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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)

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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

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FSSC 22000 and IFS Food Standards (Updated)

FSSC 22000 and IFS Food Standard have been updated recently, with FSSC 22000 Version 6 to be enforced from April 2024, and IFS Food Version 8 enforced from October 2023.

You can get (free) copies of the newly updated standards from the standards owners:

FSSC 22000 Version 6

IFS Food Version 8

Changes to Food Fraud Requirements in the Standards

FSSC 22000

There have been minor changes to the food fraud requirements in FSSC 22000 for Version 6.  The clause numbers remain the same: 2.5.4.1 and 2.5.4.2.

  • The biggest change is that this standard now explicitly requires that the methodology for the vulnerability assessment process be defined.
  • Version 6 does not make any mention of the “documented procedure” for vulnerability assessments that was part of the previous version (Version 5.1).
  • The definition for food fraud in FSSC 22000 (Appendix 1) has had “feed” added to its scope.
  • For businesses within the FSSC category FII (food brokering, trading and e-commerce), they must also ensure that their suppliers have a food fraud mitigation plan.

 

Food Fraud Requirements of FSSC 22000, Version 6 (with new wording in blue)

2.5.4 Food Fraud Mitigation

2.5.4.1 Vulnerability Assessment

The organization shall:

    • Conduct a food fraud vulnerability assessment based on a defined methodology, to identify and assess potential vulnerabilities; and
    • Develop and implement appropriate mitigation measures for significant vulnerabilities.

The assessment shall cover the processes and products within the scope of the Organization.

2.5.4.2 Plan

    1. a) The organization shall have a documented food fraud mitigation plan, based on the output
      of the vulnerability assessment      , specifying the mitigation measures and verification procedures. 

      b) The food fraud mitigation plan shall be implemented and supported by the organization’s
      FSMS.
      c) The plan shall comply with the applicable legislation, cover the processes and products
      within the scope of the organization and be kept up to date.
      d) For food chain category FII*, in addition to the above, the organization shall ensure that
      their suppliers have a food fraud mitigation plan in place.

*FII = Food brokering, trading, and E-commerce activities

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IFS Food

The new version of IFS Food, Version 8, has had its requirements significantly re-worded.  The clause numbers remain the same: 4.20.1 to 4.20.4.

The new wording is easier to understand and makes the requirements more easily enforced for auditing.  But does not change what a food business must do to comply.  For example, while the previous version required that food fraud vulnerability assessments be reviewed “at least annually and/or in the event of increased risks”, the new version says they should be reviewed “at least once within a 12-month period or whenever significant changes occur.”

The only notable change to meaning is that the phrase “full commitment from the senior management” has been removed from clause 4.20.1, presumably because it is not easily auditable.

Food Fraud Requirements of IFS Food, Version 8 (with new wording in blue)

4.20 Food Fraud

4.20.1 The responsibilities for a food fraud vulnerability assessment and mitigation plan shall be clearly defined. The responsible person(s) shall have the appropriate specific knowledge and full commitment from the senior management.

4.20.2 A documented food fraud vulnerability assessment, including assessment criteria, shall be documented, implemented and maintained.  The scope of the assessment shall cover all shall be undertaken on all raw materials, ingredients, packaging materials and outsourced processes, to determine the risks of fraudulent activity in relation to substitution, mislabelling, adulteration or counterfeiting. The criteria considered within the vulnerability assessment shall be defined.

4.20.3 A documented food fraud mitigation plan shall be documented, implemented and maintained developed, with reference to the vulnerability assessment, and shall include the testing and monitoring methods.  and implemented to control any identified risks. The methods of control and monitoring shall be defined and implemented.

4.20.4 The food fraud vulnerability assessment shall be reviewed, at least once within a 12-month period or whenever significant changes occur. regularly reviewed, at least annually, and/or in the event of increased risks. If necessary, the food fraud mitigation plan shall be revised/updated accordingly.

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Takeaways

There are no big surprises in these two updates, but it pays to read all clauses carefully.

The good news is that if you have to stay up to date with multiple standards we’ve got you covered – at least when it comes to staying on top of food fraud requirements 😊

We’ve just released Edition 3 of our authoritative guide to current food fraud requirements in all major food safety standards, for auditors, consultants and food fraud specialists, with updates for the amended FSSC and IFS requirements.

Get all the food fraud requirements of all the major standards in one convenient e-book (updated)

Download it instantly, print or save it and keep it as a handy reference.

It costs USD27, which includes all future updates.  Learn more about it 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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How To Do a Vulnerability Assessment for Food Fraud

Updated 30th December 2022

What is a vulnerability assessment?

 

A vulnerability assessment is a risk-assessment-style evaluation of a food’s vulnerability to food fraud.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

Vulnerability assessments are also done to assess the threat of a malicious attack on food.  Malicious attacks include attacks conducted for extortion, ideological reasons or terrorism. We call these issues of food defense. To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

Why ‘vulnerability’ and not ‘risk’? 

 

  • A risk is something that has occurred before and will occur again. A risk can be quantified using existing data.
  • A vulnerability is a weakness that can be exploited.  A vulnerability can lead to a risk.

Food fraud is difficult to estimate and quantify, so we use the word vulnerability rather than risk.

Why do a vulnerability assessment?

 

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]