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 1 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 identify emerging threats. Food safety Food defense Food fraud 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 le mitigation constitutes fraud. Food fraud deceives at preventing food fraud in a given tab p strategy e the consumers by providing them with supply chain. c c lower quality foodstuff, against their • Food operator: Organisation a knowledge and will. carrying out any of the activities related to processing, manufacture, Changes Determine if Vulner- impacting Economically-motivated adulteration packaging, storage, transportation, draft mitigation abilities vulnerabilities strategy characteri- deprives the consumers of the quality import, distribution of food, including 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 Not acceptable 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 strategy materials (raw or semi-finished), food ingredients or food products from suppliers. 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: including: – 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 /kg – 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 pressure) 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