The growing threat of food fraud

Food fraud is a centuries-old phenomenon, and in recent years several scandals in the food sector have made headlines. Consider, for example, the horsemeat scandal that hit Europe in 2013 and the fipronil crisis in 2017. Such incidents have led to food fraud increasingly being seen as a growing threat worldwide.

This is why the GFSI Benchmarking Requirements incorporated two new key elements relating to food fraud in version 7.0 of February 2017.

• Carrying out a vulnerability assessment with regard to food fraud.
• Putting in place adequate measures to limit the risk of food fraud.

Before going deeper into this topic, let's first explain exactly what food fraud is and what types exist.

What is food fraud?

Food fraud is defined as:

• The fraudulent and intentional substitution, dilution or addition of a product or raw material; or the misrepresentation of a product or material, for the purpose of financial gain. This is done by increasing the apparent value of the product or by reducing production costs.

This definition does not only apply to the company's own production, but must also be extended to any outsourced processes.

Despite the growing threat posed by food fraud, there is currently no generally recognised definition within European legislation. Only Regulation (EC) No 178/2002, in Article 8 "Protection of consumers' interests", provides that fraudulent or deceptive practices must also be avoided.

Types of food fraud:

GFSI defines 7 types of food fraud.

1. Dilution

Mixing a high-value liquid ingredient with a lower-value liquid.

E.g.: diluting olive oil with cheaper oils.

2. Substitution

Replacing a high-value ingredient or part of the product with another, lower-value ingredient or part.

E.g.: partially replacing sunflower oil with mineral oil.

3. Concealment

Hiding or masking the lower quality of a product.

E.g.: adding Sudan red to mask the colour of lower-quality paprika.

4. Unapproved enhancements

Adding unknown, undeclared ingredients or additives to food in order to improve its qualitative characteristics.

E.g.: adding melamine to milk to artificially boost its protein content.

5. Mislabelling

Placing false claims on packaging.

E.g.: false claims regarding origin or production process.

6. Grey market production/theft/diversion

Selling undeclared surplus products.

E.g.: selling products that, following a food safety issue, may no longer be marketed within the food chain.

7. Counterfeiting

Copying a brand, packaging concept, recipe, processing method, etc. of products.

E.g.: copying popular food products without them being produced with acceptable safety guarantees.

How does GFSI want to combat food fraud?

The GFSI Benchmarking Requirements incorporated two new key elements to limit food fraud.

• Carrying out a vulnerability assessment with regard to food fraud.
• Putting in place adequate measures to limit the risk of food fraud.

Vulnerability assessment and possible associated measures

• Food Fraud procedure

A Food Fraud team must be set up, bringing together the following elements:

• Knowledge of the supply chain.
• Direct contact with suppliers and/or traders.
• Knowledge of raw materials and potential hazards.

• Gathering information

To carry out a good vulnerability assessment, it is important to gather and monitor the necessary information. This can be done via conventional media or via specific channels such as trade journals, newsletters, notifications from the authorities (RASFF Portal, European Commission), etc.

• Vulnerability assessment

Any weak points in the supply chain must be identified. Account should be taken of the type of raw material, the supplier and/or the length of the supply chain, the likelihood of detection and the potential impact.

• Control measures

If the vulnerability assessment reveals that certain raw materials are susceptible to food fraud, adequate control measures must be defined. Possible measures include: certificates of analysis, positive release of raw materials, specific entry controls, and choosing alternative ingredients or suppliers.

• Verification

The vulnerability assessment must be kept up to date. An annual review is therefore the absolute minimum. Verification must also take place whenever ingredients or suppliers change. Other possible reasons for an interim review include: sudden price fluctuations, the emergence of new risks, an increase in fraud-related complaints, etc.

Fraud involving packaging materials

This article mainly discusses "food" fraud in the strict sense. Fraud involving packaging materials is also possible, although the line between quality and fraud is a thin one there. Think, for example, of: misuse of the FSC label, thinning of plastic film, or using recycled material instead of virgin packaging material.

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AMNorman has the expertise needed to provide you with useful information and support you in developing a food fraud analysis that complies with GFSI standards.