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Food Fraud Prevention

Economically-motivated adulteration
Table of contents

2 Introduction and purpose of this booklet

3 What is food fraud
4 Why is it important to prevent food fraud
4 Glossary of terms used in this booklet

5 Food fraud prevention process

6 Vulnerability assessment
10 Mitigation measures
10 – Raw material specifications
10 – Analytical surveillance
11 – Supplier relationship
13 – Supplier audit
14 – Supply chain transparency and simplification
16 Alert system

16 Frequently asked questions

19 Useful resources & tools

Introduction and purpose What is food fraud
of this booklet

The food industry considers the safety No process can guarantee that food Food fraud commonly encompasses • Deliberate mislabelling of food,
of its products as its main concern. Over and food supply are not the target of a wide range of deliberate fraudulent such as:
the years, industry and regulators have criminal activity. The purpose of this acts. The focus of this booklet – products substituted with
developed food safety management booklet is to guide food operators however, is on one type of food fraud a cheaper alternative,
systems, making major outbreaks of through approaches and processes to – the intentional and economically- e. g. farmed salmon sold as wild,
food poisoning now quite unusual in improve the resilience of supply chains motivated adulteration of foods. This or Basmati rice adulterated
many countries. These systems typically to food fraud. It provides guidance on is the fraudulent addition of non- with cheaper varieties;
use Hazard Analysis Critical Control how to assure the authenticity of food authentic substances, or the removal or – false statements about the source
Point (HACCP) principles, which are by minimising vulnerability to fraud and replacement of authentic substances of ingredients, i.e. their geographic,
accepted globally. HACCP has proven mitigating the consequences of food without the purchaser’s knowledge, for plant or animal origin.
to be effective against accidental fraud. economic gain of the seller.
contamination. This booklet does not address the
The two main types of economi- other types of food fraud such as
However, HACCP principles have cally-motivated adulteration are: counterfeiting (fraudulently passing
not been routinely used to detect or • Sale of food which is unfit and off inferior goods as established and
mitigate deliberate, fraudulent actions potentially harmful, such as: reputable brands), product tampering,
on a system or process. These actions – recycling of animal by-products theft, smuggling, document fraud, and
include the deliberate contamination of back into the food chain; product diversions. Neither does it cover
food, or food fraud. – packing and selling of meat with food adulteration intended to cause
This booklet unknown origin; public health harm, economic harm, or
• Describes a process for food fraud – knowingly selling goods past their terror (i.e. food defense issues).
prevention and the principles of the ‘use by’ date.
vulnerability assessment;
• Outlines measures that can deter
fraudsters, or give early detection
of food fraud; Food Safety Management System
• Provides sources of information
and intelligence that may help to
Food safety Food defense Food fraud
identify emerging threats.

Mitigation of Mitigation of Mitigation of

unintentional/ intentional intentional
accidental adulteration – adulteration –
adulteration – Ideologically Economically
Science based motivated motivated

2 3
Why is it important Glossary of terms Food fraud prevention
to prevent food fraud used in this booklet process

While it is not the intention of food • Economically-motivated Like any management system, a Periodically, or as changes occur that
fraud to harm consumers, such acts adulteration (EMA): The intentional food fraud management system is a may impact the previously identified
can cause illness and even death. This adulteration of foods, motivated by continuous process as depicted in the vulnerabilities (e.g. a newly identified
was the case in 2008 when melamine economic gain. It is the type of fraud figure below (from U.S. Pharmacopeia adulterant for an ingredient is reported,
was used as a nitrogen source to covered in this booklet. Appendix XVII: Food Fraud Mitigation changes in the supply chain for an
fraudulently increase the measured • Vulnerability assessment (or Guidance). It begins with an evaluation ingredient), the entire process must be
protein content of milk, resulting in vulnerability characterisation): step to characterise food fraud carried out again to ensure its continued
more than 50 000 babies hospitalised Within a food fraud management vulnerabilities, followed by the design effectiveness.
and six deaths after having consumed system, the step aimed at reviewing and review of a mitigation strategy, and
contaminated infant formula. and assessing various factors, which its implementation.
create vulnerabilities in a supply
The common factor in many cases chain (i.e. weak points where fraud
of food fraud, is that the adulterant is has greater chances to occur).
neither a food safety hazard, nor readily • Mitigation measure: Measure
identified (as this would defeat the aim taken to decrease vulnerability to a
of the fraudster). Common adulterants certain type of adulteration in a given Food Fraud Management System
include water and sugar, or ingredients supply chain.
that may be legitimately used and • Mitigation strategy: Selected
declared, but whose improper use set of mitigation measures aimed Implement Start
constitutes fraud. Food fraud deceives at preventing food fraud in a given tabl
the consumers by providing them with supply chain.

lower quality foodstuff, against their • Food operator: Organisation
knowledge and will. carrying out any of the activities
related to processing, manufacture, Changes
Determine if Vulner-
Economically-motivated adulteration packaging, storage, transportation, draft mitigation abilities impacting
deprives the consumers of the quality import, distribution of food, including strategy characteri-
or system
acceptable zation
products they intend to purchase. It can food services and sale. in place
also have serious implications on food • Supplier: The party that is supplying
safety and the health of consumers. The materials (raw or semi-finished), food

prevention of food fraud is paramount to ingredients or food products to other

protect the trust of our consumers and parties (e.g. food operators) in the

to maintain fair, sustainable business value chain. Draft of
practices. • Buyer: The party that is buying mitigation
materials (raw or semi-finished), food
ingredients or food products from

4 5
Vulnerability assessment

A general approach to prevent food To characterise the vulnerability of an

fraud can be summarised as follows: ingredient to food fraud, the following
• Conduct vulnerability assessment, 3 aspects must be assessed:
– Know your materials and Vulnerability driven by factors
risks (history, economic factors, inherent to the ingredient
geographical origins, physical Factors such as the ingredient market
state, emerging issues); price, its fraud history, composition,
– Know your suppliers physical state and level of processing 50
(manufacturer, broker, history); are entirely independent of the actions
– Know your supply chain (length, taken by the buyer to mitigate the risk
complexity, supply & demand of fraud. This is defined as the inherent
arrangements, ease of access); vulnerability of a food ingredient.
– Know your existing control Certain ingredients are by nature
measures. more vulnerable to adulteration (e.g.
• Design mitigation strategy and apple juices or apple purees are more
implement mitigation measures. vulnerable than apple pieces).
• Validate and verify mitigation 100
measures, continually review food Fraud history (past cases of adulteration /kg

fraud management system. of specific raw materials) is a good

source of information. It is an
indicator of the raw material potential
vulnerability, and an important source of
possible adulterants for which detection
and deterrence are needed.

Vulnerability driven by factors

impacting the business (business
Factors such as the demand for a
specific ingredient (volume), the extent
of its use (ingredient used in several
products and businesses), or the market
price fluctuation may contribute to an
increased level of vulnerability to fraud.

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

6 7
Any anomaly in the economics of may indicate a lack of food control In summary, assessing the risk of Self-assessment
particular raw material sources is an and/or regulatory/enforcement fraud for a food ingredient requires Recent food fraud crises have
indicator of the raw material potential framework in the country of origin (or the understanding of the inherent raw highlighted the need to reinforce
vulnerability. Drastic increases in market any other country through which the material vulnerabilities, the business companies’ ability to combat fraud
price and scarce supplies of a raw ingredient may transit). vulnerabilities, and the existing controls – within their own organisation, and
material (e.g. poor harvest following bad in place. This will allow to define which across the entire food value chain.
weather, or caused by a new parasite) Vulnerability driven by factors preventive actions are needed (and Companies are expected to work
are good indicators of increased under the control of the buyer where) to mitigate the risk of food proactively towards mitigating the risk
raw material vulnerability based on This reflects the strength, or the adulteration. of food fraud.
economic anomalies. weakness of a company’s mitigation Guidance and self-assessment tools
strategy (full traceability, adequate It is important to note that such a have been developed by a number of
Geopolitical considerations are also purchasing specifications, availability vulnerability assessment is not a one- organisations (e.g. US Pharmacopeia,
important to characterise vulnerability to of analytical methods, robustness of time activity but a dynamic process, SSAFE, BRC) to help food companies
food fraud. A country-specific low price surveillance programmes). which needs to be maintained with undertake their own vulnerability
compared with the rest of the market regards to new information and external assessments and implement
pressures (e.g. economic anomalies, appropriate control plans (see section
bad harvest year). Useful resources & tools).
Adequate mitigation measures alleviate vulnerability to food fraud

Inherent vulnerabilities

Raw material Past and potential

composition and raw material
processing adulteration

Business pressure

Market price Market price Your control and mitigation

fluctuation measures
Level of Traceability
Raw material demand/ verifications
business need
Adequacy of Availability of
raw material methods

Vulnerability assessement

8 9
Mitigation measures

Raw material specifications Analytical surveillance Supplier relationship • Trusted supplier: Long-standing
partnership-type arrangement.
Adequacy of raw material specifications Once the adulteration risks have been As a starting point, processes must High degree of confidence
is an important preventive aspect characterised for a given raw material, be in place to approve the suppliers’ established through long positive
against food fraud. Specifications and a set of analytical control criteria production sites, with requirements for business relationship, high degree
established for raw materials, which are defined – a surveillance plan should approval based on risk (e.g. raw material of transparency, and/or testing
used in the purchase of these materials, be established. The surveillance plan risk, location of food safety control programmes. Sharing of key
must include appropriate authenticity allows to build confidence in the measures, supplier performance). Once information and expectations.
criteria to mitigate – as much as company’s suppliers, gain reassurance suppliers have been qualified according Understanding of key needs and
possible – the inherent vulnerabilities on the company’s raw material supply, to a robust approval process, the controls in both the buyer and
identified in the self-assessment. For and confirm that the prevention relationship between buyer and supplier supplier processes.
example, UV absorbance is specified to measures in place are adequate … or is critical to support any adulteration • Trusted supplier, new ingredient:
detect the potential adulteration of extra in contrast, the surveillance plan may prevention effort. Similar to “Trusted Supplier”, except
virgin olive oil with refined oils. allow the detection of food fraud issues. the buyer only recently began
The closer the relationship, the more purchasing a particular ingredient
Specification criteria linked to food fraud Raw material monitoring should knowledge and confidence will be from the supplier. High degree of
prevention must be thoroughly defined, be performed using appropriate shared between each party. Ask confidence established through
in line with the level of complexity analytical methods for the verification yourself: How well do you know your purchase of other ingredients.
and variability of the ingredient’s of authenticity. The methods must be suppliers (e.g. how long have you • Established supplier, some
composition. selective, specific, and of appropriate been dealing with them and what is relationship: Short history of
sensitivity to verify that the food their track record like, what is their business with the supplier, who is
When a specific parameter needs to be authenticity process is efficient. There business situation and are they under well respected in their market with
measured to control the raw material are 2 approaches: any financial stress)? How can you learn a solid reputation, and no significant
authenticity, particular attention must • Targeted analyses (linked to more about them (e.g. partnerships, issues reported.
be given to using analytical methods parameters specified in raw material supplier schemes)? • Established supplier,
that are fit-for-purpose (i.e. adapted specifications); no relationship: Supplier respected
for the natural variability in the raw • Untargeted techniques (finger- Confidence is increased with a in their market with a solid reputation.
material). printing) that assess the raw material supplier’s readiness to share information A business relationship and history
integrity against adulteration. on their supply chain and processes. has not yet been established.
This is why the development of trusted • Unestablished supplier,
suppliers (rather than continuous no relationship: Often a new
rotation) is important in mitigating supplier, with whom the buyer has
the risk of food fraud. The closer the no history or any general industry
relationship, the lower the risk. knowledge of the supplier. The
supplier may be new to a given

10 11
Supplier audit

In response to food fraud issues food safety schemes in order to minimise

reported in recent years, a number the risk of operating sites purchasing
of requirements have been added to fraudulent, or adulterated raw materials.

One example (from BRC Issue 7, 2015):

– Processes in place to access – Where products are labelled or claims

information on historical and developing are made on finished packs which are
threats to the supply chain, which may dependent on the status of a raw material
present a risk of adulteration or substitution – including specific origin, breed/varietal
of raw materials. Such information may claims, assured status (e.g. GlobalGAP),
come from trade associations, government genetically modified organism (GMO)
sources, private resource centres. status, identity preserved, specific
trademarked ingredients – the status of
– Documented vulnerability assessment each batch of the raw material shall be
carried out on all food raw materials or verified.
groups of raw materials to assess the
potential risk of adulteration or substitution – The facility shall maintain purchasing
(this assessment shall take into account records, traceability of raw material
historical evidence of substitution or usage and final product packing
adulteration, economic factors which may records to substantiate claims. The site
make adulteration or substitution more shall undertake documented mass balance
attractive, ease of access to raw materials tests (e.g. every 6 months in the absence of
through the supply chain, sophistication a scheme-specific requirement).
of routine testing to identify adulterants,
nature of the raw material). The vulnerability – Where claims are made about the
assessment shall be reviewed to reflect methods of production (e.g. organic,
changing economic circumstances and Halal, Kosher) the site shall maintain the
market intelligence, which may alter the necessary certification status in order
potential risk. It shall be formally reviewed to make such a claim.

– Where raw materials are identified as

being at particular risk of adulteration
or substitution, appropriate assurance and/
or testing processes shall be in place to
reduce the risk (e.g. auditor to review the
historical test results of materials identified
at risk of adulteration).

The facility shall maintain purchasing records and the traceability of raw material usage

12 13
More targeted examination may be Supply chain transparency
carried out by auditors during audits and simplification
at a specific raw material production/
handling site. For example on a meat A streamlined upstream supply chain
production site – auditors may detect improves transparency, traceability, and
the presence of unapproved flavours, the management of material safety and
dyes or preservatives in the production quality standards. It also gives fewer
and/or storage areas. On a poultry opportunities for fraudsters to penetrate
production site – auditors may look your supply chain.
for the presence of equipment used to
inject brine. The first step towards supply chain
transparency is to ask yourself: Do you
have full visibility of your supply chain?
Who are your immediate suppliers?
Who supplies them? Are you changing
a supplier or process?

Supply chain simplification will require

that you:
– Map your supply chain;
– Gather information from suppliers to
identify those who are most at risk
(e.g. via questionnaire and supplier
assurance and audit processes), and
using expertise from both within
your organisation and outside (e.g.
your trade association) to gather the
relevant information;
– Simplify your supply chain as much as
possible to eliminate sources of risk.

How well do you know your suppliers?

14 15
Alert system Frequently asked questions

It is essential to maintain a routine watch Question: What is economically- certain food products. The number of (customers, distributors, companies
of official and industry publications, motivated adulteration (EMA)? documented incidents is most likely a – including competitors – operating in
which give an early warning of changes EMA is the intentional sale of sub- fraction of the true number of incidents, your business) to prevent the fraudulent
that may trigger new threats, or change standard food products or ingredients since the goal of EMA perpetrators is to material from reaching other parts of the
the priority of existing threats, including for the purpose of economic gain. avoid detection. value chain. Finally, you should report
more local issues as they develop (e.g. Common types of EMA include the case to competent authorities.
climate impact on certain crop yield and substitution or dilution of an authentic What is Nestlé doing to prevent
subsequent fraud). ingredient with a cheaper product food fraud? What should I do when I identify
(such as replacing extra virgin olive oil Nestlé has established a process for a new adulteration risk?
Conversely, it is of paramount with a cheaper oil), flavour or colour prevention and mitigation of EMA, which You should include this new risk in
importance to trigger an alert when a enhancement using illicit or unapproved includes a vulnerability assessment step your vulnerability assessment for the
fraudulent material is detected. Alert substances (such as unapproved dyes), (per raw material category), the definition concerned raw material category, then
your business partners to prevent the and substitution of one species with of mitigation measures, and the define measures that could mitigate
adulterated material from reaching other another (such as fish species fraud). continual review of both the vulnerability this particular risk, and continue to
parts of the value chain. Report the case assessment and the efficiency of monitor this risk (e.g. through analytical
to the competent local authorities and/ Is EMA the same as “food fraud”? mitigation measures. Nestlé also drives surveillance plans) to ensure that your
or national food crime unit for further EMA is often referred to as “food longer-term initiatives (e.g. development mitigation measures are effective to
investigation. fraud”. The two terms are used of non-targeted analytical methods, prevent occurrence of this issue in your
interchangeably. development of collaborative tools supply chain.
across the industry and with authorities
Is EMA the same as contamination? to create transparency across the food What should food operators and
Whereas EMA is intentional and value chain). suppliers do about food fraud?
perpetrated for the sake of economic To prevent food fraud and better ensure
gain, contamination of a food product What should I do when I detect an food safety and consumer protection,
or ingredient can be accidental, adulterated material? food operators, their suppliers and
environmental, or malicious (i.e. not for Assess the impact of the deviation all partners along the food value
economic gain). (food safety, regulatory, impacted chain (including industry associations
products) with the support of experts and authorities) should consider the
What foods are affected by EMA? whenever needed. Take action based following:
Many foods are susceptible to EMA. on the outcome of the assessment – Conduct vulnerability assessments in
These include meat, fish and seafood, (e.g. block raw material and/or finished their supply chains;
dairy products, fruit juices, oils, honey, product stock, destroy stock, recall – Implement (and verify) mitigation
spices and wine. EMA is not a new products). You should then conduct measures accordingly;
concern, although there seems to a full traceability exercise to identify – Develop collaborative tools across
have been an increase in incidents the source of the adulterated material, the industry and with authorities to
over the recent years. This is partly and have an investigation initiated. You create transparency across the food
due to increased media coverage and, should alert your business partners value chain.
perhaps, increased surveillance in
16 17
Useful resources & tools

What should consumers know milk supplies with a chemical called Guidance documents – US Pharmacopeial Convention
about food fraud when purchasing melamine, because it artificially Food fraud database; http://www.foodfraud.org/
– U.S. Pharmacopeia Appendix xvii: – Canada Recalls and Alerts
food? increased the apparent protein content. http://www.healthycanadians.gc.ca/recall-
Food fraud mitigation guidance
There are certain things consumers Melamine-adulterated milk was used http://www.usp.org/sites/default/files/usp_pdf/ alert-rappel-avis/index-eng.php
can do to help protect themselves from in the manufacture of infant formula, EN/fcc/food-fraud-mitigation-guidance.pdf – European Union Rapid Alert System
– BRC Global Standard for Food Safety Issue 7 http://ec.europa.eu/food/safety/rasff/portal/
food fraud. If the price of a valuable which led to the hospitalisation of more index_en.htm
Understanding Vulnerability Assessment
food product is too good to be true, it than 50 000 Chinese infants, and the http://www.brcbookshop.com/p/1782/ – UK Food Standards Agency (FSA)
probably is. Whole, unprocessed foods deaths of at least six. In 1981, industrial- brc-global-standard-for-food-safety-issue-7- http://food.gov.uk/enforcement/enforcework/
understanding-vulnerability-assessment-uk- foodfraud/
(such as unground coffee and spices, grade oil adulterated with multiple – UK Serious Fraud Office
or whole fruits instead of juice) are chemicals was sold as olive oil in Spain, – UK Food and Drink Federation (FDF) http://www.sfo.gov.uk
more difficult to adulterate, therefore and resulted in more than 300 deaths. http://www.fdf.org.uk/corporate_pubs/Food- – Australia and New Zealand
Authenticity-guide-2014.pdf http://www.foodstandards.gov.au/science/
buying these foods may offer some surveillance/Pages/default.aspx
– TACCP (Threat Assessment and Critical
reassurance with regards to fraud. As Does EMA only affect humans? Control Point): a practical guide 2014 – The Department of Food Safety, Govt
for processed foods, it is a good idea to What about pets? (Campden BRI) http://www.campdenbri.co.uk/ of N.C.T of Delhi
publications/pubDetails.php?pubsID=4640 http://dcwestrev.delhigovt.nic.in/pfa/newweb/
buy from reputable sources and brands Since the food supply chains for humans, CompleteListFoodCategory.asp?SessNull=0
that have a vested interest in protecting pets and production animals are – EMA Susceptibility Database
their reputation. When fraud incidents interconnected, EMA in food products Self-assessment tools www.FoodSHIELD.org (registration required)

are discovered, they can result in large can affect both humans and animals.
– SSAFE Food Fraud Assessment Tool
profit losses and reputation damage In 2007, an EMA incident involving https://ffv.pwc.com; www.ssafe-food.org Standards
for companies. Therefore, companies adulterated wheat gluten used in pet – US Food and Drug Administration (FDA)
Vulnerability Assessment Software – BS 10501, Guide to implementing
with brand recognition will actively take food caused illnesses and death in procurement fraud controls
steps to protect their products. Some thousands of dogs and cats in the USA. ToolsEducationalMaterials/ucm295900.htm http://shop.bsigroup.com/ProductDetail/?
trade associations also certify products pid=000000000030282473
– BRC Global Standard Food Safety Issue 7
through quality and purity assurance Are government regulatory http://www.brcbookshop.com/p/1656/brc-
Alerts & Databases
testing programmes, such as the agencies concerned about EMA? global-standard-for-food-safety-issue-7-us-
North American Olive Oil Association In the USA, the US FDA (FDA.gov), – US Food and Drug Administration (FDA) free-pdf

Seal Program (http://www.naooa.org/ USDA (USDA.gov), and DHS (DHS.gov) Recalls and Enforcement Reports
sealprogram). are working to protect the food supply – US Food and Drug Administration (FDA) Supply chain security
from EMA and other food safety risks. In Import Alerts and Refusals
http://www.fda.gov/ForIndustry/ – BS ISO 28000, Specification for security
Does EMA cause harm to health? the European Union, the food industry management systems for the supply chain
The good news is that most incidents and regulators are working towards Online tool compiling information on import – BS ISO 28002, Security management systems
of EMA do not result in public health an enhanced management framework refusals for the supply chain – Development of
http://www.imprex.us resilience in the supply chain – Requirements
harm. Unfortunately, perpetrators to prevent food fraud, with guidance with guidance for use
– US Food and Drug Administration (FDA)
sometimes make mistakes resulting available from e.g. the UK Food Enforcement and Criminal Investigations – PD CEN/TR 16412, Supply chain security
in unintended health consequences. Standards Agency. Other government http://www.fda.gov/ICECI/ (SCS) – Good practice guide for small and
– US Food and Drug Administration (FDA) medium sized operators
In 2008 for example, some companies agencies provide useful resources (see
Food Defense
in China were found to be adulterating section Useful resources & tools). http://www.fda.gov/Food/FoodDefense

18 19
Sources of information Further reading
and intelligence about
emerging risks to food supply – Gfsi position on mitigating the public health
risk of food fraud http://www.mygfsi.com/
– Infosan files/Technical_Documents/Food_Fraud_
http://www.who.int/foodsafety/areas_work/ Position_Paper.pdf
infosan/en/ – Scottish Government and Food Standards
– FAO Early Warning Bulletin Agency Expert advisory group report
http://www.fao.org/food-chain-crisis/ the lessons to be learned from the 2013
early-warning-bulletin/en/ horsemeat incident; 2013.
– Giews http://www.scotland.gov.uk/
http://www.fao.org/giews/english/index.htm Resource/0043/00437268.pdf
– Centre for the Protection of National
Infrastructure Holistic management
of employment risk (HoMER). London: CPNI,
2012. http://www.cpni.gov.uk/advice/
– US Michigan State University
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