Food fraud is both a national and international problem for consumers and food businesses alike. It is not new; however, the motivation to commit food fraud is on the rise.
This article aims to give an overview of what food fraud is using example case studies, current legislation, and what the motivation may be of those responsible.
If you work in or own a food-business in manufacturing, retail or catering you should be aware of what food fraud is, the types of threat that may be present and how your business can avoid becoming complicit in food fraud without realising it.
What is Food Fraud?
Food fraud is when food products are deliberately tampered with, mislabelled or represented, diluted or when an ingredient is substituted for another more inferior product.
In “Defining the Public Health Threat of Food Fraud” (2011 Sink and Moyer define food fraud as:
“Food fraud is 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.”
What are the most common types of food fraud?
The most common types of food fraud are:
- Adulteration – This is when a foreign substance is added to lower the cost or fake higher quality.
- Substitution – When an inferior ingredient is used to replace another food or ingredient.
- Document fraud – These are documents that have been created and used fraudulently to sell or market a product.
- Theft – Food or drink is obtained by illegal means and used or sold for profit.
- Unlawful processing – This is when unapproved premises or unauthorised techniques are used, for example, the slaughter and preparation of meat.
- Waste diversion – The unlawful act of diverting food or drink that is meant for disposal back into the supply chain.
Are some foods more susceptible to food fraud?
Yes. Fish, red meat, dairy and alcohol are foods most likely to be fraudulent, with mislabelling and substation being most reported.
Other foods susceptible to food fraud include:
- Olive oil
- Fruit and vegetables
- Nuts, spices and herbs (i.e. Saffron)
- Fruit juice
EMA (Economically Motivated Adulteration) – Example
One example of adulteration is also known as economically motivated adulteration (EMA). The main motivation behind EMA is usually financial, to cut down on expensive elements of production by substituting cheaper products.
One such case of this is the highly publicised incident of the horsemeat scandal in the UK in January 2013. A routine test of burgers for sale in an Irish supermarket showed that the “100% beef burgers” were substantially contaminated with horse meat as an adulterant.
The FSAI (Food Standards Authority of Ireland) alerted major supermarkets who immediately withdrew the products. Of 27 beef burger products subsequently tested, 37% showed positive for horse, 85% for pig. Although meat, and edible, this was a betrayal of the customer, many of which would not eat certain meats for cultural, moral or religious reasons.
Further investigations proved this adulteration for profit to be very widespread throughout a complex supply chain covering many countries. Some “beef” products showed 100% horse meat and were the result of criminal activity at source, i.e. at the slaughterhouses, many of which were situated abroad in countries like Poland and Romania.
In this instance, the main motivation behind EMA is financial, to cut down on expensive elements of production by substituting cheaper products.
Why do people commit food fraud?
Food fraud is often mostly committed for monetary gain. However, there are other motivations for engaging in food crime such as a desire for publicity, or a disgruntled employee of a company who has malicious intent.
One such case happened in 2009 when Tesco was among businesses to suffer under a disgusting campaign in Gloucestershire. A member of the public saw a man spray a mixture of his urine and faeces in branches of Morrisons and Tesco, a pub and a Waterstones bookshop. An estimated £700,000 was lost in contaminated products and lost business due to store closures.
What is the impact of food crime?
Food crime is of major concern to all of us as consumers, to food businesses (profits and consumer confidence) and the economy. The food, drink and catering industry accounts for 11% of the UK economy. Food crime cost the UK economy around £11.2 billion a year.
Apart from the monetary aspect of businesses, there is also the threat to consumers’ physical health from eating or drinking contaminated foods. Consumers value truth and transparency as they need to know that the product is what it says it is on the label. If this is not the case, it may diminish consumer confidence.
What is being done to combat food crime?
The food public policy-making is under development. Laws, regulations, standards, certifications, and best practices for food fraud prevention are just developing. Work on the development of methods and the administration of tests related to food authenticity has a long history and is now expanding to consider a range of food fraud types.
In 2014, the independent review conducted by Professor Elliot made recommendations to the government regarding the Integrity and Assurance of Food Supply. As part of the government response to these recommendations, the Food Standards Agency (FSA) established the National Food Crime Unit (NFCU) in December 2014.
The government’s stated aim for the unit is for it “to give greater focus to enforcement against food fraud in government by analysing intelligence, initiating investigations and liaising with other criminal and regulatory enforcement agencies”.
Although there haven’t been other instances of fraudulent foods as high profile as the horsemeat incident, we may feel as though this is no longer an issue. However, food fraud is very prevalent and is one of the most urgent food research topics.
Food fraud/food defence in food safety and quality standards
In 2017, the British Standards Institute (BSI) in conjunction with DEFRA (Department for Environment, Food and Rural Affairs) and FSA (Food Standards Agency), published an updated edition of PAS 96, which is a guide to protecting and defending food and drink from deliberate attack. (Elements of this guidance is covered later in the course).
“The focus ……is on protecting the integrity and wholesomeness of food and food supply. Any intending attacker, whether from within a food business or its supply chain or external to both, is likely to attempt to elude or avoid routine management processes. It should help food businesses mitigate each of these threats, but the approach may also be used for other business threats”
Source: (PAS96 2017)
Food defence procedures are adopted to assure the security of food and drink and their supply chains from malicious and ideologically motivated attack leading to contamination or supply disruption (PAS97).
In terms of food production, a threat is defined as a deliberate act by an individual or group to cause harm to the consumer or loss to the business.
Vulnerability is defined as the degree of exposure the business is to the threat of having an impact on the consumer. There are two approaches to food defence:
- TACCP – Threat Assessment & Critical Control Point
- VACCP – Vulnerability Assessment & Critical Control Point
Just as HACCP is a systematic assessment of food safety hazards that might threaten the production of safe food, TACCP is a systematic assessment of the threats to the business from attack through fraud and other malicious actions.
VACCP employs a systematic approach to evaluate the vulnerabilities (susceptibility to food fraud risk) that may be present in a business.
Both approaches are complementary and can be assessed and managed under a single threat and vulnerability management system.
Is it a legal requirement to have a food defence system in place?
It is not a legal requirement to have a food defence system in place, but the BRC (British Retail Consortium) and the leading industry experts the Global Food Safety Initiative (GFSI) strongly recommend that if food companies accept food deliveries, one should be in place.
For those food businesses that are audited against the BRC Global Food Safety Standard, food defence and the potential for deliberate malicious contamination from both internal and external sources need to be risk-assessed, defined, documented, controlled, monitored and reviewed.
BRC Issue 8 covers:
- A documented risk assessment plan (threat assessment)
- Areas where significant risk is identified
- Circumstances when the plan is reviewed
- Raw material assessment and controls
- Site security issues
For the full BRC 8 requirements for food defence, go to www.brcglobalstandards.com
SALSA (Safe and Local Supplier Approval)
SALSA has been specifically designed for small and medium-sized food operations (SMEs). Issue 5, 2018 covers:
- A documented risk assessment of all food raw materials and packaging in terms of adulteration or substitution
- Identification of non-conforming materials and annual testing of incident management procedures
- The necessity of maintenance of a full traceability system
- Documented raw material assessments in terms of food integrity
For the full requirements for food defence in Section 1.6.4, go to https://www.salsafood.co.uk.
For more information, we have an online TACCP and VACCP course that explains the principles of food defence in more detail. The course also contains a case study to illustrate the practical application to a food business.