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Food fraud 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”. This widely adopted definition includes all types of fraud (from adulterant-substances to counterfeits and stolen goods), and all types of products (from raw materials to packaged finished goods).

What is Food Fraud?

Food fraud is one of the four categories of the food risk matrix including food safety, which is based on unintentional or environmental contamination that can cause harm; food defense, which is based on is an intentional act with intentional harm effects; and food quality, which may also be affected by profit-driven behavior but without intention to cause harm. Overarching these four categories is food security, which deals with individuals having access to enough food for an active, healthy life. Food protection is the umbrella term encompassing both food defense and food safety.

Figure 1: The Food Risk Matrix (Spink & Moyer, 2011).

Oversight and Regulations


 * Global Food Safety Initiative (GFSI) : GFSI is a consortium of most of the world’s food companies created to harmonize food safety standards and certification; this has become a de facto requirement to doing business. GFSI was established in January 2014. In their initial Food Fraud Position Paper, it was stated that Food Fraud (what? monitoring) would be a requirement for GFSI certification. Compliance: GFSI compliance requirements were enacted in October 2016 and a formal requirement one year later in October 2017. These are: (1) Conduct a Food Fraud Vulnerability Assessment, and (2) Implement a Food Fraud Prevention Strategy.


 * Safe Secure and Affordable Food For Everyone (SSAFE) – Food Fraud Vulnerability Assessment (FFVA) : SSAFE is a global non-profit membership organization incorporated in 2006 to help integrate food safety, animal health and plant health across food supply chains to improve public health and wellbeing. Many of the GFSI Board of Directors are on the SSAFE Board. GFSI has endorsed the SSAFE FFVA.
 * US Food Safety Modernization Act (FSMA) : FMSA was passed in 2011 and the regulations were defined in “final rules” in 2015-2016. Food Fraud is covered in the “Preventive Controls” rule (FSMA-PC). The compliance rules are in the Preventive Controls for Human Food Qualified Individual training (PCHF-QI).
 * US Food, Drug & Cosmetics Act (FDCA) : Addressing all types of Food Fraud is already a regulatory requirement such as in the FDCA “Adulterated Foods” and “Misbranded Foods” sections. Also, other related commercial laws apply including smuggling, tampering, counterfeiting, and stolen goods.
 * Sarbanes-Oxley (SOX) : Food Fraud is a requirement for SOX compliance – for the company and the auditors -- since product fraud is a “material fact” that could impact the financial condition of the operations.

Categorization

Generally, the full range of food fraud includes adulterant-substances (including dilution, substitution, and concealment), unapproved enhancements, mislabeling, grey market production/ theft/diversion, and counterfeiting. The critical difference between the various types of food fraud (see Table 1 - Food Fraud Types, Definitions, and Examples) compared to other three food-related issues centers on the fraudster’s motivation, which is purely economic or financial in nature. The result or impact of food fraud is public health vulnerability or harm. Whether or not a public health incident ensues, the adulteration or misbranding creates a variable, and potential, for harm. In part, the risk is because fraudsters often use unconventional chemicals that are not tested for, and adulterant-substances are not listed on the label. For example, in 2007 fraudsters added melamine to milk to boost the apparent protein content. There is no legitimate reason for melamine to be in a food product in any appreciable levels – although minute traces may be found since melamine is a plasticizer used to help make plastic packages flexible. At the time of the incident, the traditional authenticity or contaminant tests for food did not detect melamine.

Notes: (1) GFSI – Global Food Safety Initiative (2) SSAFE – Safe Secure and Affordable Food For Everyone (3) GFSI FFTT – Global Food Safety Initiative: Food Fraud Think Tank (4) Gray Market -- a market employing irregular but not illegal methods; Theft -- something stolen; Diversion/ Parallel Trade -- the act or an instance of diverting straying from a course, activity, or use.

Table 1: Food Fraud Types, Definitions, and Examples (adapted from Spink & Moyer, 2011)

Closing

The top ten foods most commonly listed as adulterated or mislabeled are vanilla extract, maple syrup, wine, apple juice, coffee, orange juice, saffron, honey, milk, and olive oil. Manufacturers along their stakeholders, governments, and academia are aggressively addressing this issue, which has become an international problem, with the cost to the industry is estimated at $10-15 billion each year, according to the U.S. Pharmacopeial Convention (USP).

Additional Resources


 * Elliott review into the integrity and assurance of food supply networks – final report, Secretaries of State for Health and the Department for Environment, Food and Rural Affairs (Defra), July, 2014, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/350726/elliot-review-final-report-july2014.pdf.


 * European Parliament. (2014). Report – on the food crisis, fraud in the food chain and the control there of, Rapporteur (Chair): Esther de Lange, Committee on the Environment, Public Health and Food Safety, (2013/2091(INI), October 10, 2013.


 * Everstine, K., Spink, J., & Kennedy, S. (2013). Analysis of Food Fraud and Economically Motivated Adulteration incidents. Journal of Food Protection, 4, p. 560–735.


 * US Congressional Research Service (CRS) – Food Fraud and Economically Motivated Adulteration of Food. Accessed January 8, 2018, http://foodfraud.msu.edu/wp-content/uploads/2014/01/CRS-Food-Fraud-and-EMA-2014-R43358.pdf.

References