WHITE PAPER

FOOD FRAUD:
PROTECTING YOUR PRODUCTS
AGAINST FOOD FRAUD
intertek.pt
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD

CONTENTS

Protecting your products against food fraud 3

Introduction 3
What is food fraud? 4
Background and regulation framework 4
Top 10 most fraudulent products 5
EU Commission 2015 Recommendation 6
How do you foresee the unforeseen? 6
A unified solution 8
In summary 8
Supporting You 8

intertek.pt 2
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD

INTRODUCTION

Food fraud is an emerging topic with most consumers unaware that some of the products
they are buying may be fraudulent. When it comes to designer handbags that are too cheap
to be true for instance, consumers are savvy enough to realise that these aren’t likely to
be authentic. But take an ordinary looking bottle of extra virgin olive oil on an offer or at a
discounted price and even the smartest consumer might not suspect that behind the label
could lurk 12 ounces of common corn oil.
So why don’t we come to the same assumption?

intertek.pt 3
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD
FOOD FRAUD:
PROTECTING YOUR PRODUCTS
AGAINST FOOD FRAUD
In countries where there are relatively
strict labelling regulations, some food
manufacturers still manage to cheat the
consumer by adding fillers or diluting the
real product with less expensive ingredients.
While respectable food companies
implement many processes and procedures
to ensure that they produce safe and quality
products, making food fraud a major concern
for them.
intertek.pt
What is food fraud?
First of all we have to clarify the two terms surrounding food fraud as they have different
meanings or expectations in different countries.
Authenticity concerns the truthfulness of origins, attributes, commitments, sincerity,
• 
devotion and intentions.
Adulteration is an addition of another substance to a food item in order to increase the
• 
quantity of the item. Adulterated food is impure, unsafe or unwholesome food and may
result in the loss of actual quality.
Food Fraud is committed when food is deliberately placed on the market with the intention of
deceiving the consumer for financial gain.
Although there are many kinds of food fraud – the two main types are:
• The sale of food which is unfit and potentially harmful (e.g. the recycling of animal-by-
products back into the food chain, the packing and selling of beef and poultry with an
unknown origin, or knowingly selling goods which are past their “use by” date)
• The deliberate mis-description of food, such as products substituted with a cheaper
alternative (e.g. farmed salmon sold as wild, Basmati rice adulterated with cheaper varieties)
or making false statements about the source of ingredients (e.g. their geographic, plant or
animal origin)
Background and regulation framework
Food fraud has always been an issue, with cases dating as far back as the Roman Empire
when the first artificial sweetener led to reported cases of lead poisoning. It is only recently
that food fraud has become prominent with several cases coming to light over the last few
years.
In 2006, pork in China was found to contain the banned chemical Clenbuterol to enhance
fat burning and muscle growth and affected over 300 people. In 2008, substances such as
sulphuric and hydrochloric acid had been used to dilute wines in Italy. In 2013, beef products
were found to be adulterated with horsemeat. This lead to major product recalls across
Europe, the loss of consumer confidence, as well as changes to legislation.
More recently, the recall of cumin and cumin-containing products prompted the Food & Drug
Administration (FDA) to report that “about 700 different products have been recalled by more
than 40 manufacturers and retailers in the US alone since last year.”
The responsibility for tackling food fraud lies in a number of places. Politicians and
Governments are responsible for setting the norms and regulations, the industry is
responsible for following strict guidelines when developing and selling their products,
plus the consumer is responsible for their own buying behaviour. However, the media
is also responsible with consumer magazines declaring themselves as spokespeople or
representatives of the consumer and maintaining high levels of public confidence.
Based on the EU Framework Regulation which lays down general principles and requirements
of Food Law, it is stated in Article 11 that it is mandatory for food products including imported
food products to comply with the law. With the industry and the importer having the largest
share of the responsibility, these organisations spend high amounts of money on quality
assurance.
4
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD

EC 178/2002 General Principles and Requirements of Food Law - Article 11 “Food and feed
imported into the Community for placing on the market within the Community shall comply
with the relevant requirements of food law or conditions recognised by the Community to be
at least equivalent thereto or, where a specific agreement exists between the Community
and the exporting country, with requirements contained therein.”
Article 17 states that business operators along the chain and not just the businesses placing products
on the market are responsible for fulfilling the requirements and have to verify that they are met.
EC 178/2002 General Principles and Requirements of Food Law - Article 17 “Food and
feed business operators at all stages of production, processing and distribution within the
businesses under their control shall ensure that foods or feeds satisfy the requirements of
food law which are relevant to their activities and shall verify that such requirements are met.”
Finally, Article 18 is about traceability which is a key element for food safety and has to
be established at all stages of production, processing and distribution. This is a general
requirement but in reality it is a huge amount of work and creates an enormous amount of
data which needs managing e.g. for a composite product.
EC 178/2002 General Principles and Requirements of Food Law - Article 18
“The traceability of food, feed, food-producing animals, and any other substance intended
to be, or expected to be, incorporated into a food or feed shall be established at all stages of
production, processing and distribution.”

Top 10 most fraudulent products:

The European Union (EU) has published a motion for a European Parliament Resolution on the
food crisis, fraud in the food chain and the control thereof (2013/2091(INI)) as a consequence
of the current food fraud situation. An outcome of which is the production of a top 10 list of
food products that are most at risk of food fraud.
Olive oil: It is well known that there is not enough olive oil production to cover the sales of
• 
native olive oil. The problem is the missing analytical evidence. Food fraud has been found
where extra virgin olive oil has been cut with hazelnut oil – this is particularly dangerous to
people with nut allergies. Additionally, cheaper oils such as vegetable, palm and soybean
have been added to dilute this expensive oil.
• F
 ish: Fish that was labelled as white tuna and butter fish was found by the U.S.
Pharmacopeial Convention. This fish is known as Escolar and has been banned in Italy and
Japan, as it has a high rate of food poisoning.
• Organic foods: These often turn out to be just plain conventional foods.
Milk: With the demands on cattle and EU milk, alternative animal milk is now commonly
• 
being introduced like buffalo, goat and sheep. In the Asia Pacific (APAC) region there have
been reported cases of “fake milk” which consists of ingredients like oil, urea, detergent,
caustic soda, sugar, salt and skimmed milk powder.
Grains: Many adulterants have been found in rice, lentils and grains including a variety of
• 
herbicides, pesticides and toxins such as melamine. Basmati rice has also been substitued for a
cheaper alternative.
• H
 oney and maple syrup: There are more jars of Manuka honey, which is hailed as a
‘superfood’, being sold in the UK than actually produced, according to a new report.
Alternative cheap honey also includes ingredients used to either replace or bulk out the
honey, like high fructose corn syrup.
• C
 offee and tea: Researchers have found all kind of things in coffee, from twigs to
parchment. Chicory has also been found but this does not lead to a safety issue but it
should be listed on the label. Examples have been found which contained coloured sawdust
instead of tea. Additionally many different pollutants have been found.
• S
 pices (such as saffron and chilli powder): Many packaged spices contain adulterants
especially if they are in powdered form as they can be easily substituted with
adulterants such as sulfate and borate. Saffron is the spice which is found to be most
commonlyfraudulent due to its expensive nature.

intertek.pt 5
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD

• W
 ine: Wine can be adulterated with cheaper products like fruit juice or contain harmful
chemicals such as the toxin diethylene.
• C
 ertain fruit juices: In apple juice, many other ingredients are added like other juices or WHAT IS FOOD
sweeteners. In fact, many juices have clouding agents added to make them look fresh. FRAUD?
Orange juice has been found to be watered down and known to contain various illegal
fungicides. Lemon, grapefruit, beet sugar and of course high fructose corn syrup have also “Food Fraud is committed when food
all been found. is deliberately placed on the market
with the intention of deceiving the
consumer for financial gain.”
EU Commission 2015 Recommendation
The EU has released a coordinated control plan to get more information about fraudulent
practices in the marketing of these products. 2015 concentrated on honey and fish species
with 2,600 honey samples taken and analysed.
The unique factor is that they also take into account other available data to find suspicious
goods like prices or physical checks. In these cases the analytical test methods are well
established and validated.

How do you foresee the unforeseen?

A number of questions need to be answered.
• What does your prevention plan look like?
• How do you prevent and protect yourself against the unknown?
• What is the solution?
Food fraud at its root is a criminal activity. Whilst food legislation has been put in place to
combat fraud, it is only successful by implementing preventive measures and management
systems to increase your probability of detection.
As a food operator you need to consider a food defence strategy that addresses the entire
supply chain. There are many choices you can take to try and prevent food fraud. Every
element makes its own contribution to food safety and the protection of the chain.

Testing
There are many questions that can arise from introducing testing as a preventive measure
you can put in place to stop food fraud.
Who takes the sample? An authority, the seller, buyer or trader, an independent party, or the
consumer?
Is the sample representative? What is the reference, norm and experience, should it be risk-
oriented or case-related and who is monitoring? Should it be a single or pooled sample?
Testing of the sample? Should it be in-house or external, which laboratory should do the
testing and using which method, should you screen, shoud it be known, unknown, or risk-
oriented?
What do you do when a test result does not deliver a clear result?
Testing is a good element for quality checks but should not be your only process in avoiding
food fraud.

Auditing
There are several audit possibilities along the food suply chain. Audits are a standard element
for the supplier and product qualification process. They refer to the scoring and risk evaluation
of each supplier. The range of standards is broad and complex and includes Hazard Analysis
and Critical Control Point (HACCP), Global GAP, International Featured Standards (IFS) and
British Retail Consortium (BRC). Additionally many companies have their own specific internal
procedures and requirements.

intertek.pt 6
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD

The scope, assessment criteria and checklist for each audit can vary so that the capabilities
and performance of each supplier is examined in terms of business and financial structure
as well as quality, safety, environmental, corporate social responsibility (CSR), sustainability
system certification, product, processes and self-assessment audits and procedures.
The challenge is that audits are usually a one day snap shot and announced.
But what do you decide if your internal criteria is to use suppliers with a Global Food Safety
Initiative (GFSI) recognised certification and your only supplier for a strategic raw material
is ISO 22000 certified? You need to know more about the credibility and history of the
individual supplier.
In general we can say that there are many well established systems in place but they do not
prevent food fraud taking place by themselves.

Random sampling
There are many different kinds of samples including pre-shipment, raw materials, product
releases and finished goods. The sampling itself is a crucial point regarding meaningful and
reliable analytical results. But who has taken the sample? In the best case scenario this has
been done by an independent party especially when a product is claimed.
Even the reason for sampling can be decisive such as in-house quality assurance, a buying
decision, during an audit, testing against a specification (product approval) and sometimes it
can even be time critical. Samples are important evidence and a key element in proving food
fraud.

Data management
A lot of data is generated during the process which has to be managed. Not all businesses
work paperless and the question is who has access to which results and needs to be informed
about it. How do you make the data available?
The aim is to set up a reporting system so that customer and supplier data can be cleansed.
All information has to be pulled together and combined to give an the overview in order to
make decisions.

Reporting
How do you generate reports and control who has access to them? What actions can be
taken resulting from this information? Do you have a company-wide overview, especially
in international companies, so that the whole portfolio and chain can be managed and
everybody has the same information? In order to achieve this, an integrated system is needed.

Storage
Do you store in-house or use an independent company? Under what conditions? If a Rapid
Alert System for Food and Feed (RASFF) notification is published during a crisis or for a claim,
fast access is necessary to start target analyses. What is needed is an innovative approach to
create an integrated solution.

intertek.pt 7
PROTECTING YOUR PRODUCTS AGAINST FOOD FRAUD

A unified solution
Implementing preventative measures significantly reduces the potential threat of criminal
activity. While there is no single solution in avoiding food fraud completely, it is important
to put preventative measures in place to decrease your risk. You have to crosslink the
single elements and integrate full data management. To create more insight and available
information, the data has to be pulled together and all involved parties along the chain have to
share their knowledge. This can even reduce costs and increase food safety and reliability.
The system has to be built on risk evaluation and scoring systems but also independency,
randomness (by statistical security) and unannounced actions.

In summary
Food fraud can be prevented by enforcing a total quality and transparency approach, e.g. the
samples taken from any supplier can be tested immediately to determine the risk against
a RASFF notification. This is an effective system to verify claims, determine the safety of
food and detect any signs of mislabelling, fraud etc. A tougher punishment is also needed to
prevent people from taking part in this criminal activity. Fraud cannot be detected alone. It is
often seen as a risk for the individual company, but by working together food fraud can be
combatted.
As an individual company you can protect your business against food fraud by preparing for
risk, reviewing your supply chain, building a plan with robust measures to make it difficult
for opportunists to breach your security measures, using a multitude of detection methods
to protect your business from risks, thinking globally and being open to share relevant
information!

Supporting You
If you would like to understand more about our Food Fraud services, contact our regional
customer service centres using the details on the back of this white paper.

intertek.pt 8
Intertek is a leading Total Quality Assurance provider to industries worldwide.
Our network of more than 1,000 laboratories and offices and over 42,000
people in more than 100 countries, delivers innovative and bespoke Assurance,
Testing, Inspection and Certification solutions for our customers’ operations and
supply chains. Intertek Total Quality Assurance expertise, delivered consistently
with precision, pace and passion, enabling our customers to power ahead safely.

FOR MORE INFORMATION

Rua Antero de Quental 221,

sala 102
4455-586 Perafita
Porto - Portugal

+ 351 707 010 049

info.portugal@intertek.com

intertek.pt

This publication is copyrighted by Intertek and may not be reproduced or transmitted in any form in whole or in part without the
prior written permission of Intertek. While due care has been taken during the preparation of this document, Intertek cannot be
held responsible for the accuracy of the information herein or for any consequence arising from it. Clients are encouraged to seek
Intertek’s current advice before acting upon any of the content.