Threat of food fraud

substitution and protecting the

integrity of product claims (such
as Free From) during Covid-19

Presented by: Jessica Burke

& John Figgins

00 Month
May 29th, 2020
Paula Parejo
Welcome from BRCGS

• Who we are

• How we can support you

during COVID-19
Poll
Question
 Q&A
Period
www.brcgs.com/resources/covid-19-response/
Agenda

• What is Food Fraud?

• Types of Food Fraud
• Impact of Food Fraud
• Ingredients commonly involved in food
fraud
• Past Food Fraud Incidences
• Increased Fraud risk due to Covid-19
• Examples and predictions
• Protecting the Integrity of Product
Claims
• Guidance & Tools
Presenters

Jessica Burke John Figgins

Senior Manager Technical Specialist

Technical Services Food

Poll
Question
What is Food Fraud?

Food Fraud is a fraudulent and

intentional substitution, dilution
or addition to a product or raw
material, or misrepresentation
of the product or material, for
the purpose of financial gain,
by increasing the apparent
value of the product or
reducing the cost of its
production.
Types of Food Fraud
• replacing or substituting ingredients with cheaper
alternatives (e.g. undeclared substitution of extra-
virgin olive oil with lower grades of olive oil or oils of
other botanical origin)

• undeclared dilution of genuine ingredients (e.g. the

dilution of fruit juices and fruit preserves with
undeclared cheaper fruits or sugar syrup)

• deliberate mis-labelling (e.g. of the animal species in

a meat product)
Types of Food Fraud

• making false claims regarding provenance or origin

(e.g. claiming organic status or making a false
geographic or varietal claim)

• counterfeiting to copy a well-known brand (e.g. by

falsification of records and/or packaging to make
inferior products, such as cheap alcoholic
beverages, appear to be premium products or well-
known brands).
Impact of Food Fraud
• Financial - estimates suggest that it costs the
world economy $49 billion annually and is
growing.

o Europol indicated that Operation OPSON VI

resulted in the seizure of more than 9,800
tonnes, 26.4 million litres and 13 million
units/items of counterfeit and substandard
food and drink worth an estimated €230
million.

• Serious health consequences (e.g. allergens,

gluten, melamine, diethylene glycol)
Impact of Food Fraud

• Safety or authenticity problems in

one ingredient shipment can have
a huge effect on the market if they
are not identified before products
get to retail

• Widespread supply chain

disruptions, and the inevitable
supplier adjustments that will need
to be made by producers, increase
the overall risk of fraud.
Ingredients commonly involved in food fraud
According to the Draft Report on the Food Crisis,
Fraud in the Food Chain and the Control Thereof
(2013/2091 (INI)) (European Parliament, 2013),
the top 10 food products most at risk of
adulteration or substitution are as follows:

• olive oil
• fish
• organic products
• milk
• grains
• honey and maple syrup
• coffee and tea
• spices (such as saffron and chilli powder)
• wine
• certain fruit juices
Ingredients most commonly involved in food fraud
The National Center for Food Protection and
Defense defines the top ten most fraudulent
foods as follows:

• Alcoholic beverages
• Oils and fats
• Meat and meat products
• Honey
• Spices
• Grains and grain products
• Coffee and tea
• Fish and seafood
• Dairy
• Produce.
Past Food Fraud Incidences

Addition of melamine to milk powder

resulting in the deaths of six babies Nigerian customs warn the population Distribution of eggs contaminated
and made 300,000 infants ill (2008, that fake rice made of plastic is with fipronil and false “free range”
China) entering the market (2016, Nigeria) claim (Holland

2008 2013 2016 2018 2019

Beef substituted with horsemeat (2013, ‘Locally’ caught fish sourced from far
EU) away (2018, USA)
Poll
Question
Increased Fraud risk due to Covid-19
Changes in commodity prices

• Shortages of supply of materials are often

accompanied by price rises and this can
increase the risk of fraudsters entering the
market with substituted products, extended
products or false claims

Changes in supplier relationships

• Shortages may lead to the need to change

suppliers. New suppliers will lack the history
and confidence that has been established
with current suppliers
Increased Fraud risk due to Covid-19
Supply chains have seen major disruptions

• Shortages of people to harvest crops

• Multiple large meat processing facilities shut down

due to COVID-19 cases

• Recommendations for employee distancing

measures that reduce processing rates.

• Reduced staffing levels resulting in less scrutiny

from managers, other staff, economic pressures
felt by business

• Exports out delayed or stopped due to labor

shortages and lockdown measures.
Increased Fraud risk due to Covid-19
Regulatory oversight and audit programs have been
modified:

• Flexibility in labeling for certain food products

• temporarily conducting remote inspections of food

importers

• Limiting domestic inspections

• Prioritization of certain regulatory activities and

temporarily suspending those activities determined
to be “low risk.”

Adjustments to regulatory oversight is may increase the

risk of fraud in the food system!
Examples and predictions
Thousands of kilograms of “stale” and “toxic” fish and shrimp
illegally brought into India to replace supply shortages
resulting from the halt in fishing due to lockdown measures
• https://www.newindianexpress.com/cities/thiruvananthapur
am/2020/apr/11/stale-tuna-fish-prawns-flood-markets-
2128555.html

According to the US Department of Agriculture, there will be

a decrease in the international volume of meat commerce
due to COVID-19. Beef will be more strongly affected
followed by chicken meat, the least affected will be pork.
The decrease could be up to 60 % according to some
models.
• https://apps.fas.usda.gov/psdonline/circulars/livestock_poult
ry.pdf

Certain high-value products, such as botanical

ingredients used in foods and dietary supplements (in
particular, turmeric) may be especially at risk
• https://abc.herbalgram.org/site/SPageNavigator/ABC_Advisory_BAPP_COVI
D_Update.html
Protecting the Integrity of Product Claims

BRCGS Food Safety - Requirement

5.4

• Systems shall be in place to

minimize the risk of purchasing
fraudulent or adulterated food
raw material and to ensure that
all product descriptions and
claims are legal, accurate and
verified.
Protecting the Integrity of Product Claims
Gluten-Free claims may be at risk

• Agricultural products that are inherently Gluten-Free

may be contaminated by cereals containing gluten
during planting, cultivation, harvesting, transport,
processing, etc.

• Special processes need to be in place to prevent

cross contamination to ensure truly Gluten-Free.
Protecting the Integrity of Product Claims
Gluten-Free claims may be at risk

• Gluten-Free grains may be more expensive due to

the extra procedures required

• Gluten-Free grains may be less available due to

supply chain disruptions

• This may increase the risk of fraudulent activity

Protecting the Integrity of Product Claims
Example – Regular oats are frequently contaminated
by other grains containing gluten

• often grown in the same fields or in proximity to

wheat, rye, and barley crops.

• The purity of the seeds may be an issue

• Shared equipment to sow, harvest, transport, store,

process, and package

• Purity protocol - use of pure seeds, field

management, cleaning and inspecting equipment,
grain sampling, etc

• Mechanically and optically sorting grains based on

their size, shape, color, and density

• Testing
Protecting the Integrity of Product Claims
Other examples of agricultural products used
often used to replace gluten:

• pulses (beans, chickpeas, fava beans, lentils,

peas, etc.)
• rice (glutinous, wild, etc.)
• buckwheat
• seeds (chia, flax, hemp, pumpkin, sesame,
sunflower, etc.)
• soy
• corn
Guidance
Maintain a close working relationship between the buying and technical teams to
share information on changing circumstances and access the potential risks from fraud.

Closely monitor raw material shortages and price changes to identify raw materials at
greatest risk from fraud.

Pay close attention to articles and published incidents of fraud

Review the raw material risk rating and contingency plans

Increase testing or inspection procedures where appropriate for raw materials

identified to be at increased risk.
Tools
• Global Standard Food Safety Issue 8: Understanding
Vulnerability Assessment:
https://brcgsparticipate.com/

• PAS 96:2017 – Guide to protecting and defending

food and drink from deliberate attack:
https://www.bsigroup.com/en-GB/PAS-96/

• SSAFE Food Fraud Vulnerability Assessment Tool:

http://www.ssafe-food.org/

• EU Science Hub. Monthly summary of articles on

food fraud and adulteration: https://www.
ec.europa.eu/jrc/en/food-fraud-and-
quality/monthly-summary-articles
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