Food Fraud Advisors

  • Home
  • About Us
  • Our Services
  • Tools, Templates and Training
  • Learn about food fraud
  • Report a food crime
  • News
You are here: Home / Archives for economically motivated adulteration

6th June 2024 by foodfraudadvisors

Paprika, Chilli Powder and Sudan Dye Contamination

Can paprika and chilli powder be “too red”?

This post was originally published in The Rotten Apple newsletter.

 

In 2016 an inspector from the New York State (NYS), Department of Agriculture and Markets visited a food market looking for suspicious spices. There had been a spate of adulteration incidents with paprika and related spices such as chilli powder and curry powder internationally and the New York authorities were surveying local supplies.

The inspector was Audrey, a colleague of Tom Tarantelli, now retired. Tom recently sent me an intriguing photograph of some products from the same brand that Audrey spotted that day.

In one store, Audrey noticed some packages of paprika that looked “too red”. This was, perhaps, a sign the paprika had been adulterated with unauthorised colourants.

She purchased the paprika and took it back to the lab for testing.  It was, indeed adulterated. Tom told me they found 2,400 ppm Sudan 4 and 850 ppm Sudan 1 in the product. It was one of the highest concentrations of Sudan 4 ever found, as high as the worst European case that had been reported up to that time.

The results were so remarkable that Tom purchased more packages to keep. “Realizing this product would be thrown away, I went to the store and obtained more. Such a great sample!” Tom told me.

That was in 2016, eight years ago.  Today, the products Tarantelli purchased are still a brightly-hued, fresh-looking red.

Paprika samples purchased in 2016 retained their “too red” colour for almost 8 years. This photograph was taken in December 2023. Paprika from this brand contained very high concentrations of the illegal, carcinogenic dyes, Sudan I and Sudan IV. Photograph: Thomas Tarantelli

 

The photograph above was taken just a few months ago, more than seven years after the samples were purchased. The colour is bright. Pure paprika, on the other hand, loses its red colour over time and ages to a dull brownish colour.

This is the challenge for spice traders: old paprika doesn’t have an attractive colour. Dull-coloured paprika is perceived to be of lower quality and to have less flavour, and therefore must be sold for a lower price.

One solution is for traders to add colouring agents to their wares. Since pure spices are not allowed to contain even food-grade colourants, the traders do not bother to use colourants that are safe or legal. Instead, they use colourants that are cheap, easy to obtain and easy to handle.

Sudan dyes seem to be popular with unethical spice traders who want to enhance the colour of the spices they sell. The dyes are industrial colouring agents, much cheaper than food-grade colours, and sold for use in industrial oils, waxes and shoe polish. Sudan I has an orange colour and  Sudan IV is a blueish red. Sudan dyes have been found in paprika, chilli powder and curry powder many times over the past decade. They are also a common adulterant in unrefined palm oil, which has a bright red colour when fresh.

Sudan dye adulteration was first detected in food in 2003, and was the cause of a huge recall in the United Kingdom in 2005, which affected 570 foods. Alerts and notifications for Sudan dye contamination continue to this day. Last month Italian authorities rejected palm oil from Ivory Coast because it contained Sudan 3 and Sudan 4 dyes and German authorities recalled cheddar cheese powder from Syria which contained multiple Sudan dyes.

There were 39 notifications for Sudan dyes in foods between 2014 and 2024 in the European Rapid Alert System for Food and Feed (RASFF), and 12 in the US FDA Import Alerts records. Many of the alerts are for adulterated palm oil, but in Europe, paprika, seasoning and spice blends, barbeque rub, chilli pepper, sumac and sweet and sour sauce were also affected. In America, barbeque flavoured snacks were affected in addition to palm oil.

FT-NIR spectra of a pure sample of paprika and the same sample after adulteration with Sudan II, III, IV and Congo red at 5 % (w/w). Source: Castell, et. al (2024)

 

The incident in 2016 wasn’t the only time Tarantelli and his colleagues found Sudan dyes in spices. In fact, they found sixteen commercially available spices containing such dyes in less than two years. The spices included turmeric, curry powder, malathy and chilli powder in addition to paprika.

Chemists from the New York State (NYS), Department of Agriculture and Markets found Sudan dyes in sixteen samples in less than two years. Source: Thomas Tarantelli in Food Safety Tech (2017)

 

The New York State inspectors reported their results to the US FDA, prompting a series of recalls. Unfortunately, the recalls were classed as less serious Class 2 recalls because of the assumption that spices like paprika are consumed in only small quantities.

However, as Tarantelli pointed out in an article he wrote in Food Safety Tech in 2017, assumptions about serving sizes can be wrong. In fact, when he compared the amount of spice consumed by some ethnic groups to the reference serving size used by the FDA they were 20 times higher.

“In the Code of Federal Regulations (CFR) Title 21, the serving size per meal for spice is referenced as ½ gram. However, certain ethnic groups may consume a daily amount of 20 grams of spice per person.”

Takeaways for food safety professionals

  • Foods that appear fresher, tastier or of better quality when their colour is more intense are vulnerable to adulteration with undeclared colourants.
  • Red-coloured foods such as paprika, chilli powder and palm kernel oil are sometimes adulterated with Sudan dyes to enhance their colour and increase their apparent value.
  • Sudan dyes are not approved for use in food, they are industrial dyes with carcinogenic properties.
  • Despite a long history of recalls, safety alerts and import alerts for Sudan dye adulteration, food fraud perpetrators continue to adulterate foods with this dangerous group of chemicals.
  • Although some food regulators consider adulterated spices to present a lower risk to consumers than other foods, because many people consume them in small amounts, some sectors of the population consume significant quantities of spices and are therefore at higher risk.
  • Food businesses that purchase red-coloured foods including spices and unrefined palm oil should consider such foods vulnerable to Sudan dye adulteration, and implement mitigations.

Main sources:

Castell, A., Arroyo-Manzanares, N., López-García, I., Zapata, F. and Viñas, P. (2024). Authentication strategy for paprika analysis according to geographical origin and study of adulteration using near infrared spectroscopy and chemometric approaches. Food control, 161, pp.110397–110397. doi:https://doi.org/10.1016/j.foodcont.2024.110397.

‌Tarantelli, T (2024), correspondence with author.

Tarantelli, T. (2017). Adulteration with Sudan Dye Has Triggered Several Spice Recalls. [online] FoodSafetyTech. Available at: https://foodsafetytech.com/feature_article/adulteration-sudan-dye-triggered-several-spice-recalls/.


‌There are ‘protected origin’ paprikas in Europe (more correctly known as Protected Designation of Origin (PDO)).  These protected paprikas are from specific regions and are known for their unique regional characteristics.  For example, there is a special paprika from a certain part of Spain called Pimentón de La Vera and one from Hungary called Kalocsai fűszerpaprika-őrlemény.  Source: Castell et al (2024)

Share this:

  • Click to share on Facebook (Opens in new window) Facebook
  • Click to share on X (Opens in new window) X
  • Click to share on LinkedIn (Opens in new window) LinkedIn
  • Click to email a link to a friend (Opens in new window) Email

Filed Under: Adulteration, Food Fraud

24th January 2024 by Karen Constable

Is Food Fraud to Blame for the Cinnamon-apple Recall?

[Listen to an audio version of this post here]

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 23 January 2024, the number of affected people had increased to at least 385.

And this could be just the tip of the iceberg, because it’s thought that around 1.8 million packages were affected, accounting for around 8 months of production.  That means thousands, or perhaps tens of thousands, of other people also consumed the tainted food.

Watching the case numbers go up, from 4 cases in October to 251 in December and now 385, has been like watching a slow-motion train crash.

a chart of case numbers in the cinnamon applesauce recall
The number of cases has climbed from four to more than three hundred in just a few months.  Source: (US) FDA

How much lead was in the food?

The earliest reports from the FDA said the level of lead in the recalled foods was “extremely high”.  Later, they reported finding lead at levels of 2 parts per million (ppm) in one sample of the fruit puree.  That level 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.

 

How did the lead get into the food?

Cinnamon was suspected of being the source of the lead contamination from the earliest days of the recall because products made by the same manufacturer without cinnamon were not affected.  It took some time for the FDA to obtain samples of the cinnamon for testing, and it was not until mid-December that results were published.

In December, the FDA confirmed that the cinnamon ingredient in the foods was the source of the lead.

How much lead was in the cinnamon?

The FDA found lead at up to 5,110 parts per million (ppm) in the cinnamon.

That is more than two thousand times higher than typical.  Cinnamon usually contains just 2 ppm of lead (Hore, et. al (2019)).  The amount in the cinnamon is also more than two thousand times higher than the ‘safety’ limit of 2.5 ppm proposed for cinnamon by the Codex Alimentarius Commission.

The figures below provide a graphical representation of the amount of contamination. The image on the left shows 5,110 ppm, the amount of lead found in one sample of the contaminated cinnamon, equal to five squares of the 32 x 32 grid. The image on the right represents the maximum amount of lead allowed in cinnamon: less than one pixel on your screen.

A graphical representation of the amount of lead in the samples. Left: 5,110 ppm, the amount of Pb found in one sample of cinnamon; Right, 2.5 ppm, the proposed maximum allowable limit.

Why was there so much lead in the cinnamon?

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 such as from the soil or through contact with paint results in low levels of contamination.  The levels of lead in the samples tested by the FDA were thousands of times higher than would occur from accidental contamination.

In the first months of the investigation, many food safety commentators openly discussed the possibility that the cinnamon was deliberately adulterated with lead for economic gain.  Tampering with food for economic gain is more commonly known as food fraud, or, in the USA “economically motivated adulteration”.

Lead adulteration of spices

For buyers and sellers of spices like cinnamon, one way to make more money is to add colourants to the spices to make them look better.  For example, fresh high-quality turmeric has an intense yellow colour, so adding yellow colourant to turmeric can increase its appeal, meaning it can be sold for a higher price.

Unfortunately, the colourants used by unscrupulous spice traders are not always safe.  Many of them are lead-based pigments, which are cheap, have intense colours and are easy to obtain in some countries.

The most well-studied example of such fraudulent adulteration is the use of lead chromate (‘chrome yellow’) to impart a bright yellow colour to turmeric.

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

Lead chromate comes in a range of intense colours, ranging from pale brown to intense oranges and crimson.  In addition, because lead is a heavy metal, it is literally heavy.  Spices are traded by weight, so adding a lead-based pigment increases their weight and hence the price.

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 figure, 880 ppm of lead in cinnamon, from a paper published in 2019, is not as high as in the latest incident, but it is more than four hundred times higher than ‘normal’, and enough to result in dangerously high levels of lead in any food to which the spice 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)

Is this a case of food fraud?

Deliberately adding lead-based pigments such as lead chromate to spices is, unfortunately, a common food fraud practice.  The intention is to make more money for the perpetrator.

Some weeks after the lead results were shared by the FDA, they revealed that the cinnamon contained high levels of chromium as well.  Test results for other heavy metals, including arsenic and cadmium, were not higher than usual.

Two samples of cinnamon contained 1,201 ppm and 531 ppm of chromium, respectively.  The ratio of lead to chromium is consistent with lead chromate having been added to the cinnamon.

There have been many past cases in which food fraud perpetrators have added lead chromate to spices.  Because the cinnamon in this investigation likely contains lead chromate, and because lead chromate is added to spices to increase their apparent value by changing their appearance and adding weight, food fraud is the most probable explanation for the presence of lead.

Probable explanations for the extremely high levels of lead in the cinnamon:

  • lead is a component of the pigment lead chromate, which is used to impart bright colours to textiles;
  • lead chromate is cheap and easy to obtain in some countries;
  • lead chromate is sometimes used to illegally add colour to spices, particularly turmeric;
  • spices coloured with lead chromate appear fresher and of higher quality than uncoloured spices, and can be sold for a higher price;
  • lead chromate comes in a range of colours, including browns, crimsons and yellows;
  • the cinnamon in this incident contained very high levels of chromium as well as lead.  Chromium is also a component of lead chromate pigment;
  • spices adulterated with lead chromate are heavier than pure spice, so they can be sold for a higher price;
  • the addition of lead chromate to the cinnamon could have allowed the perpetrator to sell it for a higher price, resulting in economic gains.

Not a food defence (malicious contamination) incident

While some food adulteration actions are intended to cause harm for malicious purposes, lead adulteration does not lend itself to intentionally harmful adulteration.  Malicious acts are intended 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 was intentionally adulterated, the slow-acting nature of lead poisoning means the primary purpose of the adulteration was probably not to cause harm to consumers.

Conclusion

When the history of lead chromate adulteration of spices is considered, along with the presence of high levels of both chromium and lead in the cinnamon, and the fact that lead poisoning is slow-acting, it seems likely that the cinnamon used to make the recalled fruit purees was intentionally adulterated with lead chromate-containing material for economic gain.  That makes it an example of food fraud.


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

An earlier version of this post originally appeared in The Rotten Apple, a weekly newsletter for food professionals, by Karen Constable

Share this:

  • Click to share on Facebook (Opens in new window) Facebook
  • Click to share on X (Opens in new window) X
  • Click to share on LinkedIn (Opens in new window) LinkedIn
  • Click to email a link to a friend (Opens in new window) Email

Filed Under: Food Fraud

24th May 2023 by foodfraudadvisors

Acronym Decoder

BRC and BRCGS: British Retail Consortium (superseded) and British Retail Consortium Global Standards.  The British Retail Consortium (BRC) is a group of British companies that published guidance and standards for food manufacturers, including a food safety standard that was also commonly referred to as BRC.  The standards owner is now known as BRCGS.

CoOL or COOL: Country of Origin Labelling.

EMA: Economically motivated adulteration or substitution. EMA is a subset of food fraud and is defined as the fraudulent, intentional substitution or addition of a substance, or dilution of a substance for the purposes of economic gain.  Non-EMA food fraud includes black market importation and trading of food and alcoholic beverages for the purposes of avoiding duty and taxes.

DEFRA: The Department for Environment, Food and Rural Affairs, a United Kingdom government department responsible for food production and standards as well as environmental and agricultural responsibilities.

FDA:  Food and Drugs Administration.  The FDA is the name of a regulatory body in a number of countries, including USA, Philippines and India.

FSA: Food Standards Agency, a United Kingdom government regulatory body.

FSMA: Sometimes pronounced ‘Fizzmah’.  Stands for Food Safety Modernisation Act (United States of America).

FSSC 22000: A food safety management system standard similar to ISO 22000 but with extra requirements incorporated to meet the requirements of a GFSI standard.

FSVP:  Standards for Foreign Supplier Verification Program.  It is part of the requirements of the US Food Safety Modernisation Act and applies to US importers of food and their suppliers.

GFSI: Global Food Safety Initiative.  The GFSI is a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe.  The GFSI provides direction and approval to organizations that create food safety management systems, so a GFSI-approved food safety standard is one that represents international best practice.  Well known GFSI standards include BRC, FSSC 22000 and SQF.

GMO: Genetically Modified Organism.

HACCP:  HACCP is a set of principles designed to control and prevent food safety risks during food production.  The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO).  Download the 2020 revision of the HACCP Code here.

HARCP: Hazard Analysis Risk-based Preventive Control.  HARCP = food safety as legislated by the United States.  This acronymn being used by some in the USA when talking about the requirements of the recently enacted Food Safety Modernisation Act (FSMA) in that country.  HARCP is claimed to differ from HACCP by including requirements for preventive controls.  Read more about HARCP here.

IA: Intentional Adulteration.  Within the US Food Safety Modernisation Act (FSMA), Intentional Adulteration specifically refers to malicious adulteration that is intended to cause widescale harm.  Learn more about intentional adulteration here.

ISO 22000:  ISO is the International Organization for Standardization.  They have thousands of standards across many different businesses, products and systems.  ISO 22000 is the ISO standard for food safety management systems.  Like other major food safety management systems it is based on the principles of HACCP.

NSF:  a pseudo-government organization head-quartered in the United States that is active in the area of food safety and sanitation.

PCQI:  Preventive Controls Qualified Individual.  The name of the role held by an expert food safety professional who meets certain requirements under the (US) Food Safety Modernisation Act.

SQF:  Safe Quality Food Institute.  The Safe Quality Food Institute owns and publishes a group of food safety standards also known as SQF that is a GFSI – approved standard.

USP: United States Pharmacopeial Convention.  USP is a non-profit organization that creates identity and purity standards for food ingredients and food chemicals, as well as for medical drugs.

TACCP: Threat Assessment Critical Control Point.  TACCP = prevention of malicious threats to food.

VACCP: Vulnerability Assessment Critical Control Point.  VACCP = food fraud prevention.  Learn more about TACCP and VACCP here.

Learn about Vulnerability Assessments, what they are and how to do them, here.

Share this:

  • Click to share on Facebook (Opens in new window) Facebook
  • Click to share on X (Opens in new window) X
  • Click to share on LinkedIn (Opens in new window) LinkedIn
  • Click to email a link to a friend (Opens in new window) Email

Filed Under: Learn

27th April 2023 by Karen Constable

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 activitiesIngredients (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)YesYesRisk 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)

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––YesYes
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.

Share this:

  • Click to share on Facebook (Opens in new window) Facebook
  • Click to share on X (Opens in new window) X
  • Click to share on LinkedIn (Opens in new window) LinkedIn
  • Click to email a link to a friend (Opens in new window) Email

Filed Under: Consultancy, Food Fraud, Learn, Vulnerability Assessments

30th December 2022 by foodfraudadvisors

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.

 

Share this:

  • Click to share on Facebook (Opens in new window) Facebook
  • Click to share on X (Opens in new window) X
  • Click to share on LinkedIn (Opens in new window) LinkedIn
  • Click to email a link to a friend (Opens in new window) Email

Filed Under: Adulteration, Regulatory

  • 1
  • 2
  • 3
  • 4
  • Next Page »

MORE FROM FOOD FRAUD ADVISORS

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 … [Read More...]

Food Fraud Databases Compared

Updated 30 April 2025 A food fraud database is a collection of information about food fraud incidents and food fraud … [Read More...]

What to do About Food Fraud (USA)

I was talking to a new client the other day.  They are based in the United States and had discovered their competitors' … [Read More...]

Paprika, Chilli Powder and Sudan Dye Contamination

Can paprika and chilli powder be “too red”? This post was originally published in The Rotten Apple … [Read More...]

Is Food Fraud to Blame for the Cinnamon-apple Recall (Video)

Our Principal, Karen Constable, explains how high levels of lead may have got into applesauce (video audiogram). For … [Read More...]

follow

  • View foodfraudadvice’s profile on Facebook
  • View karenconstable4’s profile on Twitter
  • LinkedIn

© Copyright 2015 - 2025 Food Fraud Advisors · All Rights Reserved · Privacy Policy · Return and Refund Policy