fraud, gaps and loopholes€¦ · consumers in good faith and in accordance with honest market...
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www.eurofins.de
Fraud, gaps and loopholes:Non-analytical and analytical tools need to be
combined for knowing your supply chain
Non-analytical and analytical tools need to be combined for knowing your supply chain
Joerg Lickfett & Johannes Jaschik
13.02.2020
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Supply Chain
2Non-analytical and analytical tools need to be combined for knowing your supply chain 2
Cultivation Storage Production
Transport
Pesticides, GMO, dioxins, PCBs and
POPs, veterinary drugresidues, alkaloides, forbidden additives,
heavy metals, microbiology, mycotoxins, radioactivity, authenticity
Pesticides, GMO, dioxins, PCBs and
POPs, veterinary drugresidues, alkaloides, forbidden additives,
heavy metals, microbiology, mycotoxins, radioactivity, authenticity
Gas certification,
impurities(Allergens,
GMO, foreignbodies,
Cleaning,Mix up
Gas certification,
impurities(Allergens,
GMO, foreignbodies,
Cleaning,Mix up
Irradiation, Germanation
inhibitor, storage
protection, microbiology, mycotoxins
Irradiation, Germanation
inhibitor, storage
protection, microbiology, mycotoxins
Process contaminants(Acrylamid, 3-MCPD(-
Ester), Furan, etc.), PAH, Mineral Oils(MOSH/MOAH), Disinfectants,
detergents, Solvantresidues, foreign
bodies, microbiology, hygiene, Migration frompackaging (BisphenolA, etc.), used water
Process contaminants(Acrylamid, 3-MCPD(-
Ester), Furan, etc.), PAH, Mineral Oils(MOSH/MOAH), Disinfectants,
detergents, Solvantresidues, foreign
bodies, microbiology, hygiene, Migration frompackaging (BisphenolA, etc.), used water
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Supply Chain
3Non-analytical and analytical tools need to be combined for knowing your supply chain 3
Cultivation Storage Production
Transport
Pre-harvestinspections ,
Set up ofspecifications.
Sampling on-site,(Supplier-)Audits,(Residue) Analysis
Inspections , sealing,
controls on arrival ,
sampling in the harbor,
gas certification
Audits(Storage checks) , training
Development ofindividual test plans,
risk management , monitoring (incl.
Analysis) , methoddevelopment,
hygiene audits, packaging control, sensory analysis, shelf life studies, labelling check
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Organic products: Critical points
Contamination(special vulnerability)
Contamination(special vulnerability)
4Non-analytical and analytical tools need to be combined for knowing your supply chain
Organic food fraud
PesticidesPesticidesSafenerSafener
SynergistsSynergists
Authenticity
(because of limited availability)
Authenticity
(because of limited availability)
GMOGMO
DisinfectantsDisinfectantsFertiliserFertiliser
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Methods
5Non-analytical and analytical tools need to be combined for knowing your supply chain
Instrumental methods
• Residue analysis
• Analysis of organic / anorganic contaminants
• Isotope testing
• PCR (for GMO)
Not-instrumental methods
• Audits (e.g. Hygenic, ISO, IFS)
• Risk Analysis
• Training, Webinars
Which methods are available:
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Food Supply Chain Service in the Sign ofChange
• List of Test Methods
• Analytical Results
Focus on TECHNICAL PART for individual steps of the process chain
Technical Experts needed
6
• Consultancy
• Risk Assessment
• Data Interpretation
Focus on SOLUTIONSalong the completeprocess chain
Food Fraud Expertsneeded
Non-analytical and analytical tools need to be combined for knowing your supply chain
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Identify and track
• History
• distribution
• location
• use
7Non-analytical and analytical tools need to be combined for knowing your supply chain Bildquelle: pixaby.com
Traceability
Products
Parts
Materials
basis for credible sustainability, quality or origin indications
Due diligence:
traceability throughout or part of the supply chain
of
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Risk Analysis
8Joerg Lickfett, Eurofins NDSC Food Testing Germany, Bildquelle: pixabay.com
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9
Risk Analysis
Joerg Lickfett, Eurofins NDSC Food Testing Germany, Bildquelle: Pixaby.com
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Traceability
10Non-analytical and analytical tools need to be combined for knowing your supply chain Bildquelle: Pixaby.com
Knowledge about:
• Origin of products
• Suppliers
• Working conditions
• Environmental impact
Complex supply chains are often accompanied by a la ck of
traceability.
In order to optimise qualilty a comprehensive knowled ge of supply
chain is required.
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Risk Analysis – Decision on Measures
11Non-analytical and analytical tools need to be combined for knowing your supply chain Bildquelle: Pixaby.com
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Example complex product
Simple case: single product
12Non-analytical and analytical tools need to be combined for knowing your supply chain
more complex: composite product
What would this mean for such a product?
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Example: „Raw products“
13Non-analytical and analytical tools need to be combined for knowing your supply chain
• audited production site
• talked to supplier
• checked storage and cleaning measure
at source
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Example: „Raw products“
14
Origin: TurkeyDisinfection of drying facilitiesPesticide use or contaminantion during farming
Origin: GermanyContamination with growth regulator (Chlormequat) during production
Origin: Austria / ChinaRisk depending on originPersistant organic contaminants
analyse samples for supposed risks
Non-analytical and analytical tools need to be combined for knowing your supply chain
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Legal evaluation – basis (pesticides)
15
Company Presentation Eurofins Food Germany
EU Regulation 889/2008
Article 5 (of Regulation 889/2008)Pest, disease and weed management
„1. Where plants cannot be adequatelyprotected from pests anddiseases … only [plant production] products referred to inAnnex II to this Regulation may be usedin organic production.
Operators shall keep documentaryevidence of the need to use theproduct.“
We don‘t have any detailsright now.
Current legislation:
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Legal evaluation example
16
Processed has to be checked
Processcontamination has to be checked
Persistant organic usually okaycontaminants (but has to be monitored)
Non-analytical and analytical tools need to be combined for knowing your supply chain
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Storage/ Transport
17Company Presentation Eurofins Food Germany
• Fumigation during transport (Phosphan,
Methyl Bromide)?
• Disinfection/Cleaning (QAC, C hlorate etc.)?
• Storage/Container treatment (e.g.
Chlorpyrifos)?
• Accidental mix up with conventional or with
different products
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Final storage
Many other raw materials
18Company Presentation Eurofins Food Germany
Storage
Dinkel flakes
Honey
Hazelnuts
Dried apple
Vanille
Maltodextrin
Sunflower seed
Many others
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Processing
Contamination possible
19Company Presentation Eurofins Food Germany
Production
• How many processing lines?
• Only organic products in production?
• How is the disinfection and cleaning process?
• Packaging material under control?
... and of course one non compliant ingredient has
an impact on the whole finished product
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Final Product
20Company Presentation Eurofins Food Germany
Final product isdelivered to theconsumer.
Food Fraud in organic products can happen at different
stages in the whole food chain.
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Legal evaluation
Difficult in a complex product:
21Company Presentation Eurofins Food Germany
• Concentrations of residues are often diluted in the
composite product (expect to find nothing anyway!)
• Homogeneity of the multi-component sample is
difficult
• Not possible to distinguish between contamination
or possible food fraud
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Corporate due diligence
22Company Presentation Eurofins Food Germany
§ 2 Abs. 1 Nr. 7 UWG
For the meaning of this Act "business diligence" me ans the standard of professional skill and care which a tra der may reasonably be expected to exercise in his dealings with consumers in good faith and in accordance with hone st market practice.
This means:
1. obligation to acquire the factual and legal know ledge
2. the obligation to ensure compliance with the req uirements of food law
3. this can also lead to a duty of care across all trade levels
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Benefits of Traceability
• Wholesalers and retailers can validate information about products and practices and inform their customers.
• Consumers can trust the origin of a product and ther efore remain loyal to the brand.
• Farmers can conclude contracts without major hurdle s and have better access to markets and services. Traceable ce rtification also means they are more likely to receive price pr emiums.
• Suppliers see a higher level of trust, can increase their turnover and have more stable procurement.
23Non-analytical and analytical tools need to be combined for knowing your supply chain
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Reasons to know the Supply Chain
• Risk assessment: Without it I have to rely on my suppliers
• Corporate duty of care – 2 Steps backwards
• Fraud- or health hazard
• International complexity
• Document falsification
• Decision making: general vs. special analytics
• Where fraud opportunities arise in the chain
• Sample logistics
• Reliability of references – reference databases
24Non-analytical and analytical tools need to be combined for knowing your supply chain
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Why is it important for you to know your complete supply chain?
25Non-analytical and analytical tools need to be combined for knowing your supply chain Picture: 2019 International Life Sciences Institute
Because youare responsible !!
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26
Thank you very much!
Joerg LickfettKey Account Manager
Fon: +49-(0)40-49294 3109
Johannes JaschikAnalytical Service Manager
Fon: +49-(0)40-881 448-452
www.eurofins.de
Joerg LickfettKey Account Manager
Fon: +49-(0)40-49294 3109
Johannes JaschikAnalytical Service Manager
Fon: +49-(0)40-881 448-452
www.eurofins.de
?
Non-analytical and analytical tools need to be combined for knowing your supply chain