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Food Safety Standards Compared (2023)

 

food vulnerability assessment

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

When it comes to food fraud, the food safety standards have minor differences in their requirements. For example, some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t; some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on finished products.  Some explicitly require training in food fraud awareness, while others do not.

Confused? We are here to help.  Read on to find out which standards have what requirements, and get recommendations for creating a great food fraud prevention (VACCP) program.

Background

Food safety standards are standards that describe requirements for food and related businesses.  The requirements aim to ensure that food and food-related goods are safe for consumers and customers.  The correct term for such standards is food safety management systems standards (FSMS).

There are food safety standards for all types of operations within the food supply chain, including:

  • growing and packing fresh produce;
  • manufacture of food and food ingredients;
  • buying and selling food (“brokers”);
  • storage and transport of food;
  • manufacture or converting of packaging materials;
  • manufacture of animal feed or pet food;
  • services such as cleaning, laundry, or pest control for food businesses.

The over-arching aim of all food safety standards is to keep consumers safe, but most standards also have secondary aims. Some of the most popular food safety standards were developed by food retailing groups, and these standards were written to protect the retailers’ brands as well as keep consumers safe. Other standards were developed to help food businesses understand best practices and gain a way to demonstrate their excellence through independent certifications.  Some standards include quality parameters, while others only address food safety issues.

There are dozens of internationally accepted food safety management system standards, each with slightly different requirements.  This can make it difficult to know which standards are ‘better’ or more suitable for your food company.

To solve this problem, a standard for food safety standards was created by the GFSI (Global Food Safety Initiative).  The GFSI assesses and approves food safety standards using a process called benchmarking. The aim of GFSI benchmarking is to define best practices for food safety standards and provide a way to compare and align different food safety standards.

Among the dozens of food safety standards, some are benchmarked by the GFSI (Global Food Safety Initiative), while others are not.  Benchmarked standards usually have more requirements and more rigorous expectations than non-benchmarked standards.  The auditing and certification processes for benchmarked standards are typically more time-consuming and more expensive than for non-benchmarked standards.

Food Fraud in Food Safety Standards

Food fraud prevention activities are an important part of all food safety management systems because food fraud can pose a risk to food safety.  Some food safety standards have separate, stand-alone requirements for food fraud prevention activities, while others do not.  Standards that are GFSI-benchmarked all include explicit, separate food-fraud-related requirements. Other standards rely on the hazard analysis elements of the food safety system to identify and control hazards from food fraud.

The GFSI requires all benchmarked standards to require food companies to do a vulnerability assessment for food fraud and create a mitigation plan for food fraud prevention.  Most GFSI-benchmarked standards also include details about which materials should be assessed and which types of food fraud need to be managed.

Non-GFSI standards vary in how they require a food company to approach food fraud.  Some specify or recommend a VACCP program, which is based on food fraud vulnerability assessment activities. Others, like AIB, require that food fraud risks be considered in the supplier approvals processes.  The regulations of the USA Food Safety Modernization Act (FSMA) require that food businesses identify hazards from economically motivated adulteration-type food fraud (EMA) and implement preventive controls to minimise the risks.

Among the most well-known standards, there are some notable differences. For example, the SQF Food Safety Code requires food businesses to assess and manage risks from counterfeit-type food fraud, while the BRC Food Safety Standard only requires businesses to assess the risks from adulteration or substitution activities. BRC requires horizon scanning activities, while the SQF and IFS standards explicitly mention food fraud training.

Below you will find a table that compares the current food fraud requirements of each of the major food safety standards.

Table 1.  Food fraud requirements of major food safety standards, 2023. 

Click here to open or download a pdf version of this table

  AIB* BRC* FSSC* GlobalGAP* IFS* SQF*
Food types to include in food fraud prevention activities Ingredients (implied)

 

 

 Raw materials

 

 

 Products and processes

 

 

 Unclear

 

 

 Raw materials,

ingredients,

packaging,

outsourced processes

 Raw materials,

Ingredients,

finished products

 
Food fraud types

 

 

 

 Economically motivated adulteration (only)

 

 

 Adulteration,

substitution

(only)

 

 

 Any type where consumer health is at risk (in definition, Appendix A)

 

 Unclear, however counterfeit or non-foodgrade packaging or propagation materials are included as examples

 

 Substitution, mislabelling, adulteration, counterfeiting

 

 

 Substitution, mislabelling, dilution, counterfeiting

 

 
Vulnerability assessments explicitly required? Risk assessment (implied, Appendix A) Yes Yes Risk assessment Yes Implied (Edition 9)
Mitigation plan required?

 

 

 – Mitigation activities are to be included in the vulnerability assessment Yes Yes Yes Yes
Does packaging need to be included in the vulnerability assessment? Yes

(implied)

 

 Yes

(see 3.5.1.1)

 

 Yes

(as per food fraud definition, Appendix A)

 Yes

 

 

 Yes

 

 

 Implied

(primary packaging is a ‘raw material’)
Is a separate food fraud procedure explicitly required? – – Implied (“method shall be defined”) – Implied

(“responsibilities shall be defined”)

 Implied

(“methods and responsibilities shall be documented”)
Is training in food fraud explicitly mentioned? – Implied

(Clause 5.4.1)

 – – Yes

(Clause 3.3.4)

 Yes
Is an annual review explicitly required? – Yes – – Yes Yes
Other

 

 

 – Horizon scanning for developing threats must be done (Clause 5.4.1) – – Criteria for vulnerability assessments must be defined

(4.20.2)

 Food safety risks from food fraud must be specified (2.7.2.2)

*  The full names of the standards are as follows:

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

BRCGS Food Safety, Issue 9

FSSC 22000, Version 6 (NEW!)

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

IFS Food, Version 8 (NEW!)

SQF Food Safety Code, Edition 9

Takeaways

Among the major food safety management system standards, there are small but significant differences between food fraud prevention requirements.  Key differences include whether finished products or ingredients are to be assessed, which types of food fraud must be included and the presence/absence of requirements related to horizon scanning and training.

If that all seems confusing, don’t despair…

Recommendations for a robust and compliant food fraud prevention program (VACCP)

At Food Fraud Advisors we have been working at the intersection of food fraud and food safety since the very first days of food fraud requirements in food safety standards… and we’ve been helping businesses since day one.

Creating a robust and compliant food fraud program can take time and effort but it isn’t complicated.  Follow the steps below to get started:

  1. Carefully read the food fraud clauses of the standard you are/will be certified to. Pay attention to the food types and the food fraud types that are mentioned in your standard.  HINT: you may need to check the definitions or glossary. Carefully read the food fraud clauses of the standard you are/will be certified to.
  2. Pay attention to the food types and the food fraud types that are mentioned in your standard. HINT: you may need to check the definitions or glossary.
  3. Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
  4. Create a food fraud prevention procedure that defines the methods, responsibilities and criteria for food fraud prevention.
  5. You should also conduct training for all relevant staff and ensure that the food fraud system is reviewed at least annually.

Get a complete guide to the food fraud requirements of all the major food safety standards from us, the food fraud experts, here.

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Honey Fraud – Much Worse Than We Thought?

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

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

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

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

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

 

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

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

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

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

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

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

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

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

Something is just not right with honey in Europe

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

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

Takeaways

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

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

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

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

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

 

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

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5 Food Fraud Trends to Look Out For in 2023

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

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

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

1) Organic fraud

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

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

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

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

organic produce pesticide authentic fruit vegetable

2) Waste disposal fraud

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

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

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

 

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

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

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

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

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

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

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

 

4) Problematic sustainability claims

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

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

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

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

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

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

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

 

5) Authenticity testing – more accessible, better expertise

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

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

 

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

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Food Fraud Databases Compared

Updated 29 January 2023

A food fraud database is a collection of information about food fraud incidents and food fraud risks. There are paid and free databases operated by governments, not-for-profits and private companies.  The type of data varies from database to database, as does the cost and the features.

Pay-To-Use Databases

There are four well-known, pay-to-use food fraud databases.  Since 2020, company mergers, acquisitions, and name changes have made it hard to understand which database is which – and which one is best for you.  The four best-known commercially operated databases are listed below.

(1) EMAlert by Battelle.  This database has been around for many years, but no longer has a high profile.  It still exists, but contains information for only a limited number of commodities.  https://www.emalert.org/

(2) HorizonScan (FERA).  This tool was developed by the UK government’s Food and Environment Research Agency (FERA). It is widely used and includes alert systems and information about food safety, food fraud and suppliers.  https://horizon-scan.fera.co.uk/

(3) Decernis’ Food Fraud Database (formerly the United States Pharmacopoeia (USP) Food Fraud Database).  The Decernis Food Fraud Database includes scholarly articles on testing and detection methods as well as food fraud incidents.  https://decernis.com/products/food-fraud-database/

(4) Agroknow’s FoodAkai is the most recently developed tool.  It uses sophisticated AI to analyse data from global food safety agencies to offer insights into hazards in raw materials, ingredients and products.  Like HorizonScan, it includes food safety as well as food fraud issues and incidents.  https://agroknow.com/foodakai/

FoodChainID is another big name in food fraud tools and they also list a product called HorizonScan™ on their website.  Confusingly, FoodChainID’s HorizonScan™ is the same as FERA HorizonScan.  The difference is in the regional distribution rights for each product.  FoodChainID – a company – distributes the HorizonScan product in the USA.  FERA distributes it in non-US markets.

FoodChainID also has a partnership with EMAlert and recently bought the company Decernis, which owns the (formerly USP) Food Fraud Database.  This makes FoodAkai the only well-known paid tool that is independent of FoodChainID.

A less well-known paid service is MerieuxNutriSciences’ Safety HUD, which monitors official agencies and other sources for alerts on food safety and frauds. Safety Hud 2.0 | Food Compliance Solutions (mxns.com)

Costs

There is a notable lack of transparency in the pricing of food fraud databases.  Fees to access the databases are usually levied on a subscription basis.  The cost varies depending on the number of users and whether you are a consultant or a single food company.

All the databases listed above offer either a free trial or a guided demonstration, so you can compare them to decide which might be best for your company’s needs.

Affiliation

Food Fraud Advisors has no financial relationships with the products or companies listed here, though we do have contacts at each organisation, so if you would like a no obligation introduction, just ask. We do not earn a commission from such introductions.

Free Databases

(1) Food Fraud Advisors’ Food Fraud Risk Information Database (hosted on Trello) is a free and open-access online database of food fraud incidences and emerging threats, organised by food type.  No log-in required.  https://trello.com/b/aoFO1UEf/food-fraud-risk-information

(2) FoodSHIELD is a US Government-Academic partnership.  Access to the FoodSHIELD food fraud and food defense database is limited to representatives from local, state, and federal governments, the military and laboratories that perform analyses.  https://www.foodshield.org

(3) Food Protection and Defense Institute (USA)’s Food Adulteration Incidents Registry. Access by special request only. https://incidents.foodprotection.io/about

(4) Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.

(5) US FDA’s Recalls and Food Safety Alerts, has a searchable database and includes incidents arising from food fraud.  http://www.fda.gov/Safety/Recalls/

(6) MEDISYS for Food Fraud (MEDISYS-FF) is a food fraud media monitoring system that uses information from the Europe Media Monitor to collect media reports related to food fraud.  The reports can be filtered by country of origin, keyword and date.  You can request access to the system by submitting a form.  https://bigdata-wfsr.wur.nl/2020/09/18/medisys-for-food-fraud/ 

Which Database Should I Use?

How do I know which database will meet my needs?

 

What are your needs? Check the headings below to see which best describes your company’s needs for food fraud information. 

 

Low budget and/or need information infrequently

If you have a low budget and don’t need to access information often, Decernis’ Food Fraud Database has cost-effective single month or month-to-month subscriptions.

Custom alerts for specific ingredients or foods

All four paid databases allow you to create custom alerts for products, ingredients of interest.  You receive an email or other notification when a new incident occurs.

Food safety and food fraud alerts

HorizonScan and FoodAkai both include food safety hazards as well as food fraud hazards in their reporting and alert systems.

Analytical test methods information

Decernis’ Food Fraud Database includes test method information and research papers.

Large number of users across multiple sites

If you have a high number of users who want to access the database or a very large number of products, HorizonScan and FoodAkai have enterprise-level subscriptions so users on different sites can set up their own reports and alerts.

Predictions about future hazards

FoodAkai promises early warning of emerging risks, which are predicted using AI technology. The makers of FoodAkai say their software predicted the multi-country, multi-product ethylene oxide in sesame recall disaster of 2020-2021.

Students, occasional needs, non-food professionals

The Food Fraud Information Database hosted on Trello is a great place to start your food fraud journey if you are a student or new to the food industry.  It is free and contains good summaries of the types of food fraud that affect various foods.  However, it is not easily searchable (you can buy a searchable ‘snapshot’ in Excel form) and it does not provide custom alerts.  Incidents added to the database are mostly drawn from international media and are heavily weighted to English language media, so are not suitable for accurate counting or mapping of incidents.

Other free information about European and North American foods

RASFF (Europe) and FDA Recalls and Food Safety Alerts (USA) mostly contain food safety incidents, with few food fraud incidents.  Much of the data derives from cross-border food movements, especially in RASSF.  They are both free and searchable and can be a useful adjunct to the free food fraud database on Trello.

 

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Ten Years After Horsegate – A Decade to Celebrate

The horsemeat scandal of 2013 prompted action from the food industry and (some) governments against food fraud.  Ten years later, have we made progress?  Yes!

The United Kingdom created the Food Industry Intelligence Network, the Food Authenticity Network, which is now global, and the National Food Crime Unit (UK) on the recommendations of Prof Chris Elliott in his review of the crisis, which was commissioned by the UK government.

Chris recently wrote about the progress we have made on food fraud in the past decade in New Food Magazine.  He is positive about the gains we have made since 2013.

“The response from industry and government to defend the nation against fraudsters and indeed organised crime in the food sector has been enormously beneficial and makes life far more difficult for criminals.” Chris Elliott writing in New Food Magazine

We have made great progress since 2013, but it’s easy to forget how far our industry has come in our fight against food fraud. We are now paying more attention to food fraud and we are much more aware of its potential to hurt consumers and brands.  There are more tools and technologies available to food businesses to detect and deter food fraud than in 2013.  Analytical test methods, equipment and expertise are (slowly) becoming cheaper and more accessible.

Back in 2013 species identification tests were not routinely performed on red meat – the horsemeat-for-beef issue was only discovered because a sharp-eyed food inspector in Ireland noticed discrepancies on the labels and cartons of frozen “beef” at a small import-export business. At the time, the head of the Irish Food Safety Authority (FSAI) was “astounded” and thought there had been a mistake in the testing when the first sets of results were received, which showed almost 30 percent horsemeat in the “beef”.

These days it’s easy to have meat tested to determine its species and there are cost-effective test kits available for both raw and cooked meat.

However, the ‘bad guys’, as Prof Elliott says, won’t stop trying to make money from food fraud.  It can be very profitable and it carries a low risk of prosecution and punishment compared to other nefarious activities like smuggling drugs across international borders. One commentator estimated that it is three times more profitable to make and sell ‘fake’ olive oil than to smuggle cocaine (source).

In recent years there have been frequent claims in the media that food fraud is getting worse or is an increasing problem, but there is no evidence to support those claims. Food fraud is, by its nature, difficult to measure. As an industry, we are certainly talking about food fraud more, and there are more frequent reports about food fraud, but this doesn’t mean it is more prevalent.

We do need to remain vigilant, of course, because food fraud is not going away. One risk is that as big food companies and wealthy countries pay more attention to food fraud, the fraudsters will increasingly target commodities, companies and regions where there is less oversight – the “low-hanging fruit”.  These are the areas that are increasingly at risk as well-resourced companies increase scrutiny of their supply chains.

In some regions, where consumers and businesses are experiencing economic hardship, there is increasing motivation for previously legitimate food businesses to “cut corners” and for consumers to accept food from questionable sources and this also increases the risks.

Takeaways

As an industry, we are more aware of food fraud than before the horsemeat scandal, and we now have better tools and systems for keeping our consumers and our brands safe.

However, with well-resourced food companies working harder to deter and prevent food fraud in their supply chains, other businesses in the food sector will become more attractive targets for bad actors.

Don’t let your food company be the “low-hanging fruit” for food fraud perpetrators; keep being vigilant about the risk of food fraud in your supply chain and within your own company.

*** This post originally appeared in Issue #72 of The Rotten Apple Newsletter ***

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Food Safety Hazards from Food Fraud (EMA)

Updated 28th June 2023

Are you confident in your FSMA preventive controls for hazards from food fraud?

This post is for you if your company manufactures food in the USA or exports food to the USA.

Food companies in the USA must comply with food safety regulations that require them to identify and address hazards from economically motivated adulteration (EMA), a type of food fraud.

In this post you can learn what EMA is and how to identify food safety hazards from EMA.  You can also discover what type of preventive controls are best for EMA hazards.

Definitions

EMA is short for economically motivated adulteration which is a type of food fraud.  Other types of food fraud include counterfeiting, making false claims (for example, fake ‘organic’ food) and species substitution (for example, selling cheap white fish labelled as snapper).

“Economically motivated adulteration (EMA) occurs when someone intentionally leaves out, takes out, or substitutes a valuable ingredient or part of a food. EMA also occurs when someone adds a substance to a food to make it appear better or of greater value.” (US FDA)

FSMA denotes the Food Safety Modernization Act (USA). is a set of rules for food manufacturers. Under the rules, food manufacturers must assess food safety hazards and implement preventive controls. The US Food and Drug Administration (FDA) is responsible for the enforcement of the rules.  If your company is outside the USA but exports to the USA, you must also comply with the FSMA rules.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food.  (Find the official FDA definition here)

Preventive controls are procedures and systems that are designed to ensure that food safety hazards are prevented or minimized to an acceptable level.

Rules for food fraud (USA)

FSMA requires that preventive controls are implemented by food manufacturers to prevent hazards to human health.  The relevant regulation is called the FSMA Final Rule for Preventive Controls for Human Food, and is commonly known as the Preventive Controls Rule.

The Preventive Controls Rule requires food manufacturers to identify and control hazards that could arise from:

  • natural occurrences (for example, some raw meat products naturally contain certain human pathogens);
  • unintentional contamination (for example food may be accidentally contaminated with a pesticide during a pest control treatment), and
  • economically motivated adulteration (EMA).

After food manufacturers have identified the hazards, they must minimize or prevent the hazards by creating and implementing preventive controls in their food manufacturing operations. These are procedures and systems that are documented and that include monitoring, corrective actions systems and verification activities.  The preventive controls form part of the food manufacturer’s food safety plan.

Learn more about the preventive controls rule on the FDA’s preventive controls guidance webpage.

A separate part of the FSMA rules also requires food manufacturers to create and implement systems to prevent intentional, malicious adulteration.  The FDA calls this type of adulteration Intentional Adulteration (IA). It is different from economically motivated adulteration.  Intentional adulteration prevention is also known as food defense.  Click here to learn more about food defense.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food

Examples of hazards from economically motivated adulteration (EMA)

Economically motivated adulteration (EMA) is a subset of food fraud.   Food fraud includes many types of deception carried out for the purposes of economic gain.  It includes activities such as mislabeling (for example, making false claims about the geographical origin of a food product) and other fraudulent activities that do not involve the adulteration of food.

Economically motivated adulteration is a type of food fraud in which a person has added a substance to food to enhance its apparent value or profitability.  Often the added substance will boost the apparent quality or appearance of the food, other times the substance will be a diluent, which dilutes or replaces the genuine material with a cheaper material, thereby increasing the profitability of the resulting mix.

Food businesses are required by law to

  • understand food safety hazards that may be in their products;
  • create and implement systems that will prevent, minimize or eliminate those hazards;
  • systems for preventing, minizing and eliminating hazarsd  must be documented in a food safety plan.

Economically motivated food fraud (EMA) happens when food fraud perpetrators add materials to increase the apparent value of the food or to extend its shelf life in an undeclared or unlawful manner.  Materials that are added to make food or ingredients seem bigger, or heavier include water and other liquids, or fillers and bulking agents, such as starches, husks or sawdust.  Adulterants that are added to make food look better include unauthorised colorants, glosses and glazes.  Adulterants that extend shelf life include non-approved preservatives.

Food safety hazards can arise from EMA.

The food safety hazards from such adulterations include acute or chronic chemical poisoning, allergenic reactions, and microbial illnesses from pathogens introduced during the adulteration processes.

Example: Unauthorized color in turmeric

A significant proportion of powdered turmeric traded worldwide contains unsafe levels of lead.  Researchers in Bangladesh have confirmed that the lead is added to the spice in the form of toxic lead chromate which has an intense yellow-gold color, the color favoured by turmeric traders and buyers as an indicator of freshness and quality.  Curry powder, cumin and cinnamon have also been affected.  A survey of more than 1496 samples of 50 spices from 41 countries found that 50% of the spice samples had detectable lead, and more than 30% had lead concentrations greater than 2 ppm, a level that is 200 times higher than the recommended maximum lead content of candy in the USA.  Lead is a potent neurotoxin that damages organs including the brain.

Example: Undeclared peanuts in chopped hazelnuts

Peanuts are cheaper than most other nuts which makes them an attractive ‘filler’ or bulking agent in chopped nuts, powdered nuts and nut pastes.  When a food fraud perpetrator adds peanuts to a tree nut product, they gain more profit than if they sold a pure paste or powder.  In Germany in 2017, authorities found bulk quantities of chopped hazelnuts adulterated with 8% chopped peanuts.  The chopped hazelnuts were sold as ‘pure’ hazelnuts and did not declare any peanut ingredients on the label.  Because peanuts are a regulated human food allergen, their presence in the hazelnut product presented a serious food safety hazard.

 

How to identify hazards from economically motivated adulteration (EMA)

Follow the five steps below to identify hazards from EMA food fraud for your food manufacturing preventive controls plan.

  1. For each raw material that your company purchases to use in the food manufacturing process, investigate whether economically motivated adulteration is likely to occur within the supply chain.  Ask yourself: could adulterants be present in the raw material when it is purchased?  Learn how to investigate susceptibility to food fraud here.
  2. For each raw material and each finished product your company makes, also investigate whether economically motivated adulteration could occur inside your manufacturing facility or storage areas.  This is sometimes known as ‘insider activity’.
  3. After you have understood whether adulteration is likely to occur for each raw material, make a list of adulterants that could be added to each of the susceptible foods.   Historical records of past incidences of food fraud provide the best indication of the types of adulterants that can be expected in different foods and ingredients.  This page has a list of databases you can use to find historical records. .
  4. For each possible adulterant, make a note of whether it could be hazardous to human health if present in the food.  As an example, olive oil is commonly adulterated with (non-olive) vegetable oils.  That type of adulteration is unlikely to be hazardous and as such it would not require a preventive control under the FSMA rules*.   Document your decisions and justifications for such.
  5. Add the economically motivated hazards you have identified to your company’s food safety plan.  Implement preventive controls for each hazard.  Supplier approvals programs are commonly used for control of economically motivated hazards in incoming raw materials.

Need to learn more about food fraud prevention?  Visit our online training school.  Courses start at just US$59.

*Even if not strictly required under FSMA rules, it is always a good idea to prevent any type of food fraud from affecting your products.  This will protect your company and brand as well as your consumers’ health.

 

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Food Fraud in Food Additives

Food additives such as flavour-enhancers, gums, enzymes, emulsifiers, stabilizers, anti-caking agents, anti-oxidants and non-nutritive sweeteners are a bit of a “black box” when it comes to food fraud.  There are few records of food fraud in food additives in our Food Fraud Risk Information (Trello) Database, with the exception of vanilla extract flavouring, which has more entries.  However, just because we don’t have many public records for food fraud does not mean that it does not sometimes occur in food additives.

Food fraud problems with food additives might be less likely to become public knowledge because they are less likely to cause serious food safety issues compared to other food components, due to the tiny concentrations at which additives are present in finished products.  In the absence of a food safety incident or food recall, it is less likely that a food fraud will become public knowledge.

Food fraud in food additives might be easier to detect than food fraud in other ingredients.  For example, if a food additive was fraudulently diluted with a cheap filler, it would not perform as expected in a recipe, which would alert the food manufacturer to a problem.

Many food additives (excluding flavours) have short(ish) supply chains compared to other food types, which reduces the chances of fraudulent tampering with the product.

Fraud in food colourings

During July 2022, there were two border rejections for food colouring additives that contained unauthorised colouring agents.  The border rejections occurred in Europe.  The food colours originated in India.  It is not known whether the unauthorised components were present as a deliberate deception – that is food fraud – or if the importer was unaware of their regulatory status in the European Union. Links can be found in the food fraud incidents section.

 

Image: Pawel Czerwinski on Unsplash