chocolate concealed in her luggage after an international flight. Customs officials suspect the chocolate bars were being imported for commercial sale, because of the large number of bars and because chocolate of that type had been made popular on TikTok, with each bar fetching around 25 euros.

The bars had no ingredient or allergen information on their packs, posing a health risk to consumers. If successful, the smuggling would have resulted in the woman evading more than 330 euros of import duties.

In February 2025, authorities in Europe discovered chocolate from the United Arab Emirates and Turkiye made with hydrogenated palm oil instead of cocoa fat, containing undeclared colourants and with a higher fat content than declared.

And in July 2025, Dubai-style chocolate from Turkiye was found to contain undeclared colourants (green mulberry leaf, brilliant blue FCF (E 133)) in Dubai chocolate.

It’s likely these frauds are just the tip of the iceberg. I estimate there are many instances of inauthentic claims made about artisanal and boutique chocolate products in wealthy countries. ‘Single origin’ chocolate, organic chocolate and fair trade chocolate products are moderately likely to be affected by inaccurate claims due to problems in their supply chains or intentional deception by the brand owner.

This article was originally published at The Rotten Apple – a weekly newsletter for food professionals

by

Food Safety Standards Compared (2025)

 

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 overarching 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, 2025  

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 materialsProducts and processesNot describedRaw materials,

Ingredients,

packaging,

outsourced processes

Raw materials,

Ingredients,

finished products

 

Food fraud typesEconomically motivated adulteration (only)Adulteration,

substitution

(only)

Any type where consumer health is at risk (in definition, Appendix A)Examples are provided and include: counterfeit plant protection products, unauthorized propagation material, origin of packaging and access to packaging.Substitution, mislabelling, adulteration, counterfeitingSubstitution, mislabelling, dilution,

counterfeiting

Vulnerability assessments explicitly required?A food fraud risk assessment is listed in Appendix AYesYesRisk 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)

YesYesImplied

(primary packaging is a ‘raw material’)

Is a separate food fraud procedure explicitly required?––Vulnerability assessment method and verification procedures must be documented (ISO 22002-100:2025)

 

–Implied

(“responsibilities shall be defined”)

Implied

(“methods and responsibilities shall be documented”)

Is training in food fraud explicitly mentioned? –“Knowledge” is required

(Clause 5.4.1)

Yes (in ISO 22002-100:2025)–Yes

(Clause 3.3.4)

Yes
Is an annual review explicitly mentioned?–YesYes (in ISO 22002-100:2025)–YesYes
Other–Horizon scanning for developing threats must be done (Clause 5.4.1)–Must consider ‘intentional inaccurate information’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:

AIB International Consolidated Standards for Inspection of Prerequisite and Food Safety Programs, 2023

BRCGS Global Standard Food Safety, Issue 9

FSSC 22000, Version 6

GlobalG.A.P. Integrated Farm Assurance (IFA), Version 6 GFS

IFS Food, Version 8

SQF Food Safety Code, Edition 9

Get a complete guide to all food fraud clauses in every standard, including human food, packaging, logistics and animal feed in our affordable e-book. Learn more.

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.

by

Olive Oil Fraud Update – Is the Crisis Over?

When it comes to fraud-vulnerable foods, olive oil is a rockstar.

When Food Fraud Advisors began in 2015, olive oil was considered one of the most fraud-affected foods on earth, with reports of fraud dating back to the first century AD.

And then things got worse – much worse – for olive production and fraud rates in olive oil skyrocketed.

Olive groves in some of Europe’s major growing areas were decimated by the bacterial disease Xylella fastidiosa, which infects the xylem of olive trees and other trees. The disease, which is native to the Americas, has a mortality rate of up to 100% in susceptible olive cultivars. It is spread by insects that feed on sap, such as the meadow spittlebug (Philaenus spumarius).

Since its discovery in Italy in 2013, more than 21 million olive trees have been destroyed by the disease in Southern Italy, devastating local olive oil production.

Puglia in Italy once produced half of Italy’s olive oil and was home to 60 million of olive trees, many of which were hundreds of years old but has lost 21 million trees to Xylella fastidiosa since 2013.

 

In addition to tree losses from Xylella fastidiosa, droughts and heatwaves in the 2022-2023 season affected key growing areas in Spain, the world’s largest producer, causing harvest volumes to plummet. Similar losses were experienced in Morocco, after annual production dropped to less than half of 2021 levels following two years of drought in the country.

However, things may finally be looking up for olive production and for olive oil. The olive oil industry has been predicting strong harvests and a return to more typical prices for oils since early 2025.

Wholesale commodity prices are currently at just 65 percent of their all-time high, which was reached in January 2024.

Wholesale commodity prices in July 2025 are just 65 percent of their all-time high in January 2024. Image: YCharts, with data from the International Monetary Fund (https://ycharts.com/indicators/olive_oil_price)

 

Frauds in olive oil include false claims about geographical origin, ‘extra virgin’ status and ‘organic’ (bio) status, counterfeiting of premium brands, theft of oil, theft of olives, clandestine manufacturing, blending with undeclared oils, replacement with other oils and addition of colourants.

 

The 2024 olive oil crisis

In 2024, I captured an unprecedented number of reports of olive oil fraud in public media, more than double any previous year since 2015. There were 15 incident reports in 2023 and more than double that number in 2024. In 2025, the numbers are trending back towards 2023 levels, with 7 incidents recorded in the first half of the year.

While an increased number of media reports does not necessarily mean more fraud, the fact that both wholesale and retail prices were very high in 2024, and significant enforcement operations were reported frequently, gives me confidence that the increased number of reports is a true reflection of more fraud activity.

 

An unscientific tally of food fraud incidents, 2015 – 2025, by the author, with the dotted region denoting an extrapolated count for 2025.

 

Note: the counts I’ve described are indicative at best because they only capture incidents and survey results that have been reported by mainstream media outlets or scientific journals, AND discovered by me and my software systems during my weekly searches for food fraud intelligence.

Did we see the crisis coming?

In 2022, olive oil was predicted to become 25 percent more expensive due to droughts in the main olive-growing areas of Europe. However, the predictions fell short and prices rose by significantly more than that, more than doubling between 2022 and 2024.

In October 2023, I warned that due to the shortage of olives in Europe, non-European-grown oils could be fraudulently misrepresented as European oils.

Olives in Europe became so expensive and scarce in 2023 and 2024 that criminals were chainsawing off fruit-laden branches of olive trees, and even taking whole olive trees from orchards by night. Some growers resorted to microchipping their trees in response to the spate of thefts.

Spanish law enforcement agencies responded to the crisis by undertaking 300 different operations in olive growing areas in 2023, stopping vehicles full of stolen fruit, raiding oil mills, and arresting mill operators who were processing stolen fruit.

In Greece, the government warned consumers of increased fraud risks and recommended they only buy oil from reputable vendors.

Is the crisis over?

The most recent European harvest was strong, 12% higher than the five-year average, due to favourable growing conditions in key European growing regions.

In Spain, which accounts for 50 percent of global olive oil production, the most recent crop was almost double what was grown in the 2022-2023 season.

Wholesale prices began falling for consumer olive oils earlier this year and a spokesperson for a major Spanish olive oil supplier said in February 2025 that the price drops could be expected to reach supermarket shelves with a three-month lag.

While various pests and diseases are still a risk to olive trees that are stressed by climate change, Xylella fastidiosa is currently contained in Europe. The European Commission has declared the outbreak in Puglia closed.

Portuguese and Spanish outbreaks are similarly declared over, while in Corsica (France) the disease is considered to be contained. Countries continue to monitor for the presence of the disease.

The Xylella fastidiosa containment zone of Puglia, Italy, depicted in orange. The buffer zone (zona cuscinetto) is blue. Source: European Commission (https://food.ec.europa.eu/plants/plant-health-and-biosecurity/plant-health-rules/control-measures/xylella-fastidiosa/latest-developments-xylella-fastidiosa-eu-territory_en)

 

Unexpectedly, some groves that were thought to have been completely destroyed by Xylella fastidiosa have recovered, with a complete restoration of the crown of trees observed in 2024 in some areas of Italy, even among susceptible cultivars. The recovery phenomenon has been observed in young, old and even centennial groves, with some trees once again yielding commercial quantities of fruit.

In the past year, Greek production has rebounded significantly, with the most recent harvest almost double that of the previous year, which was the worst many had seen.

“Last year’s [Greek growing season] was probably the worst period I’ve seen in 20 years,” Prokopios Magiatis, olive production scientist at the University of Athens, who says this year is significantly better.

But the longer-term outlook remains challenging due to our rapidly warming climate.

In Greece, 130,000 olive trees were lost to fires in Evros in 2023, and wildfire burned 11,000 acres of olive orchards in 2024.

Climate change is causing rains to fall at the wrong time of year, leaving the trees with little moisture during winter. Warm winters also cause havoc with the trees’ reproductive cycles – if the nights do not get cold enough, the trees don’t enter the winter dormancy that helps them prepare for the following season.

In 2023, the European Union’s largest wildfire on record burnt olive groves near Alexandroupolis, Greece. Photo: Konstantinos Tsakalidis (via The Greek Herald,https://greekherald.com.au/news/greece-wildfires-burn-60-percent-of-evros-olive-groves/)

 

So, although some industry sources report things are looking up for olive production in Europe in 2025, other sources say extreme heat during flowering and the first fruit set period has already imperiled next season’s crop in some parts of Spain. The Andalusian region of Spain is predicted to have a small harvest for 2025-2026, due to heavy pest pressure, including praying olive blight.

And although Turkiye’s olive industry had a bumper season in 2024-2025, this year’s harvest is predicted to be just 60% of last year’s.

What about olive oil’s food fraud vulnerability?

As supplies of oil improve and prices ease, the motivating factors behind food fraud decrease – or to put it another way, when olives and their oils are not outrageously expensive, it’s less profitable for criminals to fake them, steal them and engage in illegal trading.

An increased focus by authorities in Spain and Italy has likely also caused some criminals to think twice about olive oil crime. In the coming months, I’m expecting to see many more reports of convictions and sentencing for crimes committed in 2021 and 2022, as investigations are brought before the courts in Europe.

In June 2025, four people were sentenced to prison in Spain for their roles in a multi-year-long fraud in which low-quality oils and sunflower oils were sold as extra virgin and organic olive oils, using a false geographical origin in the brand name. The crimes were discovered in 2021.

But while things are probably going to be slightly less crazy for olive oil fraud in the second half of this year and into 2026, I still consider olive oil to be particularly vulnerable to food fraud, because there has been no change to the characteristics that have made it a target since the earliest days of agriculture.

The oil is valuable, has multiple grades and variations that are difficult for most consumers to differentiate, carries significant price premiums for organic versions and certain provenances, and has a relatively short shelf life compared to other edible oils. Its liquid form makes it easy to dilute with cheaper oils, with the large price differential making such dilutions very profitable and the addition of colourants making it hard to detect without expensive analytical tests.

There is also a large pool of independent eateries and grocers in Europe which are sometimes willing to purchase from informal supply chains. Together, these characteristics make olive oil particularly vulnerable to food fraud.

Takeaways for food professionals and consumers

If you or your business purchases olive oil, limit your risk of purchasing fraud-affected oil by:

  • purchasing from reputable vendors and authorised stockists – avoid online stores, markets, street vendors, small independent outlets and anonymous sellers which are more likely to sell counterfeits and products from unauthorised or grey market sources;
  • purchasing premium brands, which are more likely to tightly control their supply chains;
  • paying attention to the taste and aroma of the oil and informing the vendor of any defects.

In short: 🍏 Olive oil has been vulnerable to food fraud since ancient times 🍏 Experts have been warning of impending supply problems for olive oil due to the climate crisis since 2016 🍏 Tree diseases decimated harvests in major olive growing regions, and drought also had a severe impact on the 2022-2023 harvest, precipitating huge price increases for olive oils in 2023 and 2024 🍏 Reports of olive oil fraud were significantly more numerous in 2023 and 2024 compared to previous years 🍏 Harvests have recovered somewhat, although threats from climate change remain 🍏 Fraud activity and the number of reports of fraud in olive oil is expected to be significantly lower in 2025 compared to 2024, however olive oil remains highly vulnerable to food fraud 🍏

Sources: Links to all sources are hyperlinked within the text.

🔹 Many of the sources used for this article were discovered using iComplai’s AI-powered food fraud risk prediction system 🔹

This post originally appeared in The Rotten Apple.

by

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

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

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

Members should be trained in food fraud awareness.

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

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

Agenda items for food fraud team meetings

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

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

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

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

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

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

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

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

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

 

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