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How food fraud is uncovered; two cases of origin fraud

Origin fraud occurs when a food is misrepresented with respect to its geographical origin; it’s a type of fraud that can be categorised as ‘mislabeling’.

Examples of mislabeling include:

  • describing a fruit or vegetable as ‘organic’ when it was conventionally grown
  • cheeses and meats labeled as kosher or halal that are not
  • Spanish olive oil falsely declared as being ‘Italian’.  This is origin fraud.

Mislabeling is also called misbranding in some countries.  Because it is intended to deceive customers and consumers it is illegal under consumer protection laws and trade/contract laws just about everywhere.  Because almost every type of food fraud involves mislabeling to some extent, quoting statistics on mislabeling is difficult.  As an example, a botanical supplement labelled as 100% turmeric extract but that actually contains 15% filler is both mislabeled and diluted.  To make it even trickier, different organisations using different words to describe similar food fraud activities.  Learn more about classifying food fraud types in this great Food Safety Tech Article.  Suffice to say, mislabeling fraud is very common and, according to US Grocery Manufacturers Association, it affects around 10% of food products globally.

Coffee growers in Hawaii have launched a class action to protect their products

How do we expose origin fraud?  Typically, origin fraud is uncovered after authorities have been tipped off about suspect activity in a supply chain, either by people from within the supply chain or by competitors of the mislabeled product.   The evidence used to pursue the fraudsters often comes from either fraudulent documentation, or from testing of finished products.  This year we have seen an increase in the use of authenticity testing by representatives of ‘authentic’ brands to expose fraudulent products.  This is a trend that I expect to continue as test methods are improved, refined and can more easily be extended to assess specific product attributes.

I have been following this trend with interest and was reading, today, about alleged origin fraud in coffee in the United States. This is a case that is representative of the trend to use sophisticated test methods to authenticate finished product attributes.  Another recent example would be honey testing in Australia.  In the coffee case, growers from the Kona district of Hawaii have filed a lawsuit against retailers for allegedly selling ‘Kona’ coffee that does not contain a reasonable amount of coffee from the district. Kona coffee production is 2.7 million pounds, however more than 20 million pounds of coffee labelled ‘Kona’ is sold each year.  The plaintiffs claim to have analytical test results to support their claims.  Nineteen brands of coffee, sold by retailers including Walmart, Cosco and Amazon, have been named in the complaint.  Chemical testing technology underpins this current lawsuit, as it allows the coffee growers to show, for the first time, the actual Kona content of the coffee that is being allegedly mislabeled.  For this to be possible, the coffee growers would have had to organise for testing laboratories to create a database of chemical test results of authentic samples of Kona coffee.  Databases like this are used to model a product’s unique chemical fingerprint using sophisticated mathematical computations.  The test method can then be used to compare the ‘fingerprints’ of suspect brands against those of authentic products, such as Kona-grown coffee, and infer the amount of genuine material in each sample.  Developing databases for this type of testing is expensive and time consuming.  However, there are an increasing number of laboratories that have the machinery, skills and software to perform this work, so it is becoming more accessible to brand owners.

Specialty vinegars fetch high prices and can be vulnerable to economically motivated food fraud.

In cases that do not originate with product testing, it is activities in the supply chain that provide clues to origin fraud.  This month there have been reports of origin fraud for a specialty vinegar, Modena balsamic vinegar.  Modena balsamic is protected by a special geographical designation under European regulations.  According to these rules, Modena balsamic vinegar must be produced using grapes only from certain regions in order to be considered authentically ‘Modena’.  A massive fraud involving 15 million Euros worth of materials has been uncovered in Italy after a special operation by local authorities found that the wrong grapes were being used to produce this very expensive product.  Although operational details about this investigation are scarce, these types of actions by authorities are often initiated after authorities have received a tip off from someone connected with the supply chain.   Another example of such a tip-off includes this recent wine counterfeiting operation in which authorities became aware that a printing shop had received an order for 4,500 wine labels from a company that was not the brand owner.

More tip-offs and more testing are my predictions for 2019 and 2020.  These are going to lead to more investigations, complaints and enforcement actions against perpetrators of food fraud.  And that’s a win for everyone!

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From the food fraud desk

Happy New Year!

Last year was a busy year for Food Fraud Advisors.

Detection and enforcement actions increasing

Food fraud remains a hot topic in the food industry and is garnering stronger interest from the international anti-counterfeiting industry as well as international crime prevention groups like Europol and Interpol.  Recently, the international media have been discussing the role of organised crime syndicates in the food industry, particularly in the produce sector in Italy and in tuna trading in Europe.

Detections of food fraud and seizures have increased: almost a quarter of the 31 m counterfeit items seized by EU customs agents in 2017 were food stuffs.

In 2018 we were pleased to witness a number of serious law enforcement actions across the globe.  This is a trend which I hope will continue.  As an example, the people responsible for a long-running, fraudulent organic grain scheme in the USA were charged and pleaded guilty.  In Pakistan, the authorities have used new laws prohibiting the sale of unpackaged spices, which were created to reduce food adulteration, to seize 165,000 kg of spices and shut down 400 spice processing facilities.

Rising consumer awareness

Meanwhile, consumer awareness of food fraud is also rising.  Nearly three quarters of UK consumers think there is a serious problem with food fraud in their country and one quarter of consumers think they have experienced it first hand.

food fraud worries shoppers

Test method developments

In academia, new test methods for food fraud detection continue to be created and refined.  As exciting as it is to read headlines in journals about the latest scientific breakthrough, many of the research papers report on testing methodology that won’t be ready to be used by food manufacturers, wholesalers and retailers for some time.  One such exciting headline recently gushed that scientists have found a new ‘simple’ method to distinguish organic milk from conventional milk.   The headline did indeed to turn out to be too good to be true, with more work on a larger sample size needed to validate the method.   However, with organic products at very high risk of food fraud and detection being difficult, it’s great to see the analytical community working on these problems.

Our year working for you

Within Food Fraud Advisors we have been focussing on keeping up to date with our customers’ needs for the latest versions of SQF, BRC and IFS food safety standards.  Food fraud documentation is one of the top sources of non-conformities in food safety audits so many of our customers have been seeking help to boost their programs.

SQF’s standard in particular caused a few headaches for our clients.  SQFI did not publish any guidance for food fraud until after the implementation date for Edition 8.  As a result, many SQF-certified facilities needed our help to understand and implement programs to meet the new food fraud requirements before their first audits.  Within the  SQF guidance document there is a recommendation for senior managers to be trained in food fraud awareness and we were pleased to launch a short, practical on-demand training course to meet this requirement.   We’ve had great feedback about this course, and for only $59 it’s a great way to meet your continuous improvement and training requirements for 2019.

Also in 2018, our one-stop, deep-dive food fraud training course was re-launched, with new lessons, more downloadable templates, new content for food fraud teams and step-by-step instructions for creating and implementing a food fraud prevention program from scratch.   Check it out today. 

We look forward to working with you in 2019 and beyond.

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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 recently become more prominent in the food safety and food certification industry, 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 and food authenticity have been introduced into most major food safety management system standards within the previous two years.

2. New terminology is being developed

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

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 related to systems that are intended to prevent intentional contamination of food, whether that be for economically motivated reasons or for malicious reasons such as terrorism or extortion.  A food defense plan is a plan that aims to protect food from intentional contamination.
  • 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 often refers to a food facility’s vulnerability to malicious tampering of product on its site, either by its own employees or external forces.  Within Europe, and particularly as described in the most recent issue of the British Retail Consortium’s (BRC) food safety standard, a vulnerability assessment is an assessment of a food material’s susceptibility to food fraud.  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.
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Future coffee harvests are likely to be affected by climate change

 

3. Food safety standards have become more rigorous

Food fraud prevention and mitigation measures are being introduced into all major food safety management systems.  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 new ‘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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Investigating susceptibility to food fraud

This page contains information and links to help you investigate, understand and summarise incidences of food fraud that have occurred or may occur within a food or food ingredient.  Some foods are more susceptible than others to economically motivated adulteration, substitution and dilution.  Understanding the susceptibility of an ingredient or raw material type is an important part of every vulnerability assessment process.

Susceptibility is investigated in two parts.  The first part is the general susceptibility of the food and is irrespective of  where it is purchased or sold; this can be determined using publicly available information.  The second part is specific to an individual food business.  The specific susceptibility of a food or ingredient is dependent on the characteristics of the supply chain, management of the supply chain and testing and auditing activities.

GENERAL SUSCEPTIBILITY

To investigate the general susceptibility of a food or ingredient to food fraud, use publicly available information about incidences of fraud that have occurred in the past and that might occur in the future.

There are a few different ways to access information about previous incidences and emerging issues with a raw material type, as shown below.

how to investigate info graphic

1. Online databases – access to historical data:

  • Decernis has an extremely comprehensive database of food fraud incidents which can be searched by food type and by adulterant type.  This database was developed and formerly operated by the US Pharmacopeial Convention (UPS). It also contains information about analytical methods.   www.foodfraud.org.
  • Food Fraud Advisors’ Food Fraud Risk Information Database is a free and open-access online database of food fraud incidences and emerging threats threats, organised by food type.  No log-in required.
  • HorizonScan contains historical data about both commodities and suppliers.  Users can set up email alerts for issues relevant to them.
  • FoodSHIELD was created by The Food Protection and Defense Institute, which is part of the University of Minnesota and partially funded by the USA Department of Homeland Security.  FoodSHIELD resources, including a database of economically motivated adulteration incidences are available to members.  Unfortunately membership is limited to representatives from local, state, and federal governments, the military and laboratories that perform analyses.  Members must first pass a membership checking process to ensure they are eligible to access the information. https://www.foodshield.org and https://www.foodshield.org/index.cfm/discover-tools-links/what-is-foodshield/foodshield-brochure/
  • The Food Protection and Defense Institute also operates a Food Adulteration Incidents Registry.
  • EMAlert is software that helps USA businesses with commodity scanning and assessing vulnerabilities for USA regulatory compliance.  Subscriptions start at US$2,500 per year.
  • The Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.
  • The US FDA has a searchable list of food recalls and food safety alerts, including those related to food fraud.  http://www.fda.gov/Safety/Recalls/

2. Email alerts via subscription service:

  • Food Forensics, a laboratory located in United Kingdom, offer a monthly horizon scanning risk newsletter to members.
  • FoodChainID Horizon Scan is a paid subscription service that provides alerts on adulteration and fraud, as well as food safety contamination events.
  • Some trade associations provide email services to members.
  • Government-run food safety and food regulatory bodies in some jurisdictions send emails to interested parties.  Contact your local authority for more information.

3.  Direct intelligence:

  • Information can be obtained by asking law enforcement officials and government departments.
  • Suppliers can provide information about their material types.
  • Trade associations can be approached for information on food fraud and emerging issues.
  • Conferences and webinars about food fraud and food defence are held regularly and these can be a good source of information.

SPECIFIC SUSCEPTIBILITY

Specific susceptibility is investigated by considering all the characteristics of a specific material as it is purchased by an individual food business.  Characteristics that should be considered include those associated with the supply chain, purchasing policies and the format of the material.   Each characteristic should be considered with regards to how it could affect the degree to which a person may be motivated to fraudulently adulterate the material and how it could allow a person to:

a) gain access to the material,

b) commit fraud by adulterating, substituting or diluting the material or

c) avoid detection.

To ensure that all relevant characteristics are considered it is best to use a checklist and record observations against each item in the checklist.  Create your own checklist or use a checklist prepared by experts such as those found in a proprietary Vulnerability Assessment Tool.  There are a number of fraud assessment tools available on-line, with differing degrees of usefulness to anyone conducting a food fraud assessment.  The most comprehensive checklist for food fraud vulnerability assessments can be found in Food Fraud Advisors’ Vulnerability Assessment Tools which are available here.

Need more help?  Get easy-to-use, comprehensive downloadable templates in our online training course.

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Announcing our new online training course

Food fraud requirements of BRC, SQF, FSSC and other food safety standards

How to meet the food fraud prevention requirements of major food safety standards

This course will make audit preparation a breeze.  It contains step-by-step instructions, worked examples and downloadable templates to help you meet the food fraud requirements of all major food safety standards.

sqf edition 8 food fraud

 

  • Learn why food fraud prevention has been included food safety standards
  • Hear food fraud stories that will surprise you and learn ways to protect your business
  • Get step-by-step instructions for food fraud vulnerability assessments and food fraud mitigation plans, using real life examples
  • Download templates for vulnerability assessments, mitigation plans and food fraud prevention procedures
  • Proceed at your own pace; skip forward and back through the lessons, start and stop at your convenience*

The content is a mix of written words and short video clips, plus downloadable worked examples.

Ask the trainer a question at any time.

What’s included?

  • Food Fraud Commonly Affected Foods Ebook
  • Food Fraud Vulnerability Assessment template
  • Food Fraud Prevention Procedure template
  • Food Fraud Mitigation Plan template
  • Vulnerability assessment document – worked example
  • Raw Material Specification template
  • Food Fraud Team Job Descriptions
  • Top tips for audit preparation
  • Special 40% discount code for use on www.foodfraudadvisors.com
  • Optional exam and Certificate of Competency

Duration: 3.5 hours

Visit our training academy today

* course is available for 6 months after commencement

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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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HACCP, VACCP and TACCP

HACCP (Hazard Analysis Critical Control Point)  Pronounced ‘hassup’.  HACCP = food safety.

VACCP (Vulnerability Assessment Critical Control Point) Pronounced ‘vassup’.  VACCP = prevention of economically motivated food fraud.

TACCP (Threat Assessment Critical Control Point) Pronounced ‘tassup’.  TACCP = prevention of malicious threats to food, such as sabotage, extortion or terrorism.

HACCP is a set of principles designed to control and prevent food safety risks during food production.  The ideas of HACCP form the basis of every food safety standard that is in use today.  HACCP is not owned or regulated by any organisation.  The principles of HACCP are codified (written down) by the World Health Organisation (WHO), which is part of the United Nations (UN), in a set of documents called the Codex Alimentarius , a latin phrase which translates to “Book of Food”.   The principles of HACCP are described in the Annex of the Codex document GENERAL PRINCIPLES OF FOOD HYGIENE CAC/RCP 1-1969.  You can download a copy of the code of practice here and you can view the Annex containing the principles of HACCP here.

VACCP and TACCP are relatively new terms that have emerged in the last ten years as standards agencies, government regulators and industry groups have been talking more about how to prevent food fraud and malicious tampering.  The general idea is to create new preventive systems similar to the ideas behind HACCP.  We know that HACCP is effective at preventing inadvertent contamination, and more importantly it is well understood by food businesses, auditors, standards writers and regulators.  So take the ideas of HACCP, replace the ‘Hazard’ with ‘Vulnerability’ or ‘Threat’ and go for it, right?

The idea sounds good in theory, but what about in practice?  The critical control ‘points’ in a VACCP and TACCP plan do not look much like the ‘control points’ in a HACCP plan at all. The control points in a HACCP plan are operational steps in a manufacturing process; the process is generally linear and the ‘control points’ are operational processes over which the food manufacturer can exercise direct control.

In contrast, the actions that are required to prevent deliberate tampering within a food supply chain do not sit comfortably on a linear set of operations.  The terms VACCP and TACCP are falling out of favour within the food fraud and food defense communities.  They are not referenced specifically within any of the GFSI food safety standards, nor within the USA’s FSMA.  It is much better practice to say “Vulnerabilities to food fraud” or “threats of malicious tampering”.

More acronyms demystified here.

Learn more about food fraud here.

Or start one of our online, on-demand training courses today.

food safety food fraud