UNIT 12 FOOD FRAUD AND ITS MITIGATION

Structure
12.0 Objectives
12.1 Introduction
12.2 Food authenticity
12.3 Food fraud
12.3.1 Different types of food fraud
12.3.2 Examples of food fraud
12.3.3 Types of food fraud
12.4 Various definitions to understand food fraud
12.4.1 Food fraud vulnerability elements
12.5 Motivations
12.5.1 Economic drivers
12.5.2 Supply and pricing
12.5.3 Economic health and level of competition
12.5.4 Financial strains
12.5.5 Culture and behaviour
12.5.6 Business strategy
12.5.7 Ethical business culture
12.5.8 Former offences
12.5.9 International corruption level
12.5.10 Victimization
12.6 VACCP and TACCP
12.6.1 VACCP
12.7 Legislation on food fraud
12.8. Mitigation strategies
12.8.1 Vulnerability assessment
12.8.2 Mitigation strategies
12.8.3 Mitigation strategy management components
12.8.4 Training and recordkeeping
12.9. PCQI
12.10. Let Us Sum Up

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12.11. Key Words
12.12. Terminal Questions
12.13 Answers to Check Your Progress Exercises
12.14 Answers to terminal questions
12.15 References/Suggested Readings

12.0 OBJECTIVES
After studying this unit, you will be able to:
 Define and classify food fraud
 Explain the food fraud vulnerability elements
 Describe the strategies used for controlling food fraud
 Narrate the laws that implemented to control food fraud

12.1 INTRODUCTION
Food is one of our basic needs and for survival every living being needs food. Humans make
food available in a processed or semi-processed form and consume it to support various
physiological processes. Food commodities have always been vulnerable to fraudulent
admixture or adulteration with cheaper inferior materials. Food fraud or adulteration is
common, and such food adulteration degrades food quality, makes it dangerous to consume,
and causes health problems in humans. Food fraud is defined as the intentional substitution,
addition, tampering, or misrepresentation of food, food ingredients, or food packaging, as
well as the making of false or misleading assertions about a product for financial advantage.
Adulteration can be defined in a variety of ways, including the mixing or substitution of
inferior substances in food, or the removal of some desirable elements from the food product.

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 Fig. 12.1Showing the pure and adulterated ghee (Source:FSSAI New Delhi)

12.2 FOOD AUTHENTICITY

Food authenticity is defined as food being authentic. Authentic food is described as a “match
between the food product characteristics and the corresponding food product claims”. In
short, food is authentic when, “food is what it says as it is”. The food regulations expands on
this definition by stating that, “food authenticity is about ensuring that food offered for sale or
sold is of nature, substance, and quality expected by the purchaser (Section 14 Food Safety
Act 1990).” Food authenticity is referred to as a state rather than an act. Therefore, no
motivation or intention has been described in literature. Hence, food authenticity is not an
intentional or unintentional act, such as food quality or food fraud, but rather is affect by both
intentional and unintentional doings.

12.3 FOOD FRAUD

Food fraud is a common type of economically motivated adulteration occurs when someone
leaves out, takes out or substitutes a valuable ingredient or part of a food.

Fig. 12.2 Showing pure and adulterated honey

Food fraud is the act of purposely altering, misrepresenting, mislabelling, substituting or
tampering with any food product at any point along the farm–to–table food supply–chain.
Fraud can occur in the raw material, in an ingredient, in the final product or in the food’s
packaging.Fraudulent and intentional substitution, dilution or addition to a raw material or
food product, or misrepresentation of the material or product for financial gain (by increasing
its apparent value or reducing its cost of production) or to cause harm to others (by malicious
contamination), is ‘Food Fraud.’

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Food fraud is the deception of consumers through intentional adulteration of food:
(a) by substituting one product for another;
(b) using unapproved enhancements or additives;
(c) misrepresenting something (eg, country of origin);
(d) misbranding or counterfeiting;
(e) stolen food shipments and/or
(f) intentional contamination with a variety of chemicals, biological agents, or other
substances harmful to private– or public–health.

12.3.1 Different types of food fraud

Fig. 12.3 Showing different types of food fraud

Four key operative criteria are referred to for distinguishing whether a case should be
considered as fraud or as non-compliance: if a case matches all four criteria, then it could be
considered a suspicion of fraud.

1. Violation of food regulations

2. Deception of customers

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 3. Economic gain
4. Intention

These criteria correspond to the rules currently in place in the Member States to report frauds:
1. Violation of food regulations
It entails a violation of one or more rules codified in the food regulation and food legislation
given by the regulatory bodies.

2. Deception of customers
This criterion entails some form of deception of the customers/consumers (example: altered
colouring or altered labels, which mystify the true quality or, in worse cases even the nature
of a product). Moreover, the deceptive element may also come in the form of a public health
risk as some real properties of the product are hidden (for example, in the case of undeclared
allergens).

3. Undue advantage
The act brings some form of direct or indirect economic advantage for the perpetrator.

4. Intention
This criterion can be verified through a number of factors which give strong grounds to
believe that certain non-compliances are not happening by chance, such as the replacement of
a high-quality ingredient with a lower quality one (if a contamination due to production
processes is possible, when an ingredient is mostly replaced with a lower quality one there is
substitution, which often implies fraudulent intent).

12.3.2 Examples of Food Fraud

Honey and maple syrup
Even though their labels represented their food as a pure product, some unscrupulous
companies have previously mixed honey or maple syrup with cheaper sweeteners such as
corn syrup, rice syrup, sugar beet syrups, or cane sugar. This lowered the cost of production,
but consumers still paid the full price of a pure honey or maple syrup product with the
additional profit going to the companies.

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Juice: When manufacturers sell a mixture of citric acid, sweetener, and water as “100%”
lemon juice or mix grape juice into their “100%” pomegranate juice, the consumer harm is
mostly economic. However, when a company mix expired, contaminated juice stored in dirty
conditions with fresh juice in order to hide the low quality of the expired filthy juice, the
resulting juice can possibly harm the person drinking it.

Spices: One type of spice fraud occurs when an expensive spice (such as saffron) is bulked
up with other non-spice plant material (such as plant stems). Another type of fraud is using
dyes to give spices a certain color, especially when the color strongly impacts the perception
of quality. Lead-based dyes and other industrial dyes that can cause adverse health problems
such as cancer have been found in spices such as chili powder, turmeric and cumin.

Fig: 12.4 Showing different types of spices – Visible quality

12.3.3 Types of Food Fraud

 Dilution
 Substitution
 Concealment
 Mislabelling
 Unapproved enhancement
 Counterfeiting
 Grey market production/theft/diversion

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Table: 12.1 Terminologies related to food fraud
Dilution The process of mixing a liquid ingredient with high value with a liquid of
lower value
Substitution The process of replacing an ingredient or part of the product of high value
with another ingredient or part of the product of lower value
Concealment The process of hiding the low quality of food ingredients or product
Unapproved The process of adding unknown and undeclared materials to food products in
enhancements order to enhance their quality attributes
Mislabelling The process of placing false claims on packaging for economic gain
Counterfeiting The process of copying the brand name, packaging concept, recipe, processing
method, etc. of food products for economic gain

Check Your Progress Exercise 1

Note: a) Use the space below for your answer.

b) Compare your answers with those given at the end of the unit.

1) When do we say that food is adulterated under the PFA Act?Tick mark (√ ) the right
choice.
a) If it is obtained from a diseased animal
b) If spices are sold without their essence
c) If any ingredient is injurious to health
d) All of the mentioned

12.4 VARIOUS DEFINITIONS TO UNDERSTAND FOOD FRAUD

 Food fraud is a collective term used to encompasses the deliberate and intentional
substitution, addition, tampering or misrepresentation of food, food ingredients or
food packaging: of false or misleading statements made about a product, for economic
gain
 Committed when food is deliberately placed on the market for financial gain, with the
intent of deception of consumers. Referred to in the USA and occasionally elsewhere
as economically motivated adulteration (EMA). Two of the main types include:
trading of food which is unfit for consumption or harmful, or deliberately
misdescribing or mislabelling food. The latter can include false statements regarding
geographical origin, ingredients, or substitution with lower value (i.e. myrtle instead

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 of oregano), or sometimes even dangerous contents not intended for human
consumption (i.e. industrial dyes). The terms food fraud and food adulteration can be
used to mean the same thing, when adulteration is intentional.
 The intentional misrepresentation of fact by one person solely, or acting on behalf of
an organization, in order to encourage another individual erroneously to part with
something of intrinsic value.
 Deliberately placing food on the market, for financial gain, with the intention of
deceiving the consumer. Although there are many kinds of food fraud, the two main
types are:
 Sale of food which is unfit and potentially harmful, such as: recycling of animal by-
products back into the food chain, packing and selling of beef and poultry with an
unknown origin, knowingly selling goods which are past their ‘use by’ date.
 Deliberate misdescription of food such as:products substituted with a cheaper
alternative, for example farmed salmon sold as wild, and Basmati rice adulterated
with cheaper varieties, making false statements about the source of ingredients, i.e.,
their geographic, plant or animal origin. Food fraud may also involve the sale of meat
from animals that have been stolen and/ or illegally slaughtered, as well as wild game
animals like deer that may have been poached.

12.4.1 Food Fraud Vulnerability Elements

The three elements’ opportunities, motivations and control measures can be subdivided into
six groups.
These six groups comprise

(1) technical opportunities,

(2) opportunities in time and place;
(3) economic drivers,
(4) culture and behaviour,
(5) technical control measures and
(6) managerial control measures.

Each group is composed of several fraud factors and will be described and explained in the
following paragraphs (Fig. 2). Research has established that people have the psychological

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tendency to place threats of crime outside the social group or the organization they belong to
(‘the alien conspiracy’). However, offenders are employees in most cases in which companies
are victimized by fraud. Therefore, food fraud vulnerability threats from both the external and
the internal environment of a business should be considered, which means that one needs to
be receptive to external threats as well as to the dark side of the own organization.

Table: 12.2 Element of food fraud vulnerability

Check Your Progress Exercise 2

Note: a) Use the space below for your answer.

b) Compare your answers with those given at the end of the unit.

1) How many main elements of food fraud? Tick mark (√ ) the right choice.
a) 1
b) 5
c) 3
d) 7

12.5 MOTIVATIONS
12.5.1 Economic Drivers

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Supply and pricing, product attributes resulting in added value, differences in pricing due to
regulatory diversity in countries, economic health of businesses, level of competition and
financial strains imposed on suppliers are economic aspects that affect fraud vulnerability.

12.5.2 Supply and Pricing

Since food fraud always involves the substitution of a higher value product with one or more
of less expensive or lower quality alternative(s), a high value per kilogram product will add
temptation to fraudsters. When gaps exist between physical product availability and market
demand and prices shift due to regional or global supply shortages fraud vulnerability will
also increase. Shortages may not only lead to increase of pricing but can also lead to a failure
of fulfilling contracts with customers with fraud becoming a last resort for economic
survival.Value adding product attributes. Attributes adding value to products involve
products from defined provenance or production systems (e.g., organic), or particular
processing (e.g., artisanal products). Food quality labels, such as PDO (protected designation
of origin), PGI (protected geographical indication) and TSG (traditional specialties
guaranteed) have been introduced in the EU in order to protect producers of food with special
qualities. Since they retail at higher prices than their counterparts, these special attributes may
also increase fraud vulnerability. Moreover, in some cases particular constituents add value to
products, since they are used in payment schemes. For instance, payment in the milk supply
chain is based on the protein and fat contents of milk. This may invite certain people to
artificially increase the (apparent) content of these payment markers and thus increase fraud
vulnerability.

12.5.3 Economic Health and Level of Competition

Research shows that economic aspects influence the vulnerability to fraud in general.
Depending on both the person and the situation, economic motivation can take two very
different forms: profit maximization or loss minimization, in other words the drive for more
material gain versus the fear of losing what was already gained. The motivation for
committing white-collar crime greed or need strongly depends on the situation: e.g.,
situations in which criminal opportunities that are too strong to resist and situations in which
law breaking is perceived as unavoidable for economic survival. With regard to the latter, the
economic health of a business and level of competition are important factors in fraud
vulnerability. Under economically severe weather conditions, a company may seek for
manners to cut costs and become creative in regard to meeting product specifications.

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Examples of ways to cut costs are the removal of the traceability system, elimination of
controls and buying ingredients or products from cheaper or unknown suppliers. This will all
add to the vulnerability to fraud.

12.5.4 Financial Strains

Powerful customers may also impose considerable financial strains on their suppliers. At
individual company scale, the demand may exceed the supply of the supplier at a certain
stage. For instance, there is limited availability of organic eggs on the market in the periods
before Easter and Christmas but a customer may demand large volumes of organic eggs and
has put severe punishments in place if demands are not met. If the supplier is fairly dependent
on the customer, the supplier may feel the need to fill the gap with alternative products to
meet the customer's demand for its own economic survival.

12.5.5 Culture and Behaviour

The business strategy as well as the ethical business culture of organizations, former
offences, corruption levels in countries in which organizations operate and victimization are
factors that influence cultural and behavioural aspects of fraud vulnerability.

12.5.6 Business Strategy

Individual potential fraudsters may be influenced by the business strategy of their
organization, as has been shown for other corporate crimes (Huisman, 2016). Employees may
perceive business strategies that involve hard-to reach (short term) financial goals that are
being put forward by their organizations as a threat. For the sake of saving themselves from
being fired, the employees may decide to reside to unethical behaviour, especially if there are
no specific requirements given in regard to how the goals should be achieved.

12.5.7 Ethical Business Culture

Companies with a stronger ethical corporate environment have employees who are more
willing and are more strongly committed to adhere to the organizations’ rules and regulations.
This in turn limits the risk of unethical behaviour. On the contrary, a culture characterized by
demotivation, mistrust and dissatisfaction can be a breeding ground for unethical behaviour.
Furthermore, unethical business cultures generate processes of the normalization of fraud,
which again reinforces longer-term fraudulent activity.

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12.5.8 Former Offences
Criminal offences that have occurred previously have a higher risk of reoccurring. The
history of prior violations of the law indicates firm engagement in a pattern of wrongdoing,
such as illegal activities, which can result in repeated violations. Event history analysis on
illegal corporate behaviour has elucidated that a history of prior violations implies a 19 times
higher likelihood of illicit behaviour in the future. The relationship between prior violations
and illegal behaviour appears to indicate that some companies have a culture that reinforces
illegal activities. Moreover, companies which are in certain industries rife with wrong-doing
behaviours are more likely to commit crime or are being influenced. Therefore, former
criminal offences of organizations and individuals potentially increase the vulnerability to
fraud.

12.5.9 International Corruption Level

The risk of food fraud depends not only on company practices, but also on general global
practices. A factor, which can influence food fraud risk is the corruption level in a given
country; which is affected by the geopolitical situation (Food Chemical Codex, 2014). In
countries with a high level of corruption, firms have been shown to choose more often illegal
or immoral means to gain profits.

12.5.10 Victimization
Although companies may not be directly involved in food fraud, they may be victimized by
activities of others in the chain or sector of industry. Those victimized are more likely to
become (in)directly involved in future frauds again. Repeat victimization is often the result of
factors that were already present and which were not mitigated after the first victimization.
Frequently it is impossible to change these factors by the victimized company since they are
out of its span of control. If it has become a certain culture to commit fraud in a particular
supply chain network, law-abiding businesses in the same chain are affected as well. When
major competitors of a company perform well, in part as a result of illegal methods, it
becomes difficult for other companies to choose only legal action. In some cases these
businesses are affected to the extent that they have to choose between ‘being driven out of
business’ or ‘swim with the tide’ to survive the severe and unfair competition. This will
influence the odds of repeated victimization and thus affect fraud vulnerability.

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Check Your Progress Exercise 3

Note: a) Use the space below for your answer.

b) Compare your answers with those given at the end of the unit.

1) Which of the following is not considered as motivation in case of Food Fraud?Tick mark
(√ ) the right choice.
a) culture and behaviour
b) victimization
c) financial strains
d) testing
Ans -d

12.6 VACCP AND TACCP

TACCP stands for Threat Analysis and Critical Control Points. Threat Assessment and
Critical Control Point (TACCP) helps food producers identify weak points in their supply
chain and processing activities that maybe open to intentional and malicious attack. The
TACCP protocol focuses on tampering, intentional adulteration of food and food defence.

Fig 12.5 Different parameters of TACCP

TACCP aims to
 Reduce the likelihood and consequences of a deliberate attack
 Protect organizational reputation

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  Reassure customers and the public that proportionate steps are in place to protect food
 Demonstrate that reasonable precautions are taken and due diligence is exercised in
protecting food

TYPES OF THREATS

 Economically Motivated Adulteration (EMA)

 Malicious Contamination
 Extortion
 Espionage
 Counterfeiting
 Cyber crime

TACCP process
 Assess new information
 Identify and assess threats to organization
 Identify and assess threats to operation
 Select product
 Identify and assess threats to product
 Devise flow chart of product supply chain
 Identify key staff and vulnerability chain
 Consider impacts of threats identified
 Identify which supply points are more critical
 Determine if control procedures would detect the threat
 Likelihood Vs Impact / Priority
 Identify who could carry out
 Decide and implement necessary controls
 Review and revise
 Monitor horizon scans and emerging risks

12.6.1 VACCP
Vulnerability Assessment and Critical Control Point (VACCP) focuses on food fraud as well
but widens the scope to include the systematic prevention of any potential adulteration of
food, whether intentional or not, by identifying the vulnerable points in the supply chain.

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VACCP is especially concerned with economically motivated adulteration. Examples of
supply chain risks include product substitutions, unapproved product enhancements,
counterfeiting and stolen goods

Fig 12.6 Different parameters of VACCP

Food Safety Management

system

Food Safety Food Defence Food fraud

HACCP TACCP VACCP

Hazards Threats Vulnerabilites

Fig: 12.7 Showing the food safety management system

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 Fig: 12.8 Various factors of food safety

Check Your Progress Exercise 4

Note: a) Use the space below for your answer.

b) Compare your answers with those given at the end of the unit.

1) What does TACCP focus on?Tick mark (√ ) the right choice.

a) Controlling the manufacture of goods
b) Accidental contamination of sites
c) Hazards caused by an employees’ lack of training
d) Identifying vulnerabilities, assessing threats and implementing controls
Ans- d

12.7 LEGISLATION ON FOOD FRAUD IN THE EU

Lack of consistent definitions for food fraud in the EU is a barrier to creating legislation that
influences the creation of a collective approach in addressing food fraud (Kowalska, Soon, &
Manning, 2018). Therefore, food fraud is not addressed in any single EU law but is indirectly
addressed through the violation of food law (Spink, Hegarty, Fortin, Elliott, & Moyer, 2019).
This creates an obstacle in combatting food fraud. Depending on the type of fraud and the
type of product that is involved in the fraudulent act, different legislation relates to food
fraud, including: • Regulation (EC) No 178/2002 on general food law on imports and exports,
traceability, labeling, and product recalls. • Regulation (EC) No 1924/2006 on nutrition and
health claims • Regulation (EU) No 1169/2011 on the provision of food information to and
the ban on misleading advertising and labelling practices. • Regulation (EU) 2017/625 the

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official controls regulation has been a step in the right direction considering food fraud
legislation. This legislation empowers national authorities and the European Commission by
giving them the necessary powers to ensure effective enforcement of regulatory requirements
concerning food and feed law, animal health and welfare, and plant health and plant
protection products (EC, 2019). Also, this legislation holds more focus on the authenticity
and integrity of the agri-food chain, then previous legislation such as (EC) No 172/2002 (EC,
2017).
Another challenge in the creation of food fraud legislation and regulations is that food fraud
acts are committed outside of authorized or legitimate supply chains. Therefore, to help
defend against food fraud, the EU has established the EU Food Fraud Network, which
empowers member states to exchange information and to collaborate voluntarily in matters of
food fraud (EC, 2020). Furthermore, member states have individually set up regulatory
bodies to defend against food fraud. An example of this is the NFCU established in the UK in
2015 in response to the 2013 horse meat scandal as a law enforcement arm of the Food
Standards Agency (FSA) focusing on food crime.

12.8 MITIGATION STRATEGIES

In addition to understanding food fraud, this review aimed to review prevention and
mitigation countermeasures used to protect the food supply chain from food fraud. Prevention
and mitigation both aim to control food fraud. Mitigation assumes food fraud events will
frequently occur and focus on trying to mitigate or reduce the negative consequence.
Prevention assumes that the root cause of the event could be eliminated or at least
significantly reduced in the likelihood of occurrence. Food fraud prevention aims at reducing
food fraud before it occurs. Achieving food fraud prevention and mitigation depends on
identifying, reducing or eliminating vulnerability. A vulnerability is a weakness or flaw that
creates opportunities; or susceptibility to the system for food fraud. This differs from risk
which is the potential for an unwanted outcome resulting from an incident, event, occurrence,
as determined by its likelihood and the associated consequence.

12.8.1 Vulnerability assessment

This is the identification of vulnerabilities and actionable process steps for each type of food
manufactured, processed, packed or held at the food facility. For each point, step, or
procedure in the facility’s process, these elements must be evaluated:

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  The severity and scale of the potential impact on public health. This would include
such considerations as the volume of product, the number of servings, the number of
exposures, how fast the food moves through the distribution system, potential agents
of concern and the infectious/lethal dose of each; and the possible number of illnesses
and deaths.
 The degree of physical access to the product. Things to be considered would include
the presence of such physical barriers as gates, railings, doors, lids, seals and shields.
 The ability to successfully contaminate the product.

12.8.2 Mitigation strategies

These should be identified and implemented at each actionable process step to provide
assurances that vulnerabilities will be minimized or prevented. The mitigation strategies must
be tailored to the facility and its procedures.

 The final rule removes the distinction between “broad” and “focused” mitigation
strategies. The original proposal only required “focused” mitigation strategies because
“broad” mitigation strategies, such as a fence around the entire facility, did not protect
specific points from being attacked by an insider.
 The final rule recognizes that a mitigation strategy, applied in a directed and
appropriate way to protect the actionable process step from an insider attack, would
sufficiently minimize the risk of intentional adulteration.

12.8.3 Mitigation strategy management components

Steps must be taken to ensure the proper implementation of each mitigation strategy. In each
of these areas of food defense, the facilities are given more flexibility in the final rule to
establish the actions most appropriate to their operation and product.

 Monitoring: Establishing and implementing procedures, including the frequency with

which they are to be performed, for monitoring the mitigation strategies.
 Corrective actions: The response if mitigation strategies are not properly
implemented.
 Verification: Verification activities would ensure that monitoring is being conducted
and appropriate decisions about corrective actions are being made.

12.8.4 Training and recordkeeping

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Facilities must ensure that personnel assigned to the vulnerable areas receive appropriate
training; facilities must maintain records for food defense monitoring, corrective actions, and
verification activities.

The Rapid Alert System for Food and Feed (RASFF) portal – RASFF is a free resource
database which is open to anyone, maintained by the European Commission (EC) under
regulation EC/178/2002. Under this legislation, member states are legally required to report
information concerning direct and indirect risks to human health from food or feed (European
Food Safety Authority (EFSA), 2010). Reports on RASFF include the type and date of
notification, the reason for notification, the hazard(s), the nature of the product involved, the
country of notification, and the country of origin. Although this is a database used to record
and food safety incidents, it has been used as a horizon scanning tool in multiple academic
publications.

HorizonScan– HorizonScan is a privatized subscription-based system operated by the Food

and Environment Research Agency (Fera) in the UK. It is a popular tool used by the food
industry throughout the EU. HorizonScan monitors the safety and integrity issues of food
commodities globally by collecting data from over 100 sources daily (FERA, 2020).
HorizonScan risk assesses and analyses trends in reports to identify potential food safety
issues before they escalate to more significant threats within the food supply chain (FERA,
2020).

Decernis – The Decernis Food Fraud database (formerly The US Pharmacopeial (USP) Food
Fraud Database) is available through subscription. This database focuses solely on food fraud
and provides records of potential food fraud incidents from government, media, and academic
sources. Decernis provides a list of potential adulterants, as well as information on testing
techniques for each product in the database.

Food Industry Intelligence Network (Fiin) – Fiin was created in 2015 by industry leaders.
Its development was the result of recommendations made in the Elliott Review (DEFRA,
2014). Fiin started with 21 founding member which has since grown to 46 members (as of
2019); these members include retailers, manufacturers, and foodservice companies (DEFRA,
2020; Campden BRI, 2019). Campden BRI is responsible for creating a database to collect
anonymized industry data from Fiin members on food authenticity testing. This data is

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analyzed to produce quarterly reports for the Fiin members and is the only such scheme that
exists globally.

The Food Protection and Defense Institute’s World Factbook of Food- The World
Factbook of Food was created by the Food Protection and Defense Institute (FPDI). For each
product in the World Factbook of Food, information is provided on the production, trade,
seasonality, processing steps, supply chain structure, food safety concerns, and past food
fraud incidents (FPDI, 2017). The database was designed to serve as a central reference
database for food and is available on a subscription basis.

Check Your Progress Exercise 5

Note: a) Use the space below for your answer.

b) Compare your answers with those given at the end of the unit.

1) The action of reducing the severity, seriousness, or painfulness of something, is termed

as? Tick mark (√ ) the right choice.
a) diminution
b) deadening
c) mitigation
d) None

12.9 PCQI
The U.S. Food Safety Modernization Act (FSMA) mandates every food processing facility to
have a trained resource person or “Preventive Controls Qualified Individual” (PCQI), who
has completed an FDA recognized curriculum course such as the one developed by the Food
Safety Preventive Controls Alliance (FSPCA), that is recognized by the FDA. FDA FSMA
rule applies to all facilities engaged in manufacturing, processing, packing, or holding food
for consumption in the United States.

12.10 Let Us Sum Up

Food authenticity is a state of being. Food authentication testing is a process to evaluate that
state of being. Food fraud is the act that creates the problem; it is a collective term used to
encompass the deliberate and intentional substitution, addition, tampering, or
misrepresentation of food, food ingredients, or food packaging; or false or misleading
statements made about a product, for economic gain. Food fraud prevention is the process to

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reduce the chance of food fraud occurring; food fraud mitigation is the process to reduce the
impact of an incident after it occurs; and, finally, food authenticity testing is a process to
support the food fraud prevention strategy.

12.11 KEY WORDS

 Economically motivated adulteration (EMA): The deliberate adulteration of food,
motivated by greed or a political agenda. In case of economically motivated adulteration
(EMA), aim is not to harm people but to inflate profits by fraudulent means
 Food defense (food defense) is a term that has come to be defined as effort to prevent acts of
adulteration that are intended to cause harm to a food business or to consumers, such as acts
of terrorism or attempted extortion.
 Food crimes: food crime as serious fraud and related criminality in food supply chains. This
definition also includes activity impacting on drink and animal feed. It can be seriously
harmful to consumers, food businesses and the wider food industry.
 Vulnerability: It is a term of art and a basis for assessment methods in several contexts,
including climate impact analysis, disaster management, and food security analysis.
‘Vulnerability’ is used because food fraud ‘risks’ do not exactly fit with the accepted
definition of risk as something that has occurred frequently, will occur again and for which
there is enough data to make quantitative assessments.
 Direct Food Safety risks: consumer is put at immediate risk eg addition of melamine to milk
powder results in acutely toxic exposure; hiding of substances resulting in undeclared
allergens
 Indirect Food Safety risks: consumer is put at risk through long-term exposure eg high
levels of heavy metals in food supplements causing harm or lack of benefit- over longer
period of time
 Technical food fraud risk: there is no direct or indirect food safety risk, this indicates that
material traceability may have been compromised and companies are no longer able to
guarantee the safety of their food products
 Food security as defined by when all people at all times have access to sufficient, safe,
nutritious food to maintain a healthy and active life
 TACCP: Threat Assessment Critical Control Point, TACCP helpful for prevention of
malicious threats to food
 Intentional Adulteration: Although food fraud activities often involve the intentional
adulteration of food with unauthorised substances, within the food safety industry, Intentional
Adulteration has recently been given a more specific meaning. And it is not related to food

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 fraud at all. It is related to food defense, and more specifically to activities intended to cause
wide scale harm to consumers.
 Horizon scanning is a term that has been co-opted to the language of food fraud. Horizon
scanning is the act of looking for and analysing threats and opportunities that will emerge in
the medium to long term. Within the food industry, horizon scanning refers to the act of
collecting information about current trends in food production and predicted incidences that
could increase the likelihood of food fraud for a particular food material.

12.12 TERMINAL QUESTIONS

1. What is food fraud?
2. What is food adulteration?
3. What are different types of food frauds and adulterations?
4. Why people do food fraud and adulteration?
5. What are different means to control food frauds?
6. What are major examples of food frauds?
7. What are food fraud and adulteration mitigation strategies?

12.13 ANSWERS TO CHECK YOUR PROGRESS EXERCISES

Check Your Progress Exercise 1
1) d
Check Your Progress Exercise 2
1) c
Check Your Progress Exercise 3
1) d
Check Your Progress Exercise 4
1) d
Check Your Progress Exercise 5
1) c

12.14 ANSWERS TO TERMINAL QUESTIONS

1) any deliberate action of businesses or individuals to deceive others in regards to the
integrity of food to gain undue advantage. Types of food fraud include but not limited to:
adulteration, substitution, dilution, tampering, simulation, counterfeiting, and
misrepresentation.

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2) Food Adulteration can be defined as the practice of adulterating food or contamination of
food materials by adding a few substances, which are collectively called adulterants.
Adulterants are the substance or poor-quality products added to food items for economic and
technical benefits. Addition of these adulterants reduces the value of nutrients in food and
also contaminates the food, which is not fit for consumption. These adulterants can be
available in all food products which we consume daily, including dairy products, cereals,
pulses, grains, meat, vegetables, fruits, oils, beverages, etc.

3)Type of Food Fraud Description Example

A component of the
Adulteration finished product is Melamine in milk
fraudulent

Legitimate product is made

Overrun in excess of production Under-reporting of production
agreements

Legitimate product is stolen Stolen products are co-

Theft and passed off as mingled with legitimate
legitimately procured products

The sale of distribution of Relief food redirected to

Diversion legitimate products outside markets where aid is not
of the intended markets required

Illegitimated product is
‘Knock-offs’ of popular foods
designed to look like but
Simulation not produced with the same
not exactly copy the
food safety assurances
legitimate product

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3)Type of Food Fraud Description Example

Intellectual property rights

infringement, which could
Copies of popular foods not
include all aspects of the
Counterfeiting produced with same food
fraudulent product and
safety assurances
packaging being fully
replicated

Legitimate product and

Changed expiry information,
Tampering packaging are used in a
product up-labelling etc.
fraudulent way

4) Both can be economically driven, however, the motivation behind food fraud is monetary
gain, whereas the intent behind food defence is to cause harm through any form of
intentional, malicious adulteration or economic disruption, and is typically ideologically
motivated. Areas impacted by food defence programs include cyberattacks and sabotage.

5) Food fraud is characterized by deceit and often perpetrated by criminal groups which are
well prepared to avoid detection. This makes it difficult to prevent, but there is growing
awareness that greater action needs to be taken.
As with any major challenge in the food industry, true success can only come from joint
action on the part of industry regulators and individual businesses. However, there are a
number of ways in which your business can protect itself from falling victim to food fraud.

Risk assessment. This action comes before any agreements have been made to purchase
ingredients. Your business should carry out an assessment of the ingredient market and any
history of fraud, the state and composition of the products and the price of the products in
relation to standard industry pricing.
Authenticity testing. Regular testing of ingredients at multiple stages of the supply chain are
vital. Tests should be carried out in comparison to reference materials in food fraud databases
recognized under global standards like ISO 17025.

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Education. Everyone involved in the procurement process and other key points of the supply
chain should be fully trained to spot instances of food fraud or potential red flags. For
example, the University of Minnesota’s Food Protection and Defense Institute offers such
courses.
Technology. With food supply chains growing longer and more complex, the need for a
technology stack that keeps you in control has never been greater. Solutions like modern food
and beverage enterprise resource planning (ERP) harness the power of real-time data
collection and cloud computing to generate one source of data truth. This gives you full
visibility over your supply chains and true end-to-end traceability, helping you avoid food
fraud and root out any instances that do occur before they can cause harm.

6) 2020 - ketchup produced using unsafe, fake illegal products, with incorrect labelling and
without the correct licence in Punjab, India
2019 - traditional pig breeds used to produce Parma and San Daniele hams were crossed with
breeds that grow faster. The resulting higher water content did not meet the requirements of
the Protected Designation of Origin (PDO)
2018 - imported honey in Canada adulterated with foreign sugars
2017 - aluminium foil used in place of edible silver leaf on sweetmeats in India
2013 - food containing horsemeat were mislabelled as beef
2012 - vodka laced with methanol in Czech Republic
2008 - milk and infant formula adulterated with melamine
2007 - pufferfish mislabelled as monkfish in California and Hawaii, USA
2003 - insecticide mixed into group beef by a supermarket employee in Michigan, USA15
1985 - diethylene glycol added to wine in Australia to add desired sweetness.

7) Mitigation strategies should be implemented effectively to prevent or minimise

vulnerabilities to food fraud. They must be specific to each company, manufacturing site and
product.

To ensure the correct implementation of each mitigation strategy, companies should:

monitor procedures and methods

document the corrective actions to be taken if mitigation strategies are ineffective or not
implemented correctly

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verify that monitoring is being conducted and corrective actions are being followed when
appropriate.
Prevention of food fraud must be cross-functional (not just a food safety function issue) and
implemented across businesses and supply chains22,24. Food fraud training of all
departments, including Procurement and Operations is important to ensure:

 procuring supplies of products and ingredients from reputable, approved suppliers

 approval of source suppliers (site where the products are actually made), not just
brokers and agents
 raw ingredient/finished product specifications are understood and include a full
description of the product (e.g., botanical species, variety (such as Cinnamomum
verum vs. Cinnammum cassia) and all ingredients including key attributes
 procedures in place for products that do not meet the approved specification or are not
legally compliant
 use of a recognised statistical sampling programme for sampling and inspection on
receipt, which is appropriate for the raw ingredient and consistently applied
 the testing laboratory is appropriately accredited for the analysis required
 request Certificates of Analysis for relevant criteria, such as active ingredient content
and method used e.g.,piperine for pepper
 known harvest cycle as this can influence availability of products and quality
 verification of authenticity of ingredients used in food manufacturing
 development, implementation, and effective testing programmes for materials
identified as being highly vulnerable to food fraud
 maintenance of equipment, such as weighing scales and ensure an effective
calibration programme is in place
 reviews of costs and benefits of conducting on-site audits, especially for high-risk
suppliers
 request suppliers of vulnerable products to conduct a mass balance exercise (typically
as part of the traceability programme) to prove ability to account for all quantities of
raw ingredients, products and packaging
 review and implementation of anti-counterfeit technologies where appropriate23
 follow correct importation rules; good manufacturing practice (GMP) and industry
standards are applied

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  knowledge of food laws where the products and ingredients are manufactured and
sold, to avoid unintended non-compliance to legal requirements

12.14 REFERENCES/SUGGESTED READINGS

 Food Science- B.Srilaxmi
 Food Adulteration and Food Fraud- Jonathan Rees
 Food Adulteration and Its Detection- Jesse P. Battershall
 Detection of the Common Food Adulterants- Edwin M. Bruce

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