Food Fraud Advisors

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Future and emerging threats of food fraud

Food fraud: you don’t want it.

  • If you are manufacturing, wholesaling or retailing food or beverages, fraudulent activities within your supply chain pose risks to your brand and to your customers.
  • Different food types vary in their susceptibility to food fraud.
  • The risks change over time.
  • Purchasers of food and food ingredients must remain vigilant about new and emerging risks.
  • The requirement to monitor emerging and predicted food fraud issues is a part of all major (GFSI) food safety standards.

Learn how to monitor food fraud threats here.

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Learn the lingo; food fraud terms explained

Food fraud occurs when food or drink is sold in a way that deliberately misleads or deceives consumers or customers for financial gain (Food Fraud Advisors, 2015)

(other definitions)

Food fraud occurs in two different forms:

1. Fraudulent activity that does not involve tampering with the food itself:

This includes activity such as avoidance of taxes, duties and quota restrictions (fishing), fraudulent paperwork such as forged importation documents, misrepresentation of origin, changing best-before dates and counterfeiting of popular brands.

2. Adulteration of food for economic gain:

This is sometimes referred to as economically motivated adulteration or EMA.  In this phrase, the word ‘adulteration’ is used to encompass many types of tampering, such as adding unauthorised substances, substituting undeclared substances for genuine components of a food or diluting a food product with cheaper substances.

Food fraud is a type of food crime, with food crime including food fraud and other activities such as the use of food shipments to mask drug trafficking and money-laundering through the trading of food and food commodities.

food fraud,defense,safety,security

Food fraud and the risks it presents to the food industry is a separate subject to food safety, although fraud-affected food can be unsafe.  Food safety relates to unintentional contamination of food and the presence of naturally occurring contaminants.

Food defence (food defense) is a term that has come to be defined as the effort to prevent acts of adulteration that are intended to cause harm to a food business or to consumers, such as acts of terrorism or attempted extortion.

Food security, as defined by the World Health Organisation exists “when all people at all times have access to sufficient, safe, nutritious food to maintain a healthy and active life”.

Risk or vulnerability?  In the language of food fraud, the term risk is usually replaced with the term ‘vulnerability’, so food standards bodies are increasingly talking about vulnerability assessments rather than risk assessments.  ‘Vulnerability’ is used because food fraud ‘risks’ do not exactly fit with the accepted definition of risk as something that has occurred frequently, will occur again and for which there is enough data to make quantitative assessments.  Vulnerability is a better term for food fraud, due to the fact that the ‘risk’ of a specific fraudulent activity occurring cannot be quantitatively assessed.

Horizon scanning is another term that has been co-opted to the language of food fraud.  Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  It is used across many industries, including the financial and health care industries.  Within the food industry, horizon scanning refers to the act of collecting information about current trends in food production and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to affect coffee production which could drive up prices and increase fraudulent activity in that sector.  Click here for the complete low-down on horizon scanning.

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.

Intentional Adulteration:  Although food fraud activities often involve the intentional adulteration of food with unauthorised substances, within the food safety industry, Intentional Adulteration has recently been given a more specific meaning.  And it is not related to food fraud at all.  It is related to food defense, and more specifically to activities intended to cause wide scale harm to consumers.  There is a rule within the USA’s Food Safety Modernization Act (FSMA), that addresses these activities.  It is known as the Intentional Adulteration rule.  According to the US FDA (2019), Intentional Adulteration is the deliberate contamination of food with a biological, chemical, radiological, or physical agent by an individual or group of individuals with the intent to cause wide scale public health harm.  How to protect against intentional adulteration. 

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Five things every food safety professional should know about food fraud

1. Food fraud is in the spotlight

Food fraud has been around for thousands of years but has become more prominent in the food safety and food certification industry in the last few years, following the European horse meat scandal of 2013.  Although no food safety problems arose during that incident, it was realised that similar incidences could have serious impacts on food safety.  For that reason, food fraud prevention requirements were introduced into all major food safety management system standards between 2017 and 2020.

2. New terminology

Definitions related to food fraud and food integrity have been refined in the last five years and there is now consensus on the four key terms below, although the term food security still causes confusion.

food fraud,defense,safety,security

  • Food safety relates to issues of unintentional contamination, with the aim of reducing exposure to naturally occurring hazards, errors and failures in food systems.
  • Food fraud was defined by  Spink and Moyer (2011) as “a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.”  More recently that definition has been updated to capture all types of food crime: Food fraud is deception, using food, for economic gain (Food Fraud Initiative, Michigan State University).  Within food fraud there are types of fraud that involve tampering with the food by adulterating or diluting the food.  This type of fraud is sometimes called ‘economically motivated adulteration’ (EMA).  Other types of fraud that do not involve adulteration are also deemed to be ‘food fraud’.  These include black market and grey market sales, theft, illegal importing, avoidance of tax and counterfeiting.
  • Food defence is a term that has come to be defined as the effort to prevent acts of adulteration that are intended to cause harm to a food business or to consumers, such as acts of terrorism or attempted extortion.
  • Food security is unrelated to food fraud but is instead an issue of food supply and food access for populations who are under threat from food shortages.

Other terms to know:

  • Vulnerability assessments are assessments of vulnerability to food fraud, either at the raw material, product or facility level.  Within the USA the term vulnerability assessment can also refer to a food facility’s vulnerability to malicious tampering of product on its site, either by its own employees or external forces.   Learn more about vulnerability assessments.
  • Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  Within the food industry, horizon scanning means the act of collecting information about current trends and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to reduce coffee production which could drive up prices and increase fraudulent activity in that sector.
Coffee,authentic,fraud,horizon scanning
Coffee harvests are being affected by climate change

 

3. Food safety standards have become more rigorous

Food fraud prevention and mitigation measures are now a requirement of all major food safety management system standards.  The Global Food Safety Initiative (GFSI), a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe, sets guidance for food safety standards.  Well known GFSI standards include BRC, FSSC 22000 and SQF.  Between 2015 and 2017, all GFSI food safety standards were updated to include requirements for food companies to perform a food fraud vulnerability assessment and have a food fraud mitigation plan in place.   Click here for the GFSI Food Fraud Position Paper.

The new requirements for vulnerability assessments and mitigation plans require more resources for most food businesses, particularly those with large numbers of raw materials and suppliers.

4. There are new regulatory requirements for food businesses

The Food Safety Modernization Act (FSMA) in the USA has been implemented for most food businesses in the previous few years.  Within the FSMA rules, food businesses are required to address hazards from adulterants introduced for the purposes of economic gain.  These must be included in food safety hazard analyses and if hazards are found, preventive controls must be implemented.  This means that economically motivated adulteration (EMA), a subset of food fraud, must be addressed under the new FSMA rules.

The Food Safety Modernization Act (FSMA) also includes specific requirements for ‘food defense’ which are aimed at preventing malicious adulteration and tampering as well as fraudulent adulteration.  This is known as the Intentional Adulteration (IA) rule.  The IA rule is being progressively implemented in the USA.  FSMA rules for IA will also be enforced internationally for all food facilities that manufacture food for export to America.  Click here for US FDA’s food defense guidance

food defense,vulnerability assessment,FSMA,
All American food companies will be required to have a food defense plan

 

5.  Detection of food fraud remains a challenge, despite new lab techniques

Our ability to detect food fraud has improved over the last few years, but challenges remain.  There are many technologies available, from traditional ‘wet’ chemical tests to spectroscopy and chromatography to modern forensic DNA methods.   Protein isoelectrofocusing (a type of electrophoresis) is a conventional test that provides information about the source of various milk proteins in a cheese and can be used to detect cows milk in “buffalo milk” mozzarella, for example.  PCR (polymerase chain reaction) techniques, in which a cow milk-specific gene is amplified and detected are being developed for cheese testing and they are claimed to be more specific.

Coffee variety testing has traditionally been done using Fourier transform infrared spectroscopy, a method that exploits the different amounts of chlorogenic acid and caffeine in robusta and arabica varieties.  However, a new method that exploits the different mitochondrial genetic markers in the two varieties will soon be able to achieve the same results quickly and easily in the field with ‘lab on a chip’ technology.

Researchers looking for fraudulent aloe vera can exploit its distinctive NMR (nuclear magnetic resonance) profile, due to the position of acetate groups within a key polysaccharide in the plant.  The NMR profile represents a ‘fingerprint’ for aloe vera.

Another type of ‘fingerprinting’ is based on the spectra created by different ratios of stable isotopes.  For example, it is possible to tell the difference between corn-fed and wheat-fed chicken, using stable isotope ratio mass spectrometry by comparison with databases of reference samples.  This method has also been used to check provenance claims for meat and wine products.

Authentic beef mince
What meat is that?

 

Despite the surge in technology surrounding food fraud detection, it remains difficult to detect fraudulent adulteration unless you know what you are looking for.  As an example, DNA testing can be used to determine if beef mince has been made from a cow but can’t tell me whether it has been adulterated with undeclared beef offal.  Olive oil that is suspected of having been adulterated with other edible oil can easily be tested for such adulteration in a lab test, but verifying its country of origin is more difficult.  Adulteration of ‘arabica’ coffee with the cheaper robusta variety can be detected with a simple test but that same test will not disclose whether ground coffee has been adulterated with cheaper fillers such as corn, soybean or wheat, a practice which is common in some markets.  There are now a number of ‘fingerprinting’ techniques that are designed to ‘flag’ any sample that is not authentic, no matter what the adulterant, however they can only be used if there is already an extensive database of authentic samples with which to compare the suspect sample.  Australian honey brand owners who were caught with supposedly inauthentic honey in an NMR-based fingerprint test claimed that the database used in the testing, which was done in Germany, was not suitable for testing Australian honeys.  Read more about the Australian honey scandal.

We have a lot of tools in our arsenal to answer questions about fraudulent food but those tools are only useful if we ask the right questions.

Need to learn more?  Want practical advice from expert food scientists? Click here for a free introductory consultation.

 

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September food fraud update; trade wars, fruit scares and spuds

The ‘trade war’ between the USA and China is really hotting up, with China having imposed import tariffs of up to 25% on US lobsters and other food products in the previous 2 months.  The presence of tariffs greatly increases the risk of fraudulent cross-border activities; Food Fraud Advisors predicts that the new China tariffs will lead to significantly more food fraud within the Chinese-American trade sector as well as having a knock-on affect on food trade internationally.

There have already been allegations of fraud related to the tariff imposition in the North American lobster market.  Canadian lobsters can be imported to China without incurring the tariffs imposed on lobsters from the United States.  It has been alleged that lobsters grown in the USA are being shipped to Canada, re-labeled as Canadian lobsters then exported to China.  Canadian lobster growers fear damage to the ‘Canada’ brand from these activities.

The strawberry scandal in Australia has hit local consumers, retailers and growers hard.  It started with two consumers in the state of Queensland finding metal needles inside fresh strawberries.  The affected brand and its sister brand from the same grower were pulled from shelves.  Within days another needle-like object was found in strawberries from a different brand in a different state; the fruit source was completely different and the incident was labelled a ‘copycat crime’.  In Australia strawberries are typically sold to consumers in clear clam-shell containers with four air holes in the top surface.  The air holes are large enough to allow access to the fruit inside with a small sharp object like a needle while the strawberries are displayed on a supermarket (grocery store) shelf.  Public response has been confusion; why would anyone want to do such a thing?  Since then, other fruits, including apples and bananas have been similarly affected, again, in what appear to be completely independent occurrences.  The food safety sector in Australia is at a loss as to how to prevent this type of incident; fruit is by necessity displayed and accessible for consumers to touch prior to purchase, leaving it vulnerable to malicious adulteration.

Meanwhile, strawberry growers in Australia, who were already struggling to get good prices for their bumper harvest, have seen demand for their fruit plummet.  Media outlets have published reports about farmers who are dumping tonnes of unwanted fruit because the wholesale price has fallen below the cost of production.

Whole potatoes are generally thought to be at low risk of food fraud because of their relatively low value and because of their easily recognisable form.  However, like all fruit and vegetables, they are at risk of being misrepresented with respect to their geographic origin and their variety.  Growers groups have demanded that government authorities investigate allegations of potato fraud in Ireland, after a successful campaign to encourage consumption of locally-grown Queen potatoes.  It has been alleged that imported potatoes and potatoes of other varieties are being re-labelled as Irish Queen potatoes, providing an economic gain for the perpetrators of this fraud.

 

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Coming to a store near you….

Keeping abreast of food fraud and food safety news is a daily activity and one of my favourite work tasks.  This week, as I skimmed through food industry trivia and pondered the launch of chocolate cheese (seriously), the two most alarming and unusual food fraud incidents I came across were news of thirty five businesses who were caught by Chinese authorities adding opium to food and a British business that was prosecuted for selling ‘almond’ powder that contained peanut.  By the way,  you did see that correctly: opium.  And just for the record, opium is not a permitted food additive.  Peanut-contamination of anything is, of course, a very serious risk to the safety of allergic consumers and has resulted in deaths in recent years.  It’s tragic to see that this type of adulteration continues to occur.

Having digested thousands of words of information about prosecutions, investigations, trends in food fashions and the changing regulatory landscape, I began to notice some patterns and found a couple of big red flags for future risks of food fraud.

Halal

Halal certifications are increasingly needed for market access for almost every food type at both the retail and wholesale level.  A halal product is often indistinguishable from its non-halal counterpart which means that everyday consumers are not able to verify food sellers’ claims about halal status.  Falsely claiming halal for a food item is an easy fraud to perpetrate, especially during the retail sale of un-packaged food in restaurants and takeaway stores.  Halal fraud can be as sophisticated as forgery of certification documents accompanying bulk shipments of food or as simple as dishonest signage in a takeaway store.  There have been a number of incidences of halal fraud in the news lately and these are almost certainly the tip of the iceberg.  I see very high risks in the South East Asian countries of Indonesia and Malaysia; these being some of the world’s biggest markets for halal food and having variable and sometimes chaotic food supply chains accompanied by uneven regulatory enforcement.  However, halal forgery can happen even in the most sophisticated markets with a recent prosecution in the United Kingdom in which the fraudster is alleged to have netted a quarter of a million pounds.  With this kind of money up for grabs, you can expect halal fraud to continue.

Is this meat halal?

Probiotics

Probiotics are among the hottest food ingredients for the healthy eating market right now.  New technology is claimed to enable probiotic bacteria – good bacteria – to survive in an ever-increasing range of food types, taking them beyond traditional yoghurts and ‘Yukult’ style dairy drinks.  Probiotic foods command a premium price and, as with many of the most vulnerable food fraud targets, the probiotic components are indiscernible to consumers.  There is a real and growing risk that fraudulent claims will be made about the quantity and types of live bacteria in food products, with the possibility of both accidental and deliberate frauds.  Any food business can make a mistake with formulations and shelf life, leading to discrepancies between the quantity of live bacteria in the food and what is claimed on the pack.  Premium brand owners are less likely to risk their reputation with unsubstantiated claims and these businesses are more likely to have the in-house expertise and resources to properly verify their on-pack claims.  It’s the smaller food companies and newer brands that I worry about:  they are much more likely to find themselves inadvertently or knowingly selling ‘probiotic’ products that don’t live up to the marketing hype.

Cold Brew Coffee

Can you fake cold brew coffee?  Cold brewed coffee appears to be here to stay but it has a high price tag and would be easy to fake.  Could the average consumer taste the difference between conventional and cold-brew coffee?  I’m pretty sure that I couldn’t, especially when served icy cold or with lots of milk.  The production method for cold brewed coffee is slower than conventional brewing, which usually means more costly.  And that means food businesses could be tempted to cut a few corners.  Even hipster brands that build their messages around product authenticity can find themselves in a scandal when financial pressures increase, as was the case with an ultra-premium bean-to-bar chocolate brand recently.  I wouldn’t be surprised to see a few incidences of fraudulent claims about cold-brewed coffee hitting the headlines this year.

Cold brew coffee: hot food fraud risk