Food Fraud

Food fraud, like food defence, is a part of the food protection ‘umbrella’.  Both can be economically driven, however, the motivation behind food fraud is monetary gain, whereas the intent behind food defence is to cause harm through any form of intentional, malicious adulteration or economic disruption, and is typically ideologically motivated.  Areas impacted by food defence programs include cyberattacks and sabotage.

Food fraud has the potential to become a food safety issue if there is the potential for harm to consumers through:

• direct risk from exposure to toxic or lethal substances
• indirect risk from low-dosage exposure to a contaminant over a long period of time, or from using a product where the nutritional value has been reduced due to substitution or dilution⁵.  

In 2008 milk was intentionally diluted and adulterated with melamine to increase the apparent protein content, due to the increased nitrogen content from melamine. In powdered infant formula made from the adulterated milk, melamine levels as high as 4,400 mg/kg were recorded⁶.  

What started as a food fraud incident became a food safety issue when the infant milk formula was linked to urinary tract ailments (crystals and stones in the urine leading to kidney stones)⁷ resulting in the hospitalisation of nearly 52 thousand infants and 6 deaths⁸.

Numerous factors contribute to food fraud, which can vary from country to country, the level of development and regulatory structure:

1. Opportunity:
   
   1. inherent technical aspects of the products, such as the physical state of an ingredient or product (e.g. liquid versus powder); degree of processing (e.g. a herb as a whole plant is less vulnerable than dried leaves); whether there is an analytical testing method and the availability of the detection method; knowledge (e.g. diluting milk with water and replacing with melamine to increase the apparent protein content); complexity of composition (e.g. vanilla); non-food grade equivalent available; availability of technology
   2. technical measures such as product testing upon receipt, supplier approval programmes and functional performance of ingredients
   3. access by authorised employees, visitors, contractors or unauthorised people to products during the supply chain, for example during manufacture or storage
   4. number of times the product changes hand / or use of agents and brokers
   5. transparency of the supply chain
   6. differences in availability and demand¹⁷. ­
2. Economic factors: including customer pressure to reduce prices, availability versus demand, supply shortage due to political unrest, increase in prices, austerity measures impacting regulatory agencies and trade barriers etc.
3. Lack of control measures including:
   
   1. technical - food safety legislation, historical lack of testing for the adulterant (e.g. starch in food), inability to test (e.g. no analytical test) etc.
   2. managerial - lack of regulatory enforcement, food security, stable government, social/business acceptance (‘fraud doesn’t harm anyone’ attitude or ‘it won’t happen to us’), specifications/contracts etc.
4. Complexity of supply chain: length, transparency, vertical integration, single ingredient source from approved supplier as opposed to open market etc.
5. Insufficient supplier approval and performance programs: including on-site audits which includes a food fraud component, analytical testing and tracking of analytical results and complaints¹⁸
6. History of food fraud: recurring fraud in the same product over a period of time, a pattern of food fraud in growing/manufacturing country and number of legitimate reported incidents can point to increased food fraud vulnerabilities.

Mitigation strategies should be implemented effectively to prevent or minimise vulnerabilities to food fraud. They must be specific to each company, manufacturing site and product.

To ensure the correct implementation of each mitigation strategy, companies should:

1. monitor procedures and methods
2. document the corrective actions to be taken if mitigation strategies are ineffective or not implemented correctly
3. verify that monitoring is being conducted and corrective actions are being followed when appropriate.

Prevention of food fraud must be cross-functional (not just a food safety function issue) and implemented across businesses and supply chains^22,24. Food fraud training of all departments, including Procurement and Operations is important to ensure:

• procuring supplies of products and ingredients from reputable, approved suppliers
• approval of source suppliers (site where the products are actually made), not just brokers and agents
• raw ingredient/finished product specifications are understood and include a full description of the product (e.g. botanical species, variety (such as Cinnamomum verum vs. Cinnammum cassia) and all ingredients including key attributes
• procedures in place for products that do not meet the approved specification or are not legally compliant
• use of a recognised statistical sampling programme for sampling and inspection on receipt, which is appropriate for the raw ingredient and consistently applied
• the testing laboratory is appropriately accredited for the analysis required
• request Certificates of Analysis for relevant criteria, such as active ingredient content and method used e.g. piperine for pepper
• known harvest cycle as this can influence availability of products and quality
• verification of authenticity of ingredients used in food manufacturing
• development, implementation and effective testing programmes for materials identified as being highly vulnerable to food fraud
• maintenance of equipment, such as weighing scales and ensure an effective calibration programme is in place
• reviews of costs and benefits of conducting on-site audits, especially for high-risk suppliers
• request suppliers of vulnerable products to conduct a mass balance exercise (typically as part of the traceability programme) to prove ability to account for all quantities of raw ingredients, products and packaging
• review and implementation of anti-counterfeit technologies where appropriate²³
• follow correct importation rules; good manufacturing practice (GMP) and industry standards are applied
• knowledge of food laws where the products and ingredients are manufactured and sold, to avoid unintended non-compliance to legal requirements
• alerting authorities to cases of suspected food crime, e.g. Food Standards Agency (FSA) and Food Standards Scotland (FSS): FSA's National Food Crime Unit, Scottish Food Crime Hotline

Examples:

• on receipt, a raw ingredient does not look typical or has an odd smell/texture
• there is a shortage of raw ingredients (due to natural disasters, political unrest, crop failures etc.) and there has not been an anticipated price change (e.g. cumin in India contaminated with peanut shells)
• excess raw ingredient availability, without an increase in the number of growing locations
• a supplier is selling materials below market price
• demands are made of the supplier to significantly reduce costs
• a raw material is sourced from an atypical growing climate or country
• allergens or bacteria are detected that are not typical of the product