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Oregano Fraud; six things every food professional needs to know

1. What happened?

Testing was conducted by the Australian consumer group Choice, mirroring tests conducted in the UK and published by the UK Consumer Group Which? in 2015.  A selection of packs of dried oregano were purchased from supermarkets (grocery stores), delis (specialty food stores) and grocers (produce stores) in three cities in Australia and a single sample of each was tested.  Seven of the twelve samples, over fifty percent, were found to be inauthentic, with the inauthentic samples containing between 10% and 90% of ingredients other than oregano, including olive leaves and sumac leaves.

2. Why test oregano?  

Herbs and spices are one of the rock-stars of food fraud; their complex cross-border supply chains, high price per kilogram and the fact that they are often sold in powder or particulate forms make them prime targets for adulteration, dilution and substitution with cheaper materials.  

oregano adulteration
Source: Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies

 

Why oregano in particular?  Professor Elliott, Director of the Institute for Global Food Security, and an international authority on food fraud conducted testing on oregano in the UK in 2015, the results of which were published by the UK Consumer group Which?.  It is possible that Prof Elliott used rapid evaporative ionization mass spectrometry (REIMS), a test method recently made available by Waters Corporation, although Which did not disclose the test method. REIMS makes use of a rapid sampling method that produces vapour which is analysed using time of flight mass spectrometry.  Sophisticated software compares molecular markers in the resulting spectrum with those in known materials in a database, allowing a sample to be quickly identified as belonging to a particular product type or not.  The method has huge potential for testing food authenticity, with one of the advantages being that unlike other tests for adulteration there is no need to specify which adulterants to seek.  A downside is that many hundreds or thousands of tests must be performed and compared to traditional analytical methods to create a database before the method can be used with confidence to determine the authenticity of any given material.

Professor Elliott recently revealed that Waters Corporation and Queens University, Belfast worked together to build a database of oregano samples (Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies).  This means that oregano is one of the few materials that can currently benefit from accurate authenticity testing using the REIMS method. 

3.  Are the results unexpected?

Global food fraud commentators attribute the presence of significant concentrations of adulterants or diluents in dried herbs to economically motivated food fraud in most cases, as opposed to seafood mislabelling which sometimes occurs due to unintentional errors in species identification.  Food fraud is estimated to cost the United Kingdom one billion pounds each year.  It is thought to be very common among some food types, including herbs and spices.

4. Who is responsible?

It is highly unlikely that any of the brand owners named in the Choice report were aware that they were selling adulterated herbs.  Most if not all of the brands included the Australian testing would have been sourced and packed under well-controlled systems that include vendor approval processes, formal specifications for incoming materials (such as bulk herbs) as well as certificates of analysis and declarations of conformity to specification.   The fraudulent tampering probably occurred further up the supply chain during drying, bulk packing, shipping or storage.  Interestingly, all seven adulterated samples contained olive leaves and two contained sumac leaves.  It is possible that tampering occurred in two different points within the supply chain for some products; perhaps one fraudster added olive leaves to bulk lots of the herb at a location close to the oregano growing area and sumac leaves were added by someone else at a later date.

5. What are the legal and financial ramifications?

The sale of misrepresented products is a breach of Australian consumer law and ignorance cannot be used as a defense.  The incidences were investigated by the Australian Competition and Consumer Commission (ACCC), an independent authority of the Australian government.  One company was fined a substantial sum for selling product that contained only 50% oregano leaves.  It is likely that other businesses that had been supplied with inauthentic herbs sought financial redress from their suppliers, either through purchasing contract penalties or through private legal action.

When a food business chooses to voluntarily recall or withdraw their products from the marketplace they may try to claim the costs against their business insurance. Insurance companies will seek to recover their costs from further up the food supply chain and this may have an impact on premiums in coming years.

6. What should food businesses do?

No food business is immune from economically motivated food fraud and preventing food fraud from affecting a business is a multi-functional task that should involve personnel from purchasing, finance and legal departments as well as food safety and quality personnel.  In the short term however, there are some things that can be done by food safety and quality personnel to help prevent, deter and detect food fraud without a lot of investment from other parts of a food business: 

  1. Update your purchasing specifications to include authenticity requirements.
  2. Review your vendor approvals systems and revise questionnaires and requirements if required.  Consider implementing more stringent requirements for those suppliers that provide vulnerable materials.
  3. Request certificates of analysis (CofA) from suppliers of vulnerable materials
  4. Begin a testing regime for vulnerable materials
  5. Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile
  6. Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials
  7. Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
  8. Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.

Want to learn more about food fraud mitigation in the spice industry?  This article in Food Safety Magazine provides an excellent insight. 

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What is the difference between food fraud and food defense?

What is the difference between food fraud and food defense?

The difference between food fraud and food defense is that food fraud is done to make money, while food defense relates to acts that are done to create harm.  Food fraud perpetrators do not seek to cause harm, they seek to increase profits or otherwise benefit financially, so we say food fraud is economically motivated.  Food defense attacks are done to cause harm to consumers and companies.

What is the difference between intentional adulteration and food defense?

Intentional adulteration is the act of contaminating a food product with the intention of causing harm to the people who eat the food.  Food defense is a broader term that includes protection against adulteration of food, but can also extend to protection of equipment, assets and workers in food businesses.

 

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2019; the year in review

Happy New Year and welcome to 2020.  Last year included many pleasing, positive developments in food fraud prevention.  More and more people from within the international food industry are becoming aware of the prevalence of food fraud and becoming better educated about the risks it poses to consumers and businesses.  There were new developments in technology and more enforcement activities, plus awareness has continued to spread to peripheral industries and unconventional marketplaces.   Food Fraud Advisors and our sister company Authentic Food launched new products and continued to serve our growing customer community across the globe.  Thank you for your support in 2019.  I look forward to serving you in 2020.

Karen Constable, Principal Consultant, Food Fraud Advisors

Better assessments and tests

Food safety professionals are becoming more comfortable with performing food fraud vulnerability assessments and I have seen the quality of assessments improve markedly in the past year.  Food laboratories are also gaining more expertise in food authenticity testing.  Better test methods have been developed, and this is helping the labs to do their jobs more easily,  but for me I think the most important thing is that laboratory sales personnel are becoming better at understanding the needs of their food business customers when it comes to food fraud detection.

Food testing labs have better tools to meet the needs of their food industry customers

 

New food fraud prevention strategies

The past year saw significant increases in proactive prevention initiatives that extend beyond typical anti-counterfeit tools.  As an example, a famous Scottish salmon brand has recently implemented a chemical ‘fingerprint’ system to allow them to pursue suppliers of inauthentic product across their growing global supply chain.  BeefLedger is a new provenance verification product, which supports Australian beef exporters through the use of blockchain technology.

International enforcement

In India, there has been an ongoing effort by the media to publicise food adulteration problems in that country.  In response, government authorities are tackling the problem head on, with the aim of increasing trust in the food supply.  Indian news outlets feature stories of seizures and shutdowns of illegal food outlets on an almost daily basis.  Tea, spices, ghee, jaggery, cooking oil and milk are often affected.  The Food Safety and Standards Authority of India has promised to reimburse the cost of food fraud testing for consumer samples tested by credible consumer organisations.

The food crime unit in the UK benefitted from more funding last year, which increased its investigative capacity and its ability to train people in other agencies on food fraud awareness and intelligence handling.

In Europe there appears to be a growing acceptance that some organised crime groups are actively choosing to include food fraud operations within their money-making portfolios.  Although this type of operation may not be the norm, it does occur and acknowledgement of the problem is an important step in the fight to intercept and control such crimes.

Operation Opson, a joint operation between Interpol, Europol and national law enforcement agencies was run again in 2019, for the eighth year.  Operation Opson sees fraudulent food, drink and supplements investigated, located and seized by authorities across the globe, from sub-Saharan Africa to South America.  The categories of items seized most often in 2019 were illicit alcohol, cereals (grains) and condiments.  This year also included targeted actions that focussed on organic foods, coffee and 2,4-Dinitrophenol (DNP), an illegal fat-burning supplement that has caused multiple fatalities in recently years.

Grain was the second most-seized food type in Operation Opson VIII

 

In the USA, enforcement activities are also on the rise.  In 2019 there were a number of high profile prosecutions of business owners in the seafood, beef and pet-food industries.  The implementation of the Food Safety Modernisation Act (FSMA) has improved the standard of knowledge about food safety hazards and controls across the food industry in that country.  Also in 2019, many USA food companies were required to meet the International Adulteration (IA) rule of FSMA for the first time.  The rule is designed to prevent malicious threats to public health from food adulteration.  While the IA rule is not technically related to food fraud, it has made an important contribution to the concept of food safety.  As the new decade unfolds, I predict we will continue to expand our understanding of food safety; from our historical focus on natural and accidental contaminants to wider awareness of the risks posed by deliberate, human-mediated hazards.

Marketplace improvements

The good news continues, with 2019 witnessing a small but subtle shift in the willingness of online marketplace owners to talk about the problem of counterfeit goods in general, and counterfeit foods, drinks and supplements in particular.  There has been a change in the discourse around counterfeit products which increasingly addresses safety issues in addition to financial costs.  While many consumers and retailers continue to tolerate, or even seek out, counterfeit fashion items, more businesses are becoming aware of the prevalence of unsafe counterfeit supplements, foods and electronic components in online marketplaces.  And as awareness grows, I expect enforcement and preventive activities to follow; resulting in gradual improvements to the way we source and supply goods online.

Beyond food and drink

The food industry’s anti-fraud crusade has spilled over into related industries, including agricultural chemicals and packaging materials.  These two global heavy-weights are benefitting from the food industry’s food fraud awareness and prevention strategies of recent years.  As an example, the British Retail Consortium (BRC) included raw material fraud prevention activities in its most recent Packaging Materials Standard.   In pesticides, Operation Silver Axe resulted in the seizure of 550 tonnes of illegal or counterfeit pesticides across Europe.

The packaging materials industry has benefitted from lessons learned in food fraud prevention

Our year in review

Last year Food Fraud Advisors passed the 2000 downloads milestone for our tools and templates.  We continue to receive wonderful feedback and rave reviews for  our tools, templates and downloads.

We have customers in 48 countries, from large multinational food conglomerates to small start-ups, and everything in between.  While most are food manufacturers, this year we have had more customers from businesses peripheral to food production, such as brokers, logistics businesses and packaging manufacturers.  Students and consultants continue to make up a small but significant proportion of our online learning community.

 

New products

With our sister company, Authentic Food, we developed and launched the Intentional Adulteration Vulnerability Assessment Tool in June.  It filled an important gap for businesses in the USA, as there are few resources to help meet the requirements of the new FSMA IA rules and regulations.

Our vulnerability assessment tool for packaging materials was launched in November.  This tool is designed specifically to meet the requirements of BRC Packaging Materials Issue 6 which, for the first time, includes requirements to address food-fraud-like issues within the supply chain of packaging materials.  Purchasers of the packaging vulnerability assessment tool also receive a free threat assessment tool that generates a product defense plan for site security and product safety.

Our free Food Fraud Risk Information Database continues to grow.  It currently contains more than sixty five thousand words.

My favourite thing about 2019 was having the opportunity to interact with so many intelligent and resourceful food safety professionals from all over the world, as we work together to make our food supply safer for everyone.   I look forward to more of the same this year.

 

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Vulnerability Assessments

What is a vulnerability assessment?

In the food industry, the term vulnerability assessment refers to a risk-assessment-style evaluation of a food’s vulnerability to food fraud.  Food fraud is deception, using food, for economic gain (Food Fraud Initiative, Michigan State University 2016).  Some organisations, particularly in the United States of America, use the phrase vulnerability assessment when referring to malicious attacks on food, such as those conducted for extortion, ideological reasons or terrorism. However those types of risks are issues of food defense rather than food fraud and those risks are not considered here.  To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

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

 

Why ‘vulnerability’ and not ‘risk’? 

A vulnerability assessment is slightly different to a risk assessment; risk is something that has occurred before and will occur again, it can be quantified using existing data.  A vulnerability is a weakness that can be exploited by someone or something who wishes to profit or intends harm.  A vulnerability can lead to a risk.  Because food fraud is difficult to estimate and quantify, we use the word vulnerability rather than risk.  In addition, using the word ‘vulnerability’ helps to minimise confusion in the food industry where risk assessments for food safety are commonly performed and well understood.

Why do a vulnerability assessment?

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

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Frequently Asked Questions

Vulnerability Assessment Tool (BRC Packaging Materials) – Frequently asked questions (FAQ)

Is this assessment tool suitable for businesses operating to management system standards other than BRC Packaging Materials?

This spreadsheet is especially designed to meet the requirements of BRC’s (British Retail Consortium) PACKAGING MATERIALS Issue 6, which requires that businesses assess their raw materials for vulnerability to economically motivated (fraudulent) substitution.

It is not recommended for businesses that need to meet the requirements of other management system standards.  It is not suitable for food defense or TACCP vulnerability assessments.  We recommend you purchase one of our other tools instead.

Is this assessment tool suitable for businesses that do not operate a food safety or quality management system?

If your business is not operating to a food safety or quality management standard and does not have supplier approval processes, purchasing specifications and robust systems for receiving materials then it is more vulnerable to accepting fraudulent material and this tool will underestimate the risk.

What about the Threat Assessment Tool?

The threat assessment tool is a bonus add-on for purchasers of the packaging vulnerability assessment tool, it is not sold separately.  Is is also designed to meet the requirements of BRC Packaging Issue 6.

What happens if I can’t complete all the questions?

If you have not answered all the questions the tool will estimate your material as being vulnerable (very likely to be affected by fraudulent substitution). However it is possible to supplement the calculated rating with your own estimate if desired. This means that if you already think that a particular raw material has a very low risk you may choose to simply enter your best estimates of likelihood instead of completing all the data fields. This will allow you to prioritise your time and focus on the most important raw materials first.  Note that if you do this the resulting assessment documents are unlikely to be acceptable to an auditor because they will not contain a complete explanation of how the risk assessment was performed.  To obtain a complete explanation, every question should be answered.

What if I disagree with the results?

The Vulnerability Assessment Tool calculates the vulnerability using information entered by the user.  Users are encouraged to also enter their own estimates.  The reported results are based on the user’s estimates if they have been entered; if not, calculated results are used.

Why is the Vulnerability Assessment Tool an Excel spreadsheet instead of specialised software?

The tool was created with Microsoft Excel because most of its intended users are familiar with excel and so can begin entering data as soon as they open the spreadsheet, with no special training.   Data can be copied, pasted and searched just as you would in any spreadsheet and results can be easily extracted for use in other documents. Blank and completed spreadsheets can and should be incorporated into a company’s controlled documents and record-keeping system and Microsoft Excel files are usually suitable for this purpose.

The tabular format of the data entry pages allows users to have a ‘whole picture’ visual understanding of the data that has been entered and the gaps that need to be filled.  Other types of software such as questionnaire-style assessments do not provide a visual overview and require information to be entered in a defined series of steps which can be frustrating. Within the tables of the Vulnerability Assessment Tool, colour-coding functions provide instant feedback about whether an answer affects vulnerability in a positive or negative way, which can be a valuable learning tool.

Why are some of the cells password protected?

Password protection has been applied to many of the cells in the spreadsheet.  There are a number of reasons for this, the most important of which is so that users do not accidentally ‘break’ the formulas which would be very easy to do if it was unlocked.

This means that users are not able to make changes to the wording of the questions or the automatically generated answers.

Can I copy the results into my own spreadsheet or other document?

Yes. The data can be copied, pasted, sorted and manipulated as in any spreadsheet. When copying from the tool use the excel function ‘paste special – values’, which will prevent pasting formulas that might return error values in a different document.

Do I have to purchase a new spreadsheet for each material group?

No, you may make as many copies of this spreadsheet as you need for ONE business in one manufacturing location.  You may not share it with other businesses or take it when you change jobs.  For complete terms and conditions click here.

Is there a telephone number I can call for help and support with the tool?

For support, please email support@foodfraudadvisors.com with your query, including your preferred contact details and geographical location (for time zone purposes). We will contact you by telephone or Skype or email an answer to you.

Can I have access to the formulas that generate the results?

If you disagree with the results the tool allows you to override them; the reported results are based on the user’s estimates if they have been entered; if not, calculated results are used.

If you think the methodology, including the risk calculations should be amended or you think there is an error in any formula please contact us. We want the Vulnerability Assessment Tool to be the best that it can and value your feedback.

Want to buy an unlocked version that is fully customisable?  Request a quote here.

My security settings will not allow me to run macros, is this a problem?

No problem; the Vulnerability Assessment Tool has been created without macros to keep things safe and secure and to prevent headaches with your internal IT systems.

Which version of Excel do I need to use the tool?

The Vulnerability Assessment Tool is compatible with Microsoft Excel 2004 onwards (file extensions .xlsx) and Microsoft Excel for Mac 2011 onwards.

Can I get a tax receipt?

Australian purchasers receive a tax invoice for GST purposes in their confirmation email.  Purchasers in other countries are not charged any tax but receive an itemised purchase receipt in their confirmation email.

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Latest news in food fraud

US beef sellers behaving badly and new information about lead in turmeric

In September 2019, four men from the United States beef industry were accused of food fraud by authorities. The men were owners and executives at two unrelated companies; one a beef wholesale company in New York, the other a Texan supplier to the US government.

Why would any person perpetrate food fraud? It is alleged that the New York men were struggling to make a profit in their business, even going so far as to successfully audition for a business makeoever reality TV show. They are alleged to have systematically removed United States Department of Agriculture-approved meat quality labels from cuts of beef and replaced them with counterfeit labels of a higher grade, enabling them to sell the beef at a higher price.

The men in Texas, who plead guilty for their role in a scheme to illegally add cow hearts to ground beef and who admitted to hiding the cow hearts from government inspectors, were almost certainly doing it for the money. The courts have heard that they sold the more than $1m worth of the adulterated meat to the Federal Bureau of Prisons.

In both of these cases, the frauds resulted in customers receiving food that was not true to label, and those customers proceeded to unknowingly sell and serve it to un-suspecting consumers. In one case, the meat was mislabelled but not physically modified, in the other case, the meat itself was adulterated with unauthorised material. When food is adulterated or otherwise modified, processed or (re-)packed in a fraudulent manner, the result is a product that can present significant food safety risks to consumers.

Texan meat processors have pleaded guilty to adding beef heart to $1m of ground beef.

 

Food fraud perpetrators generally wish to avoid causing serious or obvious food safety issues; after all, they do not want to be caught.  As a result, not all food frauds result in food safety incidents.  In a terrifying exception to this rule, however, it was alleged that a group of at least five people who adulterated black pepper in Vietnam in 2018 were aware that the adulterants were toxic.  The weight of the pepper was fraudulently increased by the addition of home-dyed gravel and coffee bean skins.  The dye was made by breaking open batteries to extract black-coloured manganese dioxide powder.

Another example of a toxic adulterant and one that has caused widespread illness and suffering is the industrial chemical melamine.  Melamine, which contains nitrogen atoms, can be used to trick some protein test methods which calculate protein content of food based on nitrogen within the food.   Melamine adulteration can therefore be used to boost the apparent protein content of foods such as milk powder, that are priced according to their protein content. Three hundred thousand babies became ill after drinking milk adulterated with melamine in China in 2008.  Six babies died and tens of thousands of other infants, who are now teenagers, received irreversible kidney damage, condemning them to a life of renal dialysis and ongoing surgeries.

Melamine has also been used to fraudulently adulterate wheat products, meat products and animal feed.  In the United States, melamine adulteration of dog and cat food caused the deaths of up to 3600 pets in 2007.

One of the scariest food safety issues to arise in connection with food fraud in recent years affects a food product favoured by some wealthy western consumers for its health-giving properties.  Turmeric has been lauded as a wonder-food; with properties that are said to cure joint pain, reduce inflammation, improve mood, brain function and protect against heart disease.  But powdered turmeric also presents real food safety risks to consumers because a significant proportion of powdered turmeric traded worldwide contains unsafe levels of lead.  Lead is a potent neurotoxin that damages organs including the brain.  Research released in September 2019 confirmed that the lead in turmeric is added to the spice in the form of toxic lead chromate which has a beautiful, intense yellow colour, the exact colour favoured by turmeric traders and buyers as an indicator of freshness and quality.  Curry powder, cumin and cinnamon have also been affected.  Another 2019 study, which surveyed more than 1496 samples of 50 spices from 41 countries found that 50% of the spice samples had detectable lead, and more than 30% had lead concentrations greater than 2 ppm, a level 200 times higher than the recommended maximum lead content of candy in the USA.

While not all food fraud represents a risk to food safety, fraudsters who adulterate food to make extra money for themselves put consumers lives at risk.  Stay up to date with new food fraud incidents on our free, open-access food fraud database.

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Authenticity testing – recommended frequency

Part 3 in our series about food fraud testing

Part 1: Food testing checklist

Part 2: How to design a food testing plan

Guidance on test frequencies:

When developing a food fraud testing plan, one of the biggest challenges is choosing the frequency of testing.  Food Fraud Advisors has developed these guidelines to use as a starting point.   They are not a definitive guide, always follow the advice of your analytical laboratory and specialists.

For any given material, the frequency of testing should be based on its susceptibility to food fraud.  Suggestions for five different types of materials (A, B, C, D) are described below. Test frequencies should be reviewed and adjusted on a regular basis. Frequencies can be decreased if results are consistently acceptable and increased if problems have occurred or if there are changes to the product or the supply chain.

Type A: a material known to be very susceptible to food fraud (eg. honey, white fish fillets) but for which no specific incidences have occurred within your supply chain and for which no intelligence related to your supply chain has been received.

Phase 1: test a sample from 5 out of 5 incoming batches from every supplier and/or geographical source. For agricultural materials, this sampling protocol should be repeated on a seasonal basis across the year. The aim is to build a picture of authenticity across the year for your suppliers. Progress to phase 2 if all the results from phase 1 have been satisfactory. If test results have revealed problems with authenticity, phase 1 should continue for the affected suppliers or places of origin. Suppliers with satisfactory results can progress to phase 2.

Phase 2: reduce the frequency of testing to one sample per 5 to 10 incoming batches, with the frequency based on your estimate of the ongoing risk. As in phase 1, materials with seasonal supply fluctuations should be tested over various seasons. Use the results from phase 2 to continue to add to the overall picture of authenticity for this material type within your supply chain. Continue until you have at least 10 results. Progress to phase 3 if all results are satisfactory.

Phase 3: is an ongoing maintenance phase. Aim to test one sample per 10 to 20 incoming batches as an ongoing protocol.

Type B: Material for which you have received specific intelligence related to authenticity that pertains to your supply chain.

Phase 1: focussing on the implicated products or ingredients, take samples from at least 5 incoming batches. If the material is non-homogenous – for example if it is in individual packages, or individual pieces rather than being a bulk liquid or powder – consider taking duplicate or triplicate samples from each incoming batch, if budget allows. If all of these samples ‘pass’ the tests, consider trying alternative test methods or test types. Move to phase 2 if all test results are satisfactory.

Phase 2: reduce the frequency of testing to one sample per 5 incoming batches. Continue this frequency of testing until your intelligence information and your test results are sufficient to suggest that the risks within your supply chain have passed. If the risk has abated, reduce the frequency to that of phase 3 for type A.

Type C: Moderately susceptible materials

Phase 1: test a sample from 1 of 5 to 10 incoming batches from every supplier and/or geographical source. For agricultural materials, this sampling protocol should be repeated on a seasonal basis across the year. The aim is to build a picture of authenticity across the year.  Continue until you have at least 5 results per supplier or geographical source. Progress to phase 2 if all the results from phase 1 have been satisfactory. If test results have revealed problems with authenticity, phase 1 should continue for the affected suppliers or places of origin. Suppliers with satisfactory results can progress to phase 2.

Phase 2: test one sample per 10 to 20 incoming batches with the frequency based on your estimate of risk. As in phase 1, materials with seasonal supply fluctuations should be tested over various seasons. Use the results from phase 2 to continue to add to the overall picture of authenticity for this material type. Continue until you have 5 results. Progress to phase 3 if all results are satisfactory.

Phase 3: If all results from phases 1 and 2 are satisfactory, the frequency of testing can be significantly reduced. One test per year per supplier should be adequate for most materials and suppliers.

Type D: Food products at risk of counterfeiting or suspected of being from illegitimate sources

A market surveillance sampling plan should be devised. Retail and/or wholesale sources in high risk markets should be targeted in addition to online marketplaces. Anonymous market ‘buyers’ could be engaged to obtain the samples. Buyers can be instructed to purchase a specific number of items per batch per outlet, or they can be instructed to inspect or photograph samples in situ. The amount of surveillance will depend on the brand owner’s tolerance of counterfeiting and the testing budget.  Products at high risk of counterfeiting are likely to need ongoing surveillance.  Food products that have been found to have entered marketplaces through theft, diversion or grey market channels can have their risk reduced by implementing controls within distribution chains.

Type E: low risk materials. If a food ingredient or product has been shown to be low risk in a food fraud vulnerability assessment then authenticity testing should not be required. If the material or supply chain has changed such that the material requires authenticity testing then its food fraud vulnerability should be re-classified to medium or high risk.