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Is food fraud to blame for the cinnamon-apple recall?

In October 2023, cinnamon fruit puree baby foods were recalled in the United States after four children were found to have elevated levels of lead in their blood.  Multiple lots of the products were found to have “extremely high” concentrations of lead.

As of 5th December, the number of affected children had increased to at least 64.  The source of the lead appears to be the cinnamon used in the purees, with non-cinnamon variants unaffected.

Could this be a food fraud incident?

The amount of lead in one sample of fruit puree was 2 parts per million (ppm), which is more than 200 times the maximum level proposed by the FDA in their draft guidance for fruit purees intended for babies and young children.

Because cinnamon is used at low concentrations in fruit purees, for the finished product to contain 2 ppm of lead, the cinnamon itself must have contained very high levels of lead.  For example, if the finished product contains less than 1% of cinnamon, the contaminated cinnamon would have to contain more than 200 ppm of lead.

That’s one hundred times more concentrated than usual: cinnamon typically contains just 2 ppm of lead (Hore, et. al (2019)).

Cinnamon adulteration

Cinnamon can become accidentally contaminated with lead in various ways.

Cinnamon trees, from which the spice is made, can absorb lead from the soil as they grow.  Cinnamon can also become contaminated with lead through contact with machinery or transport vehicles that have lead-containing alloys, solders or paints, or lead-containing environmental dust and dirt.

However, accidental contamination usually results in low levels of contamination.  In this current recall, the amount of lead in the cinnamon is likely to be much higher than usual; perhaps more than 100 times more.  At the time of writing, the actual levels are not known.  The US FDA says “sample collection is underway”.

Many food safety commentators are openly discussing the possibility that the cinnamon was deliberately tampered with, for economic gain (food fraud) or perhaps to intentionally cause harm (food defense).

Precedents

Lead-based pigments in spices have caused harm to children in the past. Lead-chromate adulterated turmeric caused children in the USA to be poisoned in 2010 – 2014. Paprika adulterated with lead oxide caused the hospitalisation of more than 50 people in Hungary in 1994.

A sample of the Georgian spice kviteli kvavili, also known as yellow flower or Georgian saffron, was discovered to contain 48,000 ppm of lead in a NYC Department of Health and Mental Hygiene (DOHMH) lead-in-foods survey. In the same survey, which assessed more than 3,000 food samples over ten years, nineteen cinnamon samples had a median lead level of 2 ppm, with the highest level in cinnamon being 880 ppm.

That’s right: one sample of cinnamon in the NYC survey contained 880 ppm, more than four hundred times higher than ‘normal’, and enough to result in dangerously high levels of lead in any food to which it was added.

Mean lead concentrations in various spice samples: cumin, red chili, turmeric, coriander powder. The line at 2.5 mg/kg (ppm) is the allowable limit in Bangladesh. Source: Alam et al (2023)

 

Why adulterate cinnamon with lead?

Lead pigments and powders are used by food fraud perpetrators to enhance the colors of spices.  The most well-studied example of this is the use of lead chromate in turmeric.

🍏 Read how traders in Bangladesh were using lead chromate to color the turmeric roots they were selling (and what made them stop) 🍏

In addition, because lead is a heavy metal, it is literally heavy.  Spices are traded by weight, so adding lead increases their weight and therefore the price.

Deliberately adding lead to spices is, unfortunately, a common food fraud practice.  The intention is to make more money for the perpetrator.

While some food adulteration actions are intended to cause harm for malicious purposes, lead adulteration does not lend itself to intentionally harmful adulteration.  Such adulteration is perpetrated to create a high impact on consumers or companies, but lead poisoning is slow-acting and can take months or years to be identified, minimising the potential for a high-impact incident.

If the cinnamon has been intentionally adulterated with lead, it was likely done for economic gain (food fraud), rather than for malicious purposes.

Takeaways for food professionals

⚠Warning! ⚠ If the cinnamon used to make the recalled products was from a larger batch, more products are likely to be affected, and more recalls can be expected.

If your company uses cinnamon, consider testing it for heavy metals including lead.

⚠⚠⚠⚠⚠

More details about the recall can be found here: Investigation into elevated lead levels in cinnamon-applesauce pouches (US FDA)

This post originally appeared in The Rotten Apple, a weekly newsletter for food professionals, by Karen Constable

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Olive Crisis (Fraud Warning)

The world’s olive crisis is hitting supply chains hard and fraud is rampant.

First it was the disease Xylella fastidiosa, which decimated olive groves across parts of Europe. Then came a drought in key growing areas of Europe. Production is down, and crime is up.

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.

 

Olive oil is one of the most fraud-affected food products on earth, with reports dating back to the first century. The ancient historian Aelius Galenus described how merchants would dilute expensive olive oils with cheaper ingredients to increase their profits. A fifth-century Roman cookbook describes how to make cheap Spanish oil resemble expensive Italian oil by adding minced herbs and roots.

Since I began collecting food fraud stories in 2015, olive oil adulteration and misrepresentation have featured often, but in the past few months, the number of incidents has increased noticeably. And these days, it’s not just oil, other olive products are also at risk of food fraud.

I first started collecting information about threats to olive oil supplies in 2016, writing that olive growers were having trouble with pests and diseases, including Xylella fastidiosa, in Italy, Greece and Spain.  In 2016, experts were predicting price rises for olives and olive oils in Europe, the United Kingdom and America because of risks to harvests from the disease.

One area hit hard by the disease was the Italian region of Puglia, which used to produce 50 percent of Italy’s olive oil. Xylella fastidiosa appeared in the region in 2013, and 21 million trees were lost to it within a few years.

Less high-quality Italian olive oil meant more motivation for fraud, and the criminals responded.

In 2017, a survey of more than three hundred thousand litres of olive oil, conducted over two years in Brazil found 64% of 279 samples were substandard, with some products containing 85% soybean oil.

Since then, the number of food fraud incidents for olive oil appears to have grown, with a startingly high number this year. Among the food fraud reports that I have seen and collected for the Trello-hosted Food Fraud Risk Information Database and The Rotten Apple, this year’s tally stands at more than triple the ‘usual’ annual count.

From 2015 to 2021 there were zero to four reports of olive oil fraud in international media per year. In 2022, that number climbed to six. This year I have counted fifteen.

An unscientific tally of food fraud incidents and survey results, 2015 – 2023, by the author

 

It’s worth noting that this tally is indicative at best because it only captures incidents and survey results which are reported by mainstream media outlets or scientific journals AND discovered by me and my software during my searches for food fraud intelligence.

Olive fraud in 2023

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 have risen by significantly more than 25 percent.

Olives are becoming so expensive and scarce that criminals are chainsawing off fruit-laden branches of olive trees, and even taking whole olive trees from ochards by night in Europe. Some growers are even microchipping their trees in response to the thefts.

Last month, Bloomberg reported that European retail prices have doubled in the past year, and that EU exports of olive oil are expected to be lower by 10 percent.

In 2023 I have recorded a total of fifteen incidents and survey results from countries including Spain, Canada, Italy, Greece, Morroco, Brazil and Portugal. The fraud types included clandestine manufacture, marketing irregularities, theft of oil, theft of olives, labelling irregularities, blending with undeclared oils and mislabelling of the grade of oil.

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

Today’s food fraud news contains warnings about Moroccan olive oils, which are now subject to export restrictions to protect domestic supplies, after annual production dropped to less than half of 2021 levels following two years of drought in the country.

On the other side of the world, Brazillian authorities are closing down clandestine manufacturing sites, while Spanish law enforcement agencies have undertaken 300 different operations in olive growing areas, stopping vehicles full of stolen fruit, raiding oil mills and arresting mill operators who are processing stolen fruit. In Greece, the government is warning consumers of increased fraud risks and recommending they only buy their oil from reputable vendors.

Takeaways for food professionals

If you or your business purchase 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;
  • considering sourcing oil from non-European growing regions, which may be less affected by scarcity and price increases;
  • 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 the beginning of recorded history 🍏 Experts have been warning of impending supply problems and price rises for olive oil since 2016 🍏 Tree diseases have decimated harvests in many major olive growing regions, and drought is also having a severe impact 🍏 Prices have increased significantly, for both olives and olive oil 🍏 Fraud activities in olives and olive oil appear significantly more numerous in 2023 compared to past years 🍏

Sources:

Mueller, T. (2007). Italy’s Great Olive-Oil Scam. The New Yorker. Available at: https://www.newyorker.com/magazine/2007/08/13/slippery-business

‌Ministério da Agricultura e Pecuária. (n.d.). Inspeção do Ministério da Agricultura identifica 45 marcas de azeite fraudados. Available at: https://www.gov.br/agricultura/pt-br/assuntos/noticias/mapa-identifica-45-marcas-de-azeite-fraudados

Olive Oil Times. (2022). Reimagining the Xylella-Devastated Landscape of Southern Puglia. [online] Available at: https://www.oliveoiltimes.com/business/reimagining-the-xylella-devastated-landscape-of-southern-puglia/114128

‌Petroni, A. (n.d.). The plan to save Italy’s dying olive trees with dogs. [online] www.bbc.com. Available at: https://www.bbc.com/future/article/20230111-the-super-sniffer-dogs-saving-italys-dying-olive-trees.

‌Food Fraud Advisors Food Fraud Risk Information Database: Olive Oil. Available at: https://trello.com/c/GHwJnQGp/369-olive-oil

 

This post originally appeared in The Rotten Apple.

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It’s Time to Stop Underestimating the Scope of Food Fraud

Food fraud affects many more products than consumers know, and not just premium foods like honey and fine wines. It occurs in all parts of the food chain, including commodities such as grains and oils, animal feeds, fruit and bulk ingredients. 

by Karen Constable

This story was originally published by Modern Farmer.

Food fraud has been happening since humans first began to buy and sell food, thousands of years ago. Early Romans faked premium wines and added lead salts to sweeten their drinks, while medieval bakers added chalk and dust to their loaves because it was cheaper than flour.

Modern food systems are built on regulations born of the need to prevent deceptive practices like these. But modern food systems are still riddled with fraud. And yet, food fraud stories in the mainstream media consistently underestimate the breadth and scope of fraud in modern food supply chains. 

Most food fraud stories focus on premium foods such as maple syrup, wasabi, vanilla, caviar and truffles. But while these foods are at risk from food fraud, they make up only a tiny percentage of the foods we eat each day. 

Food fraud affects much more than high-cost foods such as honey and whiskey. It occurs in all parts of the food chain, including commodities such as grains and oils, animal feeds, fruit and bulk ingredients. 

 What is food fraud?

When people use deceptive tactics to make extra profits from food, the result is food fraud. The deception can be perpetrated on an enormous scale, affecting hundreds of shipments of material across multiple years. Or it can be opportunistic, such as forging an organic declaration for a single delivery of oilseeds.

Food fraud can net millions of dollars for the perpetrator and costs the global food industry $40 billion per year. 

Food fraud in bulk ingredients and animal feed

When fraud occurs in raw materials or inputs to the supply chain, huge quantities of food are affected, such as a massive fraud that occurred in organic grains used for animal feed. 

Food fraud affects ingredients and bulk food commodities like grains, as well as high priced consumer products

 

In 2019, a Missouri man was sentenced to more than 10 years in prison after being caught selling more than 10 million bushels of “fake” organic grain worth millions of dollars over a period of seven years. The man told customers he had grown the grain on his certified organic fields when it was non-organic grain that had been grown elsewhere. At other times, he sold grain from “organic” fields that had been sprayed with unauthorized chemicals and mixed non-organic grain into shipments of organic grain to increase profits. 

Most of the affected grain was purchased for animal feed for raising organic meat. Because the grain was not organic, the resulting meat was also not genuinely organic. In this way, the fraud was propagated along the supply chain, from grain trader to animal feed supplier to rancher to slaughterhouse to meat supplier and finally to millions of unsuspecting consumers. 

Cheaper bulk food ingredients are also affected by fraud. Thousands of tons of dried milk powder was adulterated in a massive fraud that led to illnesses in more than 300,000 infants who drank formula made from the milk powder. The fraud had been going on for years, undetected by authorities. 

The milk powder was adulterated with melamine, a poisonous chemical with a high nitrogen content, a whiteish color and a neutral taste. When added to milk powder or wheat gluten, it boosts the apparent protein content of the food in laboratory tests, thereby increasing the amount of money a seller can earn per pound. 

The same thing happened to ingredients used for pet foods. Wheat gluten was adulterated with melamine in 2006 and 2007, with at least 800 tons affected across dozens of shipments. The gluten was used as an ingredient by multiple pet food manufacturers in many brands of dog and cat food, killing an estimated 4,500 pets across the US. 

Different foods, different frauds

Food fraud affects every type of agricultural commodity, including fresh produce, edible oils and tree nuts. Fresh fruit might not seem like a lucrative target for food fraud, but it is vulnerable to counterfeiting, with exporters of some brands of fruit having to compete with unauthorized copies of their own products in importing countries. 

To combat this, Tasmanian cherry growers employ a range of overt and covert anti-counterfeit systems, including intricate, laser-cut carton stickers, custom-printed carton liners, watermarked carton bases and QR codes; while New Zealand kiwifruit growers have experimented with invisible “watermarks” that can be printed onto fruit skins with special food-grade chemicals.

Expensive oils and cheap oils are equally likely to be fraud-affected. Expensive oils such as hazelnut and coconut oil can be diluted with cheaper oils to increase profits for the seller. A recent survey of avocado oils found almost 60 percent did not meet purity criteria, with tests revealing they had been adulterated with sunflower and other oils. 

Speciality oils fetch high prices and can be vulnerable to economically motivated food fraud.

 

Cheap bulk oils such as palm oil can be fraud affected, too. Palm oils are considered to be environmentally unfriendly because their production can cause deforestation, so there is plenty of motivation for fraud perpetrators to make false claims about where and how they were grown or sourced. Soy and canola oils can be falsely claimed to be organic or non-GMO if they were made from GMO crops. This can even happen without the knowledge of the oil mill, which might have been deceived about the GMO status of incoming oilseeds. 

Tree nuts are popular targets for theft, because they keep for a long time and are difficult to trace when sold in bulk by thieves. A single trailer load of pistachios can be worth hundreds of thousands of dollars, netting any thief a tidy profit when he sells them on to legitimate food traders. Food and beverage thefts are now the top cargo crime in the US, with strategic, organized thefts of food shipments increasing by 600 percent between 2022 and 2023. 

Food fraud is pervasive across all parts of the supply chain, from basic agricultural commodities to bulk ingredients used for manufactured foods and through to finished grocery items in every category. 

The Grocery Manufacturer’s Association estimates that at least 10 percent of all retail food has been affected by food fraud in some way by the time it gets into your shopping cart. The real proportion is probably even higher than 10 percent. 

We must stop thinking of food fraud as something that only affects high-priced luxury foods. It takes many forms and can appear in even the cheapest food ingredients and finished products.

What must be done?

Food fraud can only be tackled by the combined efforts of all parts of the food industry. Regulations and rules prohibit food traders and suppliers from selling fraud-affected foods, but laws are ineffective on their own. Enforcement against food fraud is low on food agencies’ priorities, which rightly focus on more pressing issues such as protecting consumers from foodborne illnesses. 

In 2023, the food industry still underestimates how prevalent food fraud is and how many different food types are affected. Purchasers of ingredients and commodities such as grains and oils still rely solely on certificates that can be forged, laboratory tests or that can be faked and letters of guarantee that are not worth the paper on which they are printed. 

All actors in the food supply chain, from growers and packing houses to oil mills, animal feed suppliers, food manufacturers, restaurants and retailers, must do a better job of holding their suppliers to account. That means doing more to check the authenticity of the food, commodities and ingredients they use, instead of relying on the word of the supplier. 

Consumers are, for the most part, at the mercy of the food industry, with no way of telling whether any item in their grocery cart is affected by fraud or not. That is why people in the food supply chain must become a little less trusting of their suppliers and a little more careful about checking for food fraud in the materials they purchase. With a little more effort and a little less blind faith, the industry can together keep everyone safe from food fraud.

Karen Constable is an international food fraud prevention expert, owner of Food Fraud Advisors consultancy and founder of 🍏The Rotten Apple🍏, a weekly update on food fraud, food safety and sustainable supply chains for busy professionals.

Modern Farmer is a nonprofit initiative dedicated to raising awareness and catalyzing action at the intersection of food, agriculture, and society. Read more at Modern Farmer.”

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Food Fraud in Fruit and Vegetables

How does food fraud show up in fresh fruit and veg?

Adulteration-type fraud is rare in whole fresh fruits and vegetables because they have recognisable forms.  However, in developing countries, there have been reports of fruits and vegetables dyed with illegal colourants to improve their apparent value.  Processed fruits and vegetables such as pickles are sometimes adulterated with unauthorised or undeclared colourants.

Other types of fraud, including organic fraud, misrepresentation of origin and counterfeiting also occur in fruits and vegetables.

Theft affects fruit and veg, and it is sometimes smuggled across borders to evade inspections or taxes.  An unusual type of fraud, which involves the infringement of intellectual property rights for proprietary fruit varieties has been reported in Egyptian table grapes recently.

Counterfeiting of premium brands of fruit is said to occur frequently in China. Cheaper fruit is packaged into containers that are labelled to look like premium brands without the authority of the brand owner. Australian cherries, New Zealand kiwifruit and Dole-branded products from the Americas have been affected.

In developing countries, fruits such as mangoes are sometimes ripened using unauthorised practices, such as by treating with calcium carbide, ethephon and oxytocin chemicals. The use of such ripening agents is usually illegal and can be harmful to human health.

The outlook for food fraud in fruit and vegetables

Production is at risk from climate change and prices are affected by extreme weather events, which are becoming more frequent with climate change. Extreme weather events can lead to unexpected supply and demand patterns which can increase motivations for fraud perpetrators.  Large differences in prices between conventionally grown and organic produce can increase the likelihood of organic fraud. Large differences between prices in different countries can encourage smuggling and misrepresentation of origin.

Examples of food fraud in fruit and vegetables

Smuggled watermelons:  Authorities stopped a vehicle carrying 25 tons of illicit watermelons worth $40 million in Chile in August 2023.  The fruit had been smuggled into the country from Peru without the correct biosecurity measures.  An official explained the watermelons were being illegally imported because they were out of season and so were double their usual price (source).

Stolen potatoes:  Routine checks by Italian agri-food officers in April 2023 discovered 16 tons of potatoes which did not have correct documents as to their origin, which is a requirement under European law. The owners of the potatoes were fined (source).

Image by Freepik

Unauthorised grapes: A 16 ton container load of grapes was seized and destroyed at a port in Italy in July 2023, as they were being imported from Egypt.  The grapes were of the ‘Early Sweet’ variety, a proprietary variety that may only be produced under licence.  The owner of the variety’s intellectual property said the grapes were grown in Egypt and were labelled as a different grape variety.  The mislabelling would have allowed the grapes to be imported.  The identity of the grape variety was confirmed with DNA testing.  The intellectual property owner said that this was the fourth container load to be destroyed because of illegal trade in proprietary varieties of fruit in “recent years” (source).

Well-travelled raspberries:  In 2019, a large shipment of non-organic, Chinese-grown raspberries worth $12m was caught by Chilean customs agents as it was being exported from Chile to Canada.  They were labelled Chilean and Organic, claims that were both false (source).

Counterfeit fruits: In 2017 and 2018, nearly 1.1m pieces of fruit were revealed to have been falsely labelled with premium brands such as Dole, Zespri and Sunkist in China.  Thirteen people were prosecuted for their roles in the scam (source).

How to protect yourself from fruit and veg fraud

Food businesses should be aware that food fraud can affect fruit and veg in various ways, with misrepresentation of organic status and origin being the most likely types of fraud in wealthy countries.  Be vigilant to false claims, and verify any claims made by suppliers wherever possible.  Check that organic certificates are valid with the certifying body.  Purchase produce from trusted wholesalers, and avoid purchasing from ‘the back of the truck’.

Consumers should take care when purchasing ‘organic’ fruit from markets and independent grocers, which are more likely to have organic-fraud-affected wares than large retailers which have more robust systems to prevent fraud.  In developing countries, avoid fresh produce that has unnaturally bright colours or is ripe outside its normal season.

Click here to learn more about food fraud

 

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Fraud in Botanical Products and Dietary Supplements

Fraud in dietary supplements and herbal medicines is dangerous and costly

 

Fraud is estimated to affect around 10% of food products and dietary supplements are almost certainly affected at levels of at least 10% as well.

Supplement fraud surfaces often in my food fraud searches. Food supplements and additives were the second most seized food type, by quantity, after alcoholic beverages in Interpol’s annual food fraud operation, Operation Opson X in 2021.

Just last month, I shared the stories of how two supplement brands were working to prevent online counterfeits of their products after finding fake versions of their products in the market.

In May, NOW Foods explained how to spot fake versions of their supplements on their website

Fraud in supplements comes in at least eight different ‘flavours’

(1) Fraudulent, misleading or unsubstantiated claims of efficacy. For example, glucosamine, a supplement marketed as effective for reducing osteoarthritis, may work no better than a placebo. In fact, one study was halted because the group taking glucosamine reported worse joint pain than the placebo group! (source)

(2) False claims of potency and purity, such as listing more active ingredient on the label than is actually in the product. For example, a survey of curcumin supplements in France in 2022 found that less than half of the products contained as much active ingredient as was declared on the label. (source)

(3) The addition of materials to trick analytical tests, making an ingredient seem authentic when it is not. For example, pigments from black rice added to elderberry to boost the amount of anthocyanins (source);

(4) The use of undeclared fillers and bulking agents. This is sometimes legitimate and sometimes fraudulent, depending on the filler, product labelling and regulations.

(5) Adulteration with undeclared pharmacological ingredients such as sildenafil (Viagara) and stimulants. Weight loss products and sexual function products are most often affected. For example, a pre-workout booster supplement from the USA was found to contain DMBA by German authorities earlier this year. DMBA is a stimulant that is an unauthorised substance in Germany (source).

(6) Misrepresentation of synthetic ingredients as ‘natural’. For example, 70% of “all-natural” turmeric extract supplements purchased in the USA in 2021 contained curcumins from non-natural sources (source).

(7) Addition of unsafe or unauthorised colourants. For example, powdered turmeric is adulterated with unsafe colourants lead chromate, metanil yellow, acid orange 7 and Sudan Red G (source).

(8) Counterfeiting, in which an entity that is not the brand owner creates and sells products that resemble the brand’s products. For example, a review of supplements that contained insufficient active ingredients found that most of them carried ‘fake’ barcodes, that either belonged to fictitious, unregistered companies or to companies that do not supply supplements (source). In Hungary, forty percent of young people reported that they had encountered counterfeit dietary supplements (source).

Fraud in Botanicals

A ‘botanical’ is a part of a plant, extract or essential oil that is traded for its therapeutic properties, flavour(s), or aroma(s)

If you want to know about fraud in botanical ingredients like herbs and complementary medicines, there is a fabulous resource provided by the American Botanical Council’s Botanical Adulterants Prevention Bulletins (BAPP bulletins).

Each Botanical Adulterants Prevention Program (BAPP) bulletin provides detailed information about a single material. Take the saffron bulletin, for example. It is seventeen closely written pages about saffron, its adulteration and the detection of such, including the molecular structure of its most important chemical compounds, its common name in a multitude of languages, its geographical distribution, the size of the market and, most importantly, a deep dive into the known adulterants for saffron and the methods for detecting them.

The Botanical Adulterants Prevention Bulletins are seriously detailed. This is an extract from the Saffron bulletin.

Fighting Adulteration in Botanicals

Earlier this year, the team behind the BAPP bulletins published an ambitious paper that sought to combine all the knowledge from all the previously published bulletins into a single, peer-reviewed journal article, in the Journal of Natural Products.

It is a truly remarkable article, with thousands of words of detailed information about every reasonably foreseeable adulterant for dozens of botanical ingredients used in complementary medicines, food supplements, functional foods, and cosmetics.

I was delighted to get a chance to talk with its lead author, and Director of BAPP, Stefan Gafner, PhD about the paper and the program last month.

KC: Is the BAPP an independent program? How is it funded?

SG: BAPP is funded by direct financial support, predominantly from industry sponsor members of the American Botanical Council. Memberships and endorsements for the ABC come from not just manufacturers and suppliers but from analytical laboratories, law firms, research centres and media companies from about 80 countries worldwide.

KC: Can you tell me about your recently published Botanical Ingredients Forensics paper: why did you create it and who was it made for? What do you hope it will be used for?

SG: The inspiration for the paper was to combine the knowledge from multiple past [BAPP] bulletins so that all the information is in one place. We wanted to make the knowledge more accessible to a larger audience. The main target is QC people in industry labs.

The paper discusses three main adulteration types and how to test for them in dozens of botanicals:

  • Bulking agents, such as undeclared starches or fillers;
  • Addition of extra marker compounds to trick the analytical tests, such as pigments from black rice added to elder berry to boost the amount of anthocyanins;
  • Removal of valuable constituents, such as ginger or cinnamon with the essential oils removed before being ground up and sold as ginger powder or cinnamon powder.
Three classes of fraud in botanicals: fillers, undeclared marker compounds, removal of valuable components

KC: Do you worry (like I do) that sharing too much information about adulteration and adulterants that can evade detection is helpful to the bad guys?

SG: I am concerned that BAPP work may provide some information on adulteration to bad actors. Some people tell me that I help unethical people learn how to adulterate, rather than how to prevent adulteration. But there are other ways for fraudsters to figure it out since most of the information we summarise is already publicly available. However, there is a risk that some of the less sophisticated adulterators could become more sophisticated; that’s my main concern.

I know that some of our documents have been translated into other languages, and I’ve been told they are available in Chinese via WeChat so I can imagine that other countries may have that information and may try to see how to get around [the tests].

But we know the BAPP information is making a positive impact. When we surveyed ABC members and asked if they had changed their quality control procedures, specifications or suppliers based on the information provided in BAPP, twenty to thirty percent said “Yes”, they did change specifications or suppliers based on the information, so the program has had a very good impact [in preventing fraud].

KC: How much fraud is occurring in botanical ingredients every day?

SG: We don’t know. There are too many unknowns. No one has done a comprehensive analysis of the market. While it is possible to summarise results from various papers there are many potential confounders. For example, you do end up counting duplicate samples this way and the sampling is often not designed to have been representative of the geographic market.

However, there have been two papers that attempted to get these figures, and came up with approximately 25% of samples being adulterated based on DNA with similar results for chemical analyses*. However, it is very variable between different products. For example, Gingko leaf extract could have an adulteration rate as high as 57% (this is from soon-to-be-published research reviewing tests of 533 samples).

Europe and North America had very similar results in the Gingko study, about 60% [of samples adulterated] for both.

We think there is less fraud in Europe in regulated herbal medicines, compared to food supplements which are less regulated.

KC: Wow so fraud in botanicals is a pretty big problem. How does the food supplement industry cope with fraud in botanical ingredients?

SG: Reputable suppliers are doing a good job of mitigating fraud. They know their own supply chain well, and some even grow their own ingredients. That is, they have vertically integrated supply chains. For example, during my time at Tom’s of Maine, a significant portion of the herbal ingredients, including echinacea, chamomile, thyme and calendula were grown at its farms in Vermont, USA.

Ingredient suppliers that grow their own botanicals are also less likely to supply fraudulent materials to their customers. Being vertically integrated obviously has its benefits.

However, there is more fraud when the supply chain is less well-controlled. An example is liquorice root, which is typically grown in small quantities on individual farms in China and India, and sold on to intermediate persons, aggregators and traders who grade and blend the root from all different places. This makes it impossible to really ‘map’ the supply chain or keep control of the quality or authenticity.

Another big problem is that consumers in the USA have been taught to expect to pay prices that are too low for quality herbal products. American consumers think about some herbal extracts like a medication like paracetamol (‘Tylenol’) or ibuprofen… they think it’s all the same and so it’s fine to just buy the cheapest. However, not all Echinaceas are the same. That is one of the biggest issues we have at the moment. The high-quality herbal supplements are usually more expensive.

KC: Are you seeing any new and worrying trends in fraud in botanicals? Any good news?

SG: The good news is the BAPP program has gained good support in its twelve years, with a substantial percentage of industry now supporting it, including from Europe, Asia and Australasia. The program is having real impact.

My biggest concern is the spiking of supplements with prescription drugs, followed by fortification with marker constituents, for example, ellagic acid added to pomegranate peel extracts (Punica granatum, Lythraceae) and synthetic curcumin used in place of genuine turmeric extract.

A new vulnerability is the increasing popularity of products containing mixtures of botanicals, say six or seven ingredients. These can include ingredients that are only present in sub-therapeutic doses, and that contain excipients instead of adequate levels of the labelled botanicals.

KC: Thank you Stefan, that was a fascinating insight into the industry and the important work you do to prevent adulteration in botanicals.

🍏🍏🍏🍏🍏

*Ichim, M.C. (2019). The DNA-Based Authentication of Commercial Herbal Products Reveals Their Globally Widespread Adulteration. Frontiers in Pharmacology, [online] 10. doi: https://doi.org/10.3389/fphar.2019.01227 and Ichim, M.C. and Booker, A. (2021). Chemical Authentication of Botanical Ingredients: A Review of Commercial Herbal Products. Frontiers in Pharmacology, 12. doi: https://doi.org/10.3389/fphar.2021.666850.

Main source:

Gafner, S., Blumenthal, M., Foster, S., Cardellina, J.H., Khan, I.A. and Upton, R. (2023). Botanical Ingredient Forensics: Detection of Attempts to Deceive Commonly Used Analytical Methods for Authenticating Herbal Dietary and Food Ingredients and Supplements. Journal of Natural Products. doi: https://doi.org/10.1021/acs.jnatprod.2c00929.

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HACCP, VACCP and TACCP

What do HACCP, VACCP and TACCP mean?

They are acronyms used in food safety.

HACCP has been around for decades, VACCP and TACCP were introduced in the 2010s.

VACCP and TACCP are no longer used by most food safety experts, and have been superseded by ‘food fraud programs’ and ‘food defense plans’.

 

What does HACCP stand for?

  • HACCP (Hazard Analysis Critical Control Point)  Pronounced ‘hassup’.  HACCP = keeping food safe from accidental and natural risks to food safety.

What does VACCP stand for?

  • VACCP (Vulnerability Assessment Critical Control Point) Pronounced ‘vassup’.  VACCP = prevention of food fraud.  Has been superseded by ‘food fraud prevention’.

What does TACCP stand for?

  • TACCP (Threat Assessment Critical Control Point) Pronounced ‘tassup’.  TACCP = prevention of malicious threats to food, such as sabotage, extortion or terrorism, sometimes called Intentional Adulteration within the US Food Safety Modernization Act.  Has been superseded by ‘food defense’.

What is HACCP?

  • HACCP is a set of principles designed to control and prevent food safety risks during food production.
  • HACCP is not enforced or regulated by any single organization.
  • The ideas of HACCP form the basis of every food safety management system standard that is in use today, including GFSI food safety standards.
  • The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO), in a set of documents called the Codex Alimentarius , a latin phrase which translates to “Book of Food”.
  • FAO’s General Principles of Food Hygiene CXC 1-1969 contains the HACCP principles (sometimes called HACCP Codex).  Download the 2020 revision of the HACCP Code here: http://www.fao.org/fao-who-codexalimentarius/codex-texts/codes-of-practice/ (click the green check/tick mark on the right side of the page to download).

What is VACCP and TACCP?

  • VACCP and TACCP are terms that emerged during the 2010s as standards agencies, government regulators and industry groups started considering methods to prevent food fraud and malicious tampering.
  • VACCP is for food fraud.
  • TACCP is for food defense.
  • The acronyms VACCP and TACCP are designed to leverage the food industry’s familiarity with HACCP.  But they are unhelpful terms.  The controls in food fraud and food defense plans are nothing like the ‘critical control points’ in a HACCP plan.  The control points in a HACCP plan are operational steps in a food manufacturing process over which the food manufacturer has direct control.  Food fraud and food defense controls are different and they do not work the same way as ‘critical control points’ in HACCP.
  • The terms VACCP and TACCP are falling out of favor within the food safety industry.  They are not referenced specifically within any of the GFSI food safety standards, nor within the USA’s FSMA.

 

What to say instead of VACCP and TACCP?

  • Instead of ‘”VACCP” it is better to say food fraud prevention program.
  • Instead of “TACCP” it is better to say food defense plan.

Learn more

food safety food fraud

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Fake (Counterfeit) Health Supplements

Two US supplement companies share their food fraud stories

Photo by Mika Baumeister on Unsplash

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

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

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

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

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

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

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

NOW Foods explains how to spot a fake on their website

 

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

Adulterants and allergens

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

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

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

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

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

Sources:

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

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

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

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