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Tip-truck to table: waste diversion fraud

Organised crime groups are funnelling relabelled food back onto shelves

I’ve been wondering … what exactly happened to the 160,000 pounds (72,600 kg) of frozen shrimp that were recalled in the US in mid-2025 in relation to the radioactivity scare? Yes, it was recalled, but what happened to it after that?

What did the recalling companies and retailers actually do with each of the hundreds of thousands of 1.25 lb (570 g) bags of product? Did they empty the contents of every one and shred each package so it couldn’t be reused? Did they arrange for secure disposal with a trusted waste company and require a certificate of destruction? Or did they just dump them in a skip bin and let a contractor take them all away?

And why does this matter anyway?

It matters because the results of Operation Opson XIV have just landed. And they show that waste diversion crimes are at “unprecedented levels”.

Reminder: Operation Opson is an annual law enforcement initiative coordinated by INTERPOL and Europol with the aim of detecting and removing counterfeit, substandard, and fraudulent food and beverages from the market, and dismantling organised crime groups linked to such activities.

What are waste diversion crimes?

Waste diversion crimes in food involve illegally redirecting food, drink, or feed that is marked for disposal—such as expired, rejected, or unsafe goods—back into the human food supply chain through acts like relabelling or repackaging.

Photorealistic landscape image of identical cans with altered expiry labels in a warehouse.
Operation Opson XIV uncovered criminal-network- linked waste diversion crimes at unprecedented levels.

What do waste diversion crimes look like?

Here’s a hypothetical…

What if a seafood distributor involved in the recent US recalls decided the frozen shrimp was too valuable to throw away? What if senior management decided to make a few extra dollars by relabelling the cartons of product that had been returned to them rather than destroying them as required?

Could the distributor simply rebrand them or oversticker the cartons, add new expiry dates and keep them in the freezer until everyone has forgotten about the recalls, then sell them months or years later?

The short answer is yes.

It’s illegal and immoral, of course, but, with the shrimp worth $4 to $10 per pound, even a small quantity handled in this way can generate meaningful profits out of thin air – especially if the distributor received credits or refunds for the recalled stock.

Frozen seafood lasts many years – a man in Singapore was sentenced in 2023 for crimes related to storing frozen seafood that was almost 10 years past its expiry date – so there is plenty of scope for crime here.

In a different scenario, let’s imagine the seafood distributor does the right thing and sends the recalled shrimp for disposal.

In this scenario, what if the waste disposal company somehow had links to organisations that could relabel or repackage the shrimp and sell it back into legitimate supply chains later?

What if the waste disposal company didn’t just have links to criminals but was actually owned by an organised crime group that also owned repackaging facilities, warehouses and legitimate food distribution companies – a vertically integrated (mostly) legitimate supply chain? In this case, diverting the recalled shrimp back to retailers and restaurants would be easy.

But surely that’s too far-fetched, I hear you say. Sorry, I’m afraid it isn’t.

And anyway, Operation Opson is mostly in Europe. Surely this sort of thing isn’t happening in places like the USA? Sorry, I’m afraid it is.

The following story is not a hypothetical, but a real incident that happened in the United States.

The roadside spilling of a truckload of Skittles confectionery on its way to a cattle ranch, where it was destined for animal feed, made news headlines in 2017. When people protested that cows should not be fed Skittles, the brand owner, Mars, told reporters that the confectionery had been sent for destruction, saying they had no idea how the candies ended up on their way to a farm1.

Waste disposal crimes today

Things have changed since 2017. The price of food has increased dramatically, food security has fallen significantly, even in wealthy countries. There is also a growing body of evidence that documents the involvement of organised crime groups in food, in addition to typical crime sectors such as drugs and guns.

Today’s global landscape has made waste diversion crimes more attractive, not less.

In 2023, European law enforcement agencies dismantled two large crime groups that were reselling expired food after re-printing expiry dates or applying new labels, with 27 people arrested for their roles in a million-euro operation based in Lithuania, and selling food across multiple countries. They also arrested 3 people in Italy. In total, the agencies confiscated more than 1.5 million food and beverage items in the operations. The Lithuanian operation had been active since 2021.

At the time, Europol told reporters, “The phenomenon [of waste diversion crime] is new in its scale and diffused across several EU member states,”

Europol assured the industry that the criminals were working in food disposal, not food production, saying “There is no involvement of food producers, as intermediate suppliers or other entities working in food disposal are used as facilitators in this particular criminal activity.”

“Entities working in food disposal are used as facilitators in this particular criminal activity.” Europol (2023), via Securing Industry

In 2025, the situation seems worse. The most recent Operation Opson, Opson XIV, has just concluded, with 13 organised crime groups disrupted, 101 arrest warrants issued and €95 million worth of food and beverages seized.

One of the major trends for Opson XIV, said Europol, was finding waste disposal companies infiltrated by organised crime groups, which were using the waste companies to gain access to food destined for destruction.

This is not a new phenomenon, but this year, says Europol, the scale is “unprecedented”.

Examples everywhere?

Have you ever seen food that’s been through the waste diversion chain? You probably have, without even knowing it.

I can think of three incidents that could be linked to organised crime in waste providers.

1. Dodgy Diet Coke

‘Not right’-tasting Diet Coke discovered in London in 2025 could be expired product fraudulently reintroduced to the market – artificial sweeteners in diet soft drinks lose their sweetness, rendering old drinks tasting like soda water. Read more on the Fake Coke scandal.

2. Jars of herbs containing glass

In 2023, I reported on a waste disposal company in the Netherlands that was selling food products it had promised to destroy. The crimes were uncovered after a consumer was injured by glass in a jar of herbs from a batch sent for destruction.

The waste company was providing declarations of destruction which were false. A key person at the waste company had previously been convicted of environmental crimes.

3. Spaza shop mystery deaths

In January, I wrote about the thousands of unexplained deaths in South Africa attributed to food purchased from spaza shops (small, independent and lightly regulated retail outlets).

A key complaint about the food from these shops is that it is often expired. Much of it appears to have been illegally imported by foreign nationals operating the stores without proper immigration status.

Video footage of a raid on one shop showed foods such as savoury crackers in transparent inner packs without their outer packaging or labels. Because they are missing traceability elements such as outers and labels, these foods could be from non-legitimate supply chains.

Officially, it’s said that Spaza shop owners use collective purchasing practices to keep prices low; however, it’s possible that groups of spaza shop owners source their products from overseas suppliers with links to waste disposal companies.

Takeaways for food professionals

Enforcement agencies are discovering the presence of organised crime groups in food waste disposal operations at unprecedented levels. Food that is intended for destruction and disposal is being diverted back into the human food supply chain after expiry dates or entire labels are altered or replaced.

Purchasers of packaged foods, such as grocery stores, independent retailers and food service outlets like takeaways, restaurants and cafes should obtain their supplies from legitimate, authorised stockists and wholesalers.

Manufacturers should be vigilant when disposing of packaged or branded materials.

Supplier approval processes should include the vetting of waste disposal contractors. Background checks are recommended – for example, have key personnel got a history of criminal convictions (as was the case in the Netherlands example)?

Certificates of disposal/destruction should be verified where possible.

As a former-soft-drink-company-employee told me in response to my Diet Coke story, “The correct disposal of branded waste and reject materials is a key factor for limiting the opportunity for these crimes.”

When purchasing food as a business or consumer, be on the lookout for:

  • Food that seems too old, despite being within date
  • Outer cartons and individual packs that are more scuffed, damaged or worn than expected
  • New suppliers that appear unexpectedly and offer products from multiple disparate brands, sometimes at lower-than-usual prices
  • Corner shops/spaza shops/tuck shops selling food in inner packs marked ‘not for retail sale’, or without exterior packages that would carry the batch codes or date markings
  • Packages with foreign language labels and no local information.

If in doubt about any such food, keep a sample and contact enforcement agencies and the brand owner to describe your concerns. Big food companies will investigate and take action against waste disposal crimes affecting their brands.

… and be on the lookout for suspicious frozen shrimp in the US for the next year or two…

In short: The involvement of organised crime groups in waste disposal operations was found at unprecedented levels in the latest Europol anti-food crime operation, Operation Ospon XIV 🍏 Food intended for destruction is being diverted back into the human food supply chain, often with altered expiry dates or new labels 🍏 Purchasers are warned to be aware and to report suspect products to the brand owner and enforcement agencies for investigation 🍏

Main source:

Europol (2025) Counterfeit and substandard food worth EUR 95 million seized in global operation (Operation Opson XIV). Available online: https://www.europol.europa.eu/media-press/newsroom/news/counterfeit-and-substandard-food-worth-eur-95-million-seized-in-global-operation

 

This article was originally published at The Rotten Apple – a weekly newsletter for food professionals

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Case study: Double brokering leads to disappearing tequila

A food fraud case study

In the past, I’ve told you that food-waste-diversion crimes are being detected at unprecedented levels in Europe, and described how enforcement actions coordinated by Europol had dismantled 13 organised crime groups in their most recent anti-food-fraud operation.

This week’s case study explores diversion-style crime from a North American perspective. This case doesn’t involve the diversion of waste back into the supply chain, but, like those discovered in Europe, it does involve an organised crime group.

When: November 2024

What: 24,000 bottles of Santo Tequila worth more than $1 million.

How: Criminals used non-existent trucking companies and a process called ‘double-brokering’ to gain access to the goods, ensuring they were never delivered to their intended destination.

Details:

In November 2024, a shipment of premium Santo Tequila left Mexico on its way to a warehouse in Pennsylvania, via Texas. The shipment comprised the entire batch of a special lot of tequila that had taken 3 years to make, especially for the 2024 holiday season.

After crossing the border into Texas, the consignment was moved to two semi trucks and entrusted to a logistics company hired by Santo Spirits to deliver the tequila to its warehouse in Pennsylvania, a 2.5-day drive north.

The logistics company hired a trucking company to make the delivery. It outsourced the job to two other trucking companies through a bidding process called double brokering. Drivers hired by the second companies collected the trailers and drove away with the tequila.

In Pennsylvania, the tequila did not arrive as scheduled, and Santo was told there had been a mechanical problem with a truck. A few days later, the shipment still hadn’t arrived. Santo was told the mechanical problem had been worse than first believed, but the delivery would arrive soon, around 5 days later than scheduled.

GPS tracking provided by the logistics company showed the truck was definitely en route. A few days later, Santo was told the truck’s GPS showed it was near the warehouse in Pennsylvania.

But the truck – and the tequila – never arrived.

Investigators discovered the trucking companies had told the drivers to take the trucks to Los Angeles. The trucking companies were fake businesses, with fake online profiles, phoney letterheads, email addresses and phone numbers, and possibly operated by people outside the USA.

The emails about the mechanical issues were falsehoods, and the GPS tracking had been faked.

The drivers, however, were genuine, hired by the fake trucking companies.

The bigger picture:

This type of cargo theft, involving redirection of goods to other locations by remote operators, has increased by more than 1,200% in four years, according to a cargo theft investigator who assisted with the Santo Tequila case.

The Los Angeles Police Department (LAPD)’s special cargo theft unit says that in such cases, the goods are usually sold online or in stores. A recent ‘bust’ found $4.5 million worth of stolen goods in a warehouse.

The outcome:

Santo Spirits was luckier than most. The LAPD cargo theft unit tracked down one of the drivers, who told them he had been directed to drop the cargo in the San Fernando Valley. One truckload – eleven thousand bottles – of the missing batch were found at a warehouse in southeast Los Angeles two weeks after the heist. The other truckload was never found.

Source:

Alfonsi, S. and Chasan, A. (2025). Two truckloads of Guy Fieri’s tequila vanished last year. It shed light on a growing new crime. [online] CBSnews.com. Available at: https://www.cbsnews.com/news/double-brokering-guy-fieri-tequila-heist-60-minutes/.

🍏 Want more case studies? Check out the Food Safety Knowledge Vault on The Rotten Apple🍏

This article was originally published at The Rotten Apple – a weekly newsletter for food professionals

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Fraud Risks for Cocoa and Confectionery Businesses

Chocolate’s supply chain is vulnerable to changes in weather, farming practices, and global trade networks. It is a truly global product, with the beans mostly grown in developing nations and processed into chocolate in wealthy nations.

Supply chain challenges include problems with cultivation, trade, sustainability, and compliance.

Threats to production

In recent years, the combined effects of extreme weather events, tree diseases and climate change in the world’s biggest cocoa-growing regions have severely impacted yields.

Cocoa farmers are reportedly abandoning their trees or choosing not to replace ageing trees as the crop becomes less profitable due to rising production costs and declining yields.

In Côte d’Ivoire, for example, prolonged droughts, unpredictable rainfall, and increased plant diseases like swollen shoot disease have made cocoa farming unprofitable for many, leading farmers to leave their plantations or switch to alternative crops.

In Ghana, the world’s second largest cocoa producer, gold mining is now impacting cocoa production and taking over fertile land once used for cocoa growing.

The area of land used for growing cocoa is decreasing in Ghana. Data source: FAO.org

 

The Swiss media outlet Swissinfo reported in 2022 that cocoa farmers were selling their land to illegal gold miners, with swathes of farmland transformed into wastelands dotted with piles of clay contaminated with mercury, a by-product of gold extraction.

In the same year, a survey by the Ghanaian cocoa board revealed that 19,000 hectares of cocoa plantations had been lost, taken over or damaged by illegal gold mining.

With recent large increases in the price of gold and more problems with cocoa production due to disease and climate change, there is increasing recognition that more cocoa farmland will be lost to mining in 2026..

Cocoa futures (in USD per tonne) reached an all-time high in April 2024 and remain at more than 3 times the average price in 2023. Chart: Tradingeconocmis.com

 

With production declining, cocoa prices are rising. They increased by 25% in the two years to 2024.

Prices have since stabilised somewhat, but cocoa futures today are still more than three times higher than they were in 2021 – 2023.

Read more: 🍏The surprising link between illegal gold mining and chocolate 🍏

Threats to trade and compliance

Chocolate has always been considered an at-risk product for unethical labour practices, particularly in West Africa, which supplies around 60 to 70% of the world’s cocoa. Structural poverty, low farm-gate prices, and lack of bargaining power among farmers create conditions where forced labor, debt bondage, and child trafficking can occur to meet demand and maintain profitability.

Estimates indicate that over 1.5 million children are involved in child labor on cocoa farms in Ghana and Côte d’Ivoire, with many engaged in hazardous work, and there have been documented cases of both child and adult workers being subjected to exploitative or slave-like conditions in other cocoa-producing countries as well.

In 2023, the commodities trader Cargill was ordered to pay more than $120,000 by a Brazilian court after prosecutors alleged it did not know the extent of child labour in its Brazilian cocoa supply chains because it purchases from hundreds of producers, co-operatives and merchants. Cargill denied the allegations.

In 2021, Hershey and the Rainforest Alliance were sued for false advertising in the US, with Hershey accused of turning a blind eye to child labour in their supply chain and the Rainforest Alliance accused of being unable to prevent or even account for it.

Certification schemes like Rainforest Alliance and FairTrade are supposed to give assurance of ethical work practices in the production of the certified foods, but their efficacy has been questioned.

Researchers who reviewed the ability of schemes like FairTrade to assure child-labour-free processes in 2018 were told by a certifier “We are working with around 11,800 cocoa farmers, so we have not been able to visit any farms as of now”. Instead, they relied on farmers’ cooperatives to verify the working standards at farms.

The cooperatives receive a premium for certified cocoa, compared to uncertified cocoa, so self-reporting about their farmers’ compliance with certification standards for labour practices is problematic.

In 2025, the bigger concern with compliance and sustainability in cocoa is related to the coming enforcement of the European Union Deforestation Regulation (EUDR). Under these rules, due to be enforced from December 2025, cocoa and chocolate products imported into the EU must be proven to be deforestation-free, meaning the land used for cocoa production has not been deforested after 2020.

The importer must provide geolocation data, traceability to farm level, and comprehensive documentation at multiple points in the supply chain.

In West Africa, the major growing region, there are significant differences between the way beans are regulated and priced between the two largest producers, Cote d’Ivoire and Ghana.

Some cocoa farmers in Côte d’Ivoire sell their beans to traffickers who smuggle them out of the country to be resold in places such as Guinea and Liberia, where they can fetch a higher price than the government-mandated prices in their country. In 2024, 150,000 tonnes of Ivorian cocoa beans were said to have been illegally exported in this way.

Threats to forests

In 2024, a media outlet in France reported that rules and checks implemented by the Côte d’Ivoire government and designed to prevent deforestation had resulted in cocoa farmers leaving the country and setting up plantations in neighbouring Liberia instead.

Liberia, they say, has “an almost total lack of monitoring”, making it attractive for farmers who grow beans on newly deforested land there, before moving the beans back into Cote d’Ivoire to avoid traceability checks. Tens of thousands of cocoa farmers have reportedly crossed the border already, threatening thousands of hectares of virgin forest.

Chocolate and food fraud

With supply chains both complicated and threatened by multiple supply-demand imbalances and uncertainties, it’s no surprise that cocoa is extremely vulnerable to food fraud, with cocoa beans claimed to be organic, fair trade and ethically or sustainably sourced the most at-risk for fraud.

Fraud in cocoa beans can take the form of theft, smuggling, misrepresentation of fairtrade/rainforest status, false organic claims or misrepresentation of geographical origin; as well as simpler frauds such as adding rocks or sticks to bags of beans to increase their weight.

The EUDR, which includes significant traceability requirements and penalties for cocoa beans from recently deforested land, creates significant pressure on cocoa bean producers and traders to falsify bean origin and traceability data to make beans appear to have originated in non-deforested or ‘low-risk’ designated areas.

There is significant smuggling of cocoa beans between West African countries, due to price differences between countries, and this confounds traceability attempts.

In addition to fraud in cocoa beans, manufactured chocolate also has food fraud challenges.

Counterfeit chocolate – chocolate products packaged to look like premium brands but made without the permission of the brand owner – is perhaps the most commonly reported type of fraud in chocolate.

A notorious example of counterfeit chocolate is ‘Wonka’ bars, which periodically resurface in the United Kingdom. The Wonka brand is owned by Ferrero, which hasn’t sold Wonka chocolate bars in the United Kingdom for years.

The fake bars are produced or repackaged by unregistered businesses or individuals with no regard for hygiene or labeling regulations, making them potentially unsafe to eat, particularly for people with food allergies due to undeclared allergens. Incidents have included unhygienic manufacturing conditions, incorrect or missing ingredient lists, and the use of fake business addresses on packaging.

Dubai-style chocolate products have also been counterfeited, including some that had to be recalled due to the presence of undeclared peanuts, almonds, cashews, and walnuts.

Chocolate confectionery has been affected by counterfeit-style food fraud

 

Other frauds that have been unmasked include an ‘artisan’ producer in Italy who was allegedly buying industrially produced Easter chocolates, discarding the wrapping and then reselling them as ‘own production’ (i.e., artisanal); and smuggling operations.

In January 2025, a woman was caught in Germany with 460 bars of chocolate concealed in her luggage after an international flight. Customs officials suspect the chocolate bars were being imported for commercial sale, because of the large number of bars and because chocolate of that type had been made popular on TikTok, with each bar fetching around 25 euros.

The bars had no ingredient or allergen information on their packs, posing a health risk to consumers. If successful, the smuggling would have resulted in the woman evading more than 330 euros of import duties.

In February 2025, authorities in Europe discovered chocolate from the United Arab Emirates and Turkiye made with hydrogenated palm oil instead of cocoa fat, containing undeclared colourants and with a higher fat content than declared.

And in July 2025, Dubai-style chocolate from Turkiye was found to contain undeclared colourants (green mulberry leaf, brilliant blue FCF (E 133)) in Dubai chocolate.

It’s likely these frauds are just the tip of the iceberg. I estimate there are many instances of inauthentic claims made about artisanal and boutique chocolate products in wealthy countries. ‘Single origin’ chocolate, organic chocolate and fair trade chocolate products are moderately likely to be affected by inaccurate claims due to problems in their supply chains or intentional deception by the brand owner.

This article was originally published at The Rotten Apple – a weekly newsletter for food professionals

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Fraud in Botanical Products and Dietary Supplements

Fraud in dietary supplements and herbal medicines is dangerous and costly

 

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

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

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

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

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

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

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

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

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

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

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

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

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

Fraud in Botanicals

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

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

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

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

Fighting Adulteration in Botanicals

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

🍏🍏🍏🍏🍏

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

Main source:

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

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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  ***