Steps to Prevent Food Fraud for Manufacturers

When I (Brian) was a kid, I remember eating dyed pistachios that turned my fingers pink. While the color was amusing to me then, it turned out that red food coloring had been used by the producer in Iran to cover stains, blotches, and mottled markings that occurred during harvesting and drying. I also remember news of cheap types of fish being substituted for or misbranded as the more expensive orange roughy or mahi mahi, misleading consumers to pay more for a lesser product. Each of these was considered food fraud and, unfortunately, the issue has not gone away.

In fact, due to increased oversight and detection tools, food fraud seems to be happening more than ever and is likely more prevalent in the supply chain than is widely known. As we can see from the examples above, it is not a new problem either; the practice of adulterating food for economically motivated reasons has been going on for years.

Estimated to cost the industry $30-40 billion annually, food fraud can take place through various means. The most common of these are adulteration by substitution, omission, dilution, falsification, deception in the production method or its origin, intentional mislabeling, or masking a defect or contamination.

In addition to the industry, brands, and products that can be impacted by fraudulent ingredients, end consumers are also harmed by food fraud. One example that resulted in a food safety issue is the wheat gluten that was contaminated with melamine to inflate its protein content measures and imported from China in 2007. When used as an ingredient in pet foods, it sickened and killed hundreds of cats and dogs by causing kidney failure in those animals.

Another instance of food fraud that may have caused illness occurred in 2015, when it was speculated that suppliers added cheaper ground up peanut shells and almond husks to ground cumin, a premium quality spice. Meant to “bulk up” the product and make it heavier to increase the supplier’s margins, the obvious concern was ingestion by consumers with peanut or tree nut (almond) allergies.

Food Fraud During a Pandemic

The current COVID-19 pandemic has likely further incentivized criminals to commit food fraud. In some countries, stay-at-home measures and employee illness have increased the number of employees absent from their jobs. One example was the number of positive virus cases in meatpacking plants here in the U.S., which has led to a reduction in the number of active operators in those plants, with the consequence being a decrease in production. In some cases, this decrease has led to a shortage of raw materials and consumer-ready products, creating a domino effect in the next links in the food supply chain. This shortage and others around the world are then sometimes replaced by fraudulent ingredients and products that don’t meet client and consumer expectations.

Dependence on materials imported from countries with food manufacturing workers impacted by the pandemic has also put the continuity of the supply chain at risk. International trade has been hindered due to the lack of appropriate logistics, with closed borders and a decrease in the availability of transportation preventing materials from arriving on time. Each of these has created an opportunity for fraudulent activity.

Further, because the economy in most countries has been impacted and consumers have lost some of their purchasing power, people are looking to buy products at the lowest possible cost. As a result, they may be more interested in a product’s price than the brand they are used to or its quality, thus increasing vulnerability in the products they are purchasing.

In each of these scenarios, fraudsters may be tempted to obtain economic gain through the intentional adulteration of the food. They may choose to send their clients lower quality materials, or they may replace, dilute, or modify, without declaration, certain ingredients or products, just to meet their customer’s order. They may also be taking advantage of the fact that clients have fewer personnel to supervise the reception and oversight of those materials due to the pandemic.

Assess, Implement, and Review

So, what can be done to minimize food fraud? Foremost, FDA’s Food Safety Modernization Act and Global Food Safety Initiative (GFSI) Benchmarking Requirements require food manufacturing facilities to develop and document a food fraud vulnerability assessment and mitigation plan.