The food industry considers the safety of its products as its main concern. Over the years, industry and regulators have developed food safety management systems, making major outbreaks of food poisoning now quite unusual in many countries.

Hazard Analysis

These systems typically use Hazard Analysis Critical Control Point (HACCP) principles, which are accepted globally. HACCP has proven to be effective against accidental contamination.

However, HACCP principles have not been routinely used to detect or mitigate deliberate, fraudulent actions on a system or process. These actions include the deliberate contamination of food, or food fraud.

This document

• describes a process for food fraud prevention and the principles of the assessment
• outlines measures that can deter fraudsters or detect food fraud early, and
• provide sources of information and intelligence that may help to identify emerging threats.

Though food fraud commonly encompasses a wide range of deliberate fraudulent acts, this document focuses on one type of food fraud – the intentional and economically motivated adulteration of foods.

The Economically Motivated Adulteration (EMA) pertains to any or all of the following for the economic gain of the seller:

• fraudulent addition of non-authentic substances
• removal or replacement of authentic substances without the purchaser’s knowledge, for economic gain of the seller

The table below lists the contents of this document.

The table below lists the topics in this section.

The types of EMA include the following:

• sale of unfit and potentially harmful food, such as
  • recycling of animal by-products back into the food chain
  • packing and selling of meat with unknown origin, or
  • knowingly selling goods past their ‘use by’ date
• deliberate mislabeling of food, such as
  • products substituted with a cheaper alternative (Example: Farmed salmon sold as wild, or Basmati rice adulterated with cheaper varieties), or
  • false statements about the source of ingredients, i.e., their geographic, plant or animal origin

This document does not address the following types of food fraud:

• counterfeiting (fraudulently passing off inferior goods as established and reputable brands)
• product tampering
• theft
• smuggling
• document fraud
• product diversions
• food adulteration intended to cause

The image below is a pictorial representation of the food safety management system.

Food fraud deceives the consumers by providing them with lower quality foodstuff, against their knowledge and will.

While it is not the intention of food fraud to harm consumers, such acts can cause illness and even death.

This was the case in 2008 when melamine was used as a nitrogen source to fraudulently increase the measured protein content of milk, resulting in more than 50,000 babies being hospitalized and six deaths after having consumed contaminated infant formula.

The common factor in many cases of food fraud, is that the adulterant is neither a food safety hazard, nor readily identified (as this would defeat the aim of the fraudster).

• Common adulterants include
• water and sugar, or
• ingredients that may be legitimately used and declared, but whose improper use constitutes fraud.

The implications of EMA deprive the consumers of the following:

• food safety and health of consumers
• good quality products that the consumers intend to purchase

The prevention of food fraud is paramount to

• protect the trust of our consumers, and
• maintain fair and sustainable business practices.

A food fraud management system is a continuous process as depicted in the flowchart below (from U.S. Pharmacopeia Appendix XVII: Food Fraud Mitigation Guidance).

The table below depicts the stages of food fraud management.

Note: Periodically or when changes occur that may impact the previously identified vulnerabilities, carry out the entire process again to ensure its continued effectiveness.

Example: A newly identified adulterant for an ingredient that changes the supply chain for an ingredient.

The table below describes the steps in preventing food fraud.

The three aspects of vulnerability assessment are dependent on the following factors driving vulnerabilities:

• inherent to the ingredient
• impacting the business (business pressure)
• under the control of the buyer

The factors inherent to the ingredient that are entirely independent of the actions taken by the buyer to mitigate the risk of fraud are the following:

• ingredient market price
• fraud history
• composition
• physical state
• level of processing

Certain ingredients are by nature more vulnerable to adulteration.

Example: Apple juices or apple purees are more vulnerable than apple pieces.

Fraud history (past cases of adulteration of specific raw materials) is a good source of information which is an indicator of the following:

• raw material potential vulnerability
• important source of possible adulterants needing detection and deterrence

Factors that may contribute to an increased level of vulnerability to fraud are one or all of the following:

• demand for a specific ingredient (volume)
• extent of its use (ingredient used in several products and businesses)
• market price fluctuation
• economic anomalies of
  • particular raw material sources
  • drastic increases in market price of raw materials
  • scarce supplies of a raw material (Example: Poor harvest because of bad weather or a new parasite)
• geopolitical considerations indicating
  • a country-specific low price compared with the rest of the market
  • a lack of food control, and/or
  • regulatory/ enforcement framework in the country of origin, (or any other country through which the ingredient may transit)

This image depicts a situation of possible food fraud where the price of a valuable food is too good to be true.

If the price of a valuable food is too good to be true, it probably is!

This reflects the strength, or the weakness of a company’s mitigation strategy such as

• full traceability
• adequate purchasing specifications, and
• availability of analytical methods, and robustness of surveillance programs.

Assessing the risk of fraud for a food ingredient requires the understanding of the following:

• inherent raw material vulnerabilities
• business vulnerabilities
• existing controls

This understanding helps define what preventive actions are needed and where, to mitigate adulteration risks.

Note: Such vulnerability assessment is not a one-time activity but a dynamic process, which needs to be maintained with regards to new information and external pressures such as economic anomalies and bad harvest year.

The image below shows adequate vulnerability assessments help in mitigating food fraud.

Recent food fraud crises have highlighted the need to reinforce companies’ ability to combat fraud within their own organization, and across the entire food value chain. Companies are expected to work proactively towards mitigating the risk of food fraud.

Guidance and Self-assessment Tools

A number of organizations have developed guidance and self-assessment tools to help food companies undertake their own vulnerability assessments and implement appropriate control plans.

Examples: US Pharmacopeia, SSAFE, BRC

Reference: For more information about guidance and self-assessment tools, refer to Useful Resources and Tools .

The following are the measures in mitigating food fraud:

• raw material specifications
• analytical surveillance

To prevent food fraud, have adequate raw material specifications that include the following:

• Appropriate authenticity criteria to mitigate the inherent vulnerabilities (as much as possible) identified in the self-assessment. (Example: UV absorbance is specified to detect the potential adulteration of extra virgin olive oil with refined oils).
• Criteria linked to food fraud prevention thoroughly defined, in line with the level of complexity and variability of the ingredient’s composition.

Note: When you need to measure a specific parameter to control the raw material authenticity, focus on using analytical methods that fit the purpose (i.e., adapted for natural viability in the raw material).

Perform the following to be able to plan the analytical surveillance:

• Characterize the adulteration risks for a given raw material.
• Define a set of analytical control criteria.

Establish a surveillance plan that allows to

• build confidence in the company’s suppliers
• gain reassurance on the company’s raw material supply
• confirm that the prevention measures in place are adequate, and
• detect food fraud issues.

Monitor raw materials using appropriate analytical methods for the verification of authenticity. The methods must be selective, specific, and of appropriate sensitivity to verify that the food authenticity process is efficient.

There are two approaches:

• targeted analyses (linked to parameters specified in raw material specifications)
• untargeted techniques (fingerprinting) that assess the raw material integrity against adulteration

The table below lists the topics in this section.

To build a trusted supplier relationship, have processes to approve the suppliers’ production sites, with requirements for approval based on risk

Examples: Raw material risk, location of food safety control measures, and supplier performance.

Once suppliers are qualified according to a robust approval process, the relationship between buyer and supplier is critical to support any adulteration prevention effort.

The development of trusted suppliers (rather than continuous rotation) has the following benefits in mitigating the risk of food fraud.

• The closer the relationship,
  • lower the risk, and
  • more knowledge and confidence gets shared between each party.
• Confidence increases with a supplier’s readiness to share information on their supply chain and processes.

While building a trusted supplier relationship, ask yourself the following questions:

The various supplier types could be as follows based on the business relationship you one shares with them:

• long-standing partnership-type arrangement
• trusted supplier for a new ingredient
• some relationship with an established supplier
• no relationship with an established supplier
• no relationship with an unestablished supplier

The long-standing partnership type arrangement entails the following:

• high degree of
  • confidence established through long positive business relationship
  • transparency and/or testing programs
• sharing of key information and expectations
• understanding of key needs and controls in both the buyer and supplier processes

The trusted supplier arrangement is similar to the “long-standing partnership-type arrangement”, except the buyer only recently began purchasing a particular ingredient from the supplier.

A high degree of confidence gets established through the purchase of other ingredients.

The established supplier type of relationship with some relationship represents that of a short history of business with the supplier, who is well respected in their market with a solid reputation, and no significant issues reported.

The established supplier type of relationship with no relationship entails a supplier who is respected in their market with a solid reputation, but a business relationship and history have not yet been established.

The unestablished supplier may be new to a given industry. They are often people with whom the buyer has no history or any general industry knowledge of the supplier.

The image below is a representation of purchase records and traceability of raw material usage in a product.

In response to food fraud issues reported in the recent years, a number of requirements have been added to food safety schemes to minimize the risk of operating sites purchasing fraudulent or adulterated raw materials.

The guidelines of supplier audit conducted in 2015 are the following:

• processes to identify threats in the supply chain
• documented vulnerability assessment
• raw materials at risk of adulteration

Processes were established to access information about past and current threats to the supply chain. These threats were likely to present a risk of adulteration or substitution of raw materials. Such information was obtained from

• trade associations
• government sources, and
• private resource centers.

Documented vulnerability assessment was carried out on all food raw materials or groups of raw materials to assess the potential risk of adulteration or substitution. The following were considered during this assessment:

• historical evidence of substitution or adulteration
• economic factors that may make adulteration or substitution more attractive
• ease of access to raw materials through the supply chain
• sophistication of routine testing to identify adulterants
• nature of the raw material

The vulnerability assessment was reviewed annually to understand the following factors that could alter the potential risk:

• changing economic circumstances
• market intelligence

Where raw materials were identified as being at risk of adulteration or substitution, appropriate assurance and/ or testing processes were put in place to reduce the risk (e.g., auditor to review the historical test results of materials identified at risk of adulteration).

Absence of Scheme-specific Requirement

The site undertook documented mass balance tests (for example: every 6 months in the absence of a scheme-specific requirement).

The status of each batch of the raw material was verified when

• products were labelled, or
• claims were made on finished packs which were dependent on the status of a raw material including
  • specific origin
  • breed/ varietal claims
  • assured status (For example: GlobalGAP)
  • genetically modified organism (GMO) status
  • identity preserved, or
  • specific trademarked ingredients.

• The facility maintained the following to substantiate claims:
• purchasing records
• traceability of raw material usage
• final product packing records

Methods of Production

Where claims were made about the methods of production (for example: organic, Halal, Kosher), the site maintained the necessary certification status to make such a claim.

The auditors were able to do the following during their inspection:

• Carry out more targeted examination at a specific raw material production/ handling site. (Example: On a meat production site).
• Detect the presence of the following in the production and/or storage areas:
  • Unapproved flavors
  • Dyes
  • Preservatives
• Look for the presence of equipment used to inject brine on a poultry production site.

A streamlined upstream supply chain has the following benefits:

• Improves transparency, traceability, and the management of material safety and quality standards.
• Gives fewer opportunities for fraudsters to penetrate your supply chain.

The first step towards supply chain transparency is to ask yourself the following questions first:

• Do you have full visibility of your supply chain?
• Who are your immediate suppliers?
• Who supplies them?
• Are you changing a supplier or process?

The table below describes the steps in simplifying the supply chain.

The image below depicts transparency in the supply chain as a means to eliminate the sources of risk.

Maintaining a routine watch of official and industry publications does one or all of the following:

• Gives an early warning of changes that may trigger new threats.
• Changes the priority of existing threats, including more local issues as they develop (Example: Climate impact on certain crop yield and subsequent fraud).

The table below lists the topics in this section.

The table below provides the full forms of the abbreviated terms used within this document.

The table below provides the definitions of the terms used within this document.

The table below answers the frequently asked questions about adulteration.

The table below answers the questions about food fraud.

The list below provides hyperlinks to the following guidance documents:

• BRC Global Standard for Food Safety Issue 7: Understanding Vulnerability Assessment
• TA CCP (Threat Assessment and Critical Control Point): a practical guide 2014 (Campden BRI)
• UK Food and Drink Federation (FDF)
• US Pharmacopeia Appendix xvii: Food fraud mitigation guidance 

The list below provides hyperlinks to the following self-assessment tools:

• SSAFE Food Fraud Assessment Tool:
  • PWC
  • SSAFE
• US Food and Drug Administration (FDA) Vulnerability Assessment Software 

The list below provides hyperlinks to the following alerts and databases:

• Australia and New Zealand
• Canada Recalls and Alerts
• EMA Susceptibility Database (registration required)
• European Union Rapid Alert System
• Online tool compiling information on import refusals
• The Department of Food Safety, Govt of N.C.T of Delhi
• UK Food Standards Agency (FSA)
• UK Serious Fraud Office
• US Food and Drug Administration (FDA) Enforcement and Criminal Investigations
• US Food and Drug Administration (FDA) Food Defense
• US Food and Drug Administration (FDA) Import Alerts and Refusals
• US Food and Drug Administration (FDA) Recalls and Enforcement Reports
• US Pharmacopeial Convention Food fraud database 

The list below provides hyperlinks to the following standards:

• BRC Global Standard Food Safety Issue 7
• BS 10501, Guide to implementing procurement fraud controls 

The table below provides the specifications of supply chain security with their specification codes.

The list below provides hyperlinks to the following sources of information:

• FAO Early Warning Bulletin
• GIEWS
• INFOSAN 

The list below provides hyperlinks to material for further reading.

• Centre for the Protection of National Infrastructure Holistic management of employment risk (HoMER). London: CPNI, 2012
• GFSI position on mitigating the public health risk of food fraud
• Scottish Government and Food Standards Agency Expert advisory group report the lessons to be learned from the 2013 horsemeat incident; 2013
• US Michigan State University