the identification of sources of information...

By: Dr John Dennis (Project lead) and Dr Simon Kelly

The identification of sources of information concerning food fraud in the UK and elsewhere (Q01R0025)

Report to Defra, Food Authenticity Branch

March 2013

Food fraud in the UK and elsewhere (FA0104) – Final Report

Contents

About the Authors Author 1 details Dr John Dennis worked for the MAFF Food Science Laboratory, The Central Science laboratory and Fera for 35 years. He was formerly the Head of the Food Science Group and a founder member of the FSA‟s Working Party on Food Authenticity and is currently Chairman of its Methods Sub-Group within Defra. He gained his degree in Biological Science and PhD in Chemical Science at the University of East Anglia. Dr Dennis is a Chartered Fellow of the Royal Society and has been a member of a number of National and European Committees and advisory groups. Author 2 details Dr Simon Kelly is a research leader in stable isotope analysis and food authentication within the Food and Environmental Safety Programme at Fera. He gained his degree in Chemistry from Anglia Polytechnic in 1992 and completed his PhD in the School of Environmental Sciences at the University of East Anglia in 2002, where he now holds an honorary lectureship. Dr Kelly is a Chartered member of the Royal Society of Chemistry and member of the Editorial Board of the journal „Food Chemistry‟. He has acted as a consultant to the joint Food and Agriculture Organisation/International Atomic Energy Agency‟s Division of Nuclear Techniques in Food and Agriculture. Simon has been involved in applying isotope ratio mass spectrometry to Food Authentication since 1992.

Table of Contents Executive Summary .................................................................... Error! Bookmark not defined.

1 Background to project......................................................................................................9

1.1 Definitions and legal framework ......................................................................................................................... 9 1.2 Categories of fraud .......................................................................................................................................... 10

1.2.1 Smuggling ............................................................................................................................................. 10 1.2.2 Deliberate mislabelling ........................................................................................................................... 10 1.2.3 Substitution ............................................................................................................................................ 10 1.2.4 Adulteration ........................................................................................................................................... 11 1.2.5 Tipping................................................................................................................................................... 11

1.3 Social and economic context ........................................................................................................................... 11 1.4 References ...................................................................................................................................................... 12

2 The challenge of gathering information on the incidence of food fraud at national, European and

international levels ........................................................................................................ 13

2.1 Context ............................................................................................................................................................ 13 2.2 References ...................................................................................................................................................... 16

3 Methods for gathering data .......................................................................................... 17

3.1 Direct contact with local and central Government agencies in the UK, Europe and Internationally ................... 17 3.1.1 UK Food Standards Agency - Food Fraud Task Force ........................................................................... 17 3.1.2 The UK Food Surveillance system (UKFSS) .......................................................................................... 17 3.1.3 European Institutions ............................................................................................................................. 19 3.1.4 International Institutions ......................................................................................................................... 19

3.2 Media .............................................................................................................................................................. 19 3.3 Retailers .......................................................................................................................................................... 18 3.4 Other food authenticity and quality laboratories in the public and private sector............................................... 19


Contents

3.5 Consumer groups ............................................................................................................................................ 19

4 Levels and trends in food and beverage fraud ........................................................... 20

4.1 National information ........................................................................................................................................ 20 4.1.1 Data from the FSA‟s Food Fraud Task Force ......................................................................................... 20 4.1.2 The UK Food Surveillance system (UKFSS) .......................................................................................... 21

4.2 Information from the European Union .............................................................................................................. 22 4.2.1 Information from EU customs seizures ................................................................................................... 23 4.2.2 European Anti-Fraud office (OLAF) ........................................................................................................ 24 4.2.3 Origin of counterfeit food and drinks products entering the EU ............................................................... 25 4.2.4 Directorate General for Competition policy, Consumer Affairs and Fraud Control (DGCCRF). ............... 26 4.2.5 Eurostats Comext database ................................................................................................................... 26 4.2.6 European Rapid Alert System for Food and Feed (RASFF) ................................................................... 29 4.2.7 Categories of food and beverage products seized by EU customs ......................................................... 28 4.2.8 European Union‟s Joint Research Centre (DG- JRC, Ispra, Italy) ........................................................... 28 4.2.9 European Food control laboratories ....................................................................................................... 29

4.3 Information from International sources ............................................................................................................. 31 4.3.1 Organisation for Economic Co-operation and Development (OECD)...................................................... 31 4.3.2 Greg Noonan (Food and Drug Administration, USA) - Authenticity in Food, US Perspective .................. 32 4.3.3 The Anti-Counterfeiting and Product Protection Program (A-CAPPP) Michigan State University (USA) 32 4.3.4 Stan Bacler (Canadian Food Inspection Agency, CFIA) - Food Authenticity Testing Programmes ......... 33

4.3.5 Dr Paul Dansted (New Zealand Ministry of Agriculture and Forestry NZ-MAF) - Food Assurance .......... 33

4.3.6 Shirley Abrantes (Brazilian National Institute of Quality Control in Health, INCQS) - Authenticity in food – what does this

mean to Brazil? ..................................................................................................................................................... 33

4.3.7 Veronica Torres Leedham (National Health Service and Agri-Food Quality, SENASA) - Authenticity in food – what does this

mean to Argentina? ............................................................................................................................................... 33

4.3.8 Wongkwan Jitnupong (Faculty of Veterinary Medicine, Khonkaen University, Thailand, FVM-KU) - Authenticity in Food –

what does this mean in regional perspective?..................................................................34

4.3.9 Isoforensics (USA)...............................................................................................................................37

4.4 Media .............................................................................................................................................................. 34 4.4.1 Television broadcasts ............................................................................................................................ 34 4.4.2 Internet .................................................................................................................................................. 34

4.5 Trade press ..................................................................................................................................................... 34 4.6 Consumer groups ............................................................................................................................................ 39

4.6.1 Which? .................................................................................................................................................. 39 4.7 Trade Associations .......................................................................................................................................... 39

4.7.1 Grocery Manufacturers Association (GMA) ............................................................................................ 39 4.8 References ...................................................................................................................................................... 36

5 Other areas ..................................................................................................................... 37

5.1 Categories of food and beverage products identified from other sources ......................................................... 37 5.2 Health effects relating to counterfeit food and beverages................................................................................. 37 5.3 Estimates of Economic Effects of food and beverages fraud ........................................................................... 38

5.4 References.....................................................................................................................................................44

6 Horizon Scanning – Continued and emerging food authenticity issues ................. 40

6.1 Counterfeit spirits and illicit spirit drink production ....................................................................................... 40 6.2 Counterfeit wine ......................................................................................................................................... 40 6.3 Meat and Bone Meal/ Processed Animal Protein (MBM/PAP) ..................................................................... 41 6.4 Pineapple and pomegranate juice ............................................................................................................... 41 6.5 The declared geographical origin of meat ................................................................................................... 41 6.6 Manuka honey and other honey authenticity issues .................................................................................... 42 6.7 Sustainable palm oil origin .......................................................................................................................... 42 6.8 Illegal fishing and fraud along the fish supply chain. ................................................................................... 42 6.9 Vanilla and other food flavours ................................................................................................................... 43 6.10 Spices (e.g. mustard and saffron) ............................................................................................................... 43 6.11 Botanical source of acetic acid in Balsamic vinegar .................................................................................... 43 6.12 Melamine alternatives giving a high „apparent‟ protein content in foods ...................................................... 44


Contents

6.13 Hydrolysed leather protein in milk ............................................................................................................... 44 6.14 Palm sugar authenticity .............................................................................................................................. 44 6.15 Authenticity of Halal food products .............................................................................................................. 45 6.16 Organic food authenticity ............................................................................................................................ 45 6.17 Internet purchasing of speciality foods ........................................................................................................ 46 6.18 Gross crude adulteration ............................................................................................................................ 46 6.19 Food irradiation .......................................................................................................................................... 46 6.20 References ................................................................................................................................................. 48

7 Conclusions and Recommendations ........................................................................... 49

7.1 References ................................................................................................................................................. 50

8 Other sources cited ....................................................................................................... 58

8.1 Additional sources consulted.....................................................................................................................59

9 Acknowledgements ....................................................................................................... 59


Executive Summary

Executive Summary

1. This project was undertaken in response to a Food Standards Agency Research Requirement to identify

sources of information on food fraud (Requirement Reference: Q01R0025; RRD31: programme Q01 – Food

Authenticity; Issued: Wednesday 30 June 2010). During the assessment and commissioning phase of the

proposals the Food Authenticity Branch (FAB) moved to Defra and the research was subsequently

commissioned as Defra project FA0104.

2. This project identified 35 principal sources of information ranging from individual companies, trade

associations, consumer groups, and private-sector laboratories, enforcement agencies through to inter-

governmental bodies such as the EU, OECD and the FAO. Some information sources contained multiple

point sources of information such as private sector laboratories. The information was gathered by direct

communication with these organisations or through publicly available data provided on web-sites or

databases. There were several organisations that did not respond to our enquires.

3. The challenge of detecting and assessing the risk of food fraud and adulteration is that it ranges from the

very real threat of international commodity issues to bogus „locally produced‟ claims at a farmer‟s market.

The size and breadth of the potential issues means that identifying a single source of information is

extremely challenging.

4. The scale of global trade in counterfeit products was estimated at 5-7% by the World Customs Organisation

(WCO) in 2004. Of this approximately $49 billion was accounted for by counterfeit food and beverages. By

comparison, the size of the counterfeit food market in the UK was estimated at £7 billion per annum by the

consumer group Which? in 2008. They suggested as much as 10% of the food on sale in retail markets and

foodservice was not as described.

5. In the UK, the Food Standards Agency‟s Food Fraud team provides a coherent and well established route to

the reporting and collation of incidences of food fraud, on their National Food fraud database, through

various different information sources, such as Trading Standards, the Police and other government

departments such as Defra FAB. Dissemination through „FSA Intelligence briefs‟ is also highly effective

dissemination route for stakeholders.

6. The UK Food Surveillance system (UKFSS) is a national database that records results of all food and feed

samples, submitted for analysis and/or examination by official control laboratories on behalf of UK local

authorities and port health authorities. Closer examination of the database revealed that there is the

possibility for Government to run a search report that could be used on a frequent basis to monitor LA

enforcement activity in the Food Authenticity area.

7. The collation and dissemination of food fraud information on a European and international level is not well

defined. There are several players at this level including OLAF, DG TAXUD, JRC, OECD, DG

ENVIRONMENT, FAO, WCO and so on. However, the European Rapid Alert System for Food and Feed

(RASFF) can be readily searched on categories such as „adulteration‟ and „fraud‟ to obtain information

entered by the relevant National competent authorities.

Key messages

There is a clear difference between the number and type of food authenticity and food fraud


Executive Summary

cases detected and reported by the enforcement community in the UK and the frequency

and breadth of issues investigated by private sector laboratories around Europe. There is a

significant information and intelligence gap in this area that is derived from insufficient

information sharing between the food industry and the enforcement community leading to

undetected food fraud in the UK.

There is also a technology gap between the methodologies made available through the LA

Public Analyst and the leading analytical food authenticity research establishments. This

means the most up to date methods are not always available and/or LAs are not aware of

the techniques on offer in the fight against food fraud and food adulteration.

The adulteration of food is driven by economic incentives and is not malicious in the vast

majority of cases. However, the associated risks to public health should not be overlooked.

Recommendations

1. Put in place a system to make UK Enforcement Officers aware of the latest technology to fight food fraud

(e.g. FSA/Defra workshop on recent advances in food authentication at TSO and EHO annual conferences).

2. Establish a European network of competence for analytical techniques in food authentication, on a

commodity basis, so that the latest technology and appropriate expertise can be readily accessed. This

would be analogous to the appointment of National Reference Laboratories for food authentication as with

for example pesticide, veterinary drug, dioxin, and heavy metal analysis. The appointed food authenticity

NRL could also train PAs in the relevant technology when appropriate.

3. Seek funding from the Commission‟s Directorate-General for Research and Innovation for a COST action

(European Cooperation in Science and Technology) to initiate an anti-food fraud intelligence network, at the

European level. Once established this AFFI network could seek to establish international links at all levels

between enforcers, practitioners, government bodies and consumer protection organisations. Its aim would

be to disseminate information through a specific food fraud alerting service to all relevant international

stakeholders and could be linked into existing systems such as RASFF.

4. The FSA‟s Food Fraud Team and Defra‟s Food Authenticity Branch should forge links with the U.S. Food

and Drug Administration‟s „Pathway to Global Product Safety and Quality‟. The FDA, in close partnership

with its foreign counterparts, plans to assemble global coalitions of regulators dedicated to building and

strengthening the product safety net around the world. With these coalitions, FDA intends to develop a

global data information system and network in which regulators worldwide can regularly and proactively

share real-time information and resources across the global market place.

Key messages

The key to consumer protection is the rapid sharing of information and intelligence about

suspected and actual incidence of food fraud and adulteration between the food industry and

the enforcement community, without prejudice. Partnerships between government and trade

associations should facilitate information sharing and enforce laws and regulations.


Executive Summary

Introduce a system of „horizon scanning‟ of emerging food fraud issues by examining

correlations between commodity prices and links with levels of fraud and differences between

production and traded volumes. This would be a move towards a proactive rather than

reactive intelligence led system of detection of food fraud and would be highly desirable. This

links with recommendations for the requirements of a system covering EFSA’s mandate for

automatic scanning of the Eurostat Comext database. Such a system should provide alerts to

the users, indicating for example i) significant increase of the volume of a given product over

time to a specific MS or EU in total ii) new trade partners iii) new food or feed commodities

entering the EU.

Whilst commodity adulterant or commodity specific analytical tests are useful, high

throughput non-targeted screening methods are the key to moving towards a proactive rather

than reactive national analytical food authentication system and have implications for food

defence.

Recent opinion suggests that organised crime syndicates are increasingly behind cases of

food fraud and adulteration. Consequently, the detection and prevention of food fraud

requires strategic planning and investment within both local and central government with an

appropriate and sustainable budget.

Frequently identified issues

1. Illegal imports of meat

2. Counterfeit spirit drinks

3. Illegal re-dating of food

4. Missing health declaration certificates

5. Counterfeit alcoholic spirits

6. White fish substitution

7. Fruit juice extended with added water and sugar, especially pineapple and pomegranate

8. Addition of nitrogen rich chemicals to food to increase the apparent protein content

9. Addition of cheap sources of sugar to honey

10. Mis-description of meat origin

11. Free range egg mis-description

12. Industrially produced vanillin described as natural vanilla from beans in ice cream and dairy

products such as yoghurt

13. Extra virgin olive oil quality and origin

Emerging food fraud and authenticity issues

1. Geographical origin of liquid egg

2. Meat from animals fed on meat and bone meal/processed animal protein (MBM/PAP)

3. Fruit juice authenticity

4. Counterfeit wines

5. The declared geographical origin of meat e.g venison

6. Fish species mis-description


Executive Summary

7. Illegal fishing and fraud along the fish supply chain.

8. Manuka honey and other honey authenticity issues

9. Sustainable palm oil origin

10. Extra virgin olive oil and other speciality single seed vegetable oils

11. Vanilla and other food flavours

12. Origin and quality of spices (e.g. mustard and saffron)

13. Botanical source of acetic acid in Balsamic vinegar

14. Melamine alternatives giving a high „apparent‟ protein content in foods

15. Hydrolysed leather protein in milk

16. Palm oil authenticity

17. Palm sugar authenticity

18. Authenticity of Halal and Kosher food products

19. Organic food authenticity

20. Internet purchasing of speciality foods

21. Gross crude adulteration

22. Food irradiation

23. Counterfeit spirits and illicit spirit drink production

24. Counterfeit wine produced from cane and maize alcohol

25. Coffee and chocolate origin


Section 1: Background to project

1 BACKGROUND TO PROJECT

Food fraud and mis-description has been an important issue for the Food Standards Agency since

its inception and has been a key issue for public protection since historical times. The Strategic Plan to

2010 had a specific aim to “improve consumer protection from food fraud and illegal practices”. To meet

this objective a Task Force was set up to identify key priorities. The Task Force identified that improved

intelligence gathering and better sharing of information between food enforcement agencies is a vital

element in the control of food fraud.

The challenge of detecting and assessing the risk of food fraud is that it ranges from the very real

threat of international commodity issues such as melamine in Chinese formula milk to a bogus organic

claim on a greengrocer's blackboard. The size and breadth of the potential issues means that identifying

a single source of information is extremely difficult. The sources of information may stretch from

individual companies or trade associations through to inter-governmental bodies such as the EU.

1.1 Definitions and legal framework

The Overarching EC requirements intended to ensure consumers are not misled are the Food

Labelling Directive 2000/13, Article 2, which requires that food labelling must not mislead the purchaser

to a material degree, particularly:

(i) as to the characteristics of the foodstuff and, in particular, as to its nature,

identity, properties, composition, quantity, durability, origin or provenance,

method of manufacture or production.

Furthermore, information provided on the label or in presentation of a food must not be false or

misleading, under Article 16 of Regulation (EC) 178/2002 and the Unfair Commercial Practices Directive,

2005/29/EC.

In the United Kingdom these provisions are currently implemented by the general requirements of

the Food Safety Act 1990 and the Trade Descriptions Act 1968. The Food Safety Act 1990 makes it an

offence for anyone to:

(i) sell, to the purchaser‟s prejudice, any food which is not of the nature,

substance or quality demanded (section 14);

(ii) give or display a label1 with any food sold, or publish or be party to the

publication of an advertisement, which falsely describes the food or which is

likely to mislead as to the nature, substance or quality of the food (section 15);

(iii) sell, offer or expose for sale, or have in possession for the purpose of sale any

food the presentation2 of which is likely to mislead as to its nature, substance

or quality (section 15).

The terms “nature”, “substance” and “quality” are not defined in the Food Safety Act 1990. It is

considered that the origin of a food could, in certain circumstances, be relevant to its nature, substance

or quality and will therefore be relevant to the offences described above. Origin is defined in Codex and

WTO rules as the „place of last substantial change‟. Furthermore, Labels must be clearly worded to



avoid contravening laws on false and misleading labelling and voluntary information on origin may be

displayed providing that it is accurate or not misleading.

The UK Food Standards Agency states food fraud has occurred “..when food is deliberately placed

on the market, for financial gain, with the intention of deceiving the consumer”.

UK Food Standards Agency

www.food.gov.uk/enforcement/workwithenforcers/foodfraud/

The United States Food and Drug Administration (FDA) defines economically motivated

adulteration (EMA) as “the fraudulent, intentional substitution or addition of a substance in a product for

the purpose of increasing the apparent value of the product or reducing the cost of its production”.

1.2 Categories of fraud

Counterfeiting and fraud in the food and beverages sectors can be characterised in a number of

ways, including the following:

• Smuggling

• Deliberate mislabelling

• Substitution (i.e. of product or ingredient)

• Adulteration (e.g. Addition of water to meat products to increase weight)

• „Tipping‟ Refilling branded spirit bottles with inferior products

1.2.1 Smuggling

Smuggling becomes attractive when price differentials are large across national boundaries

caused by different currency valuations or tax policies. This is most common in relation to high value

spirits but also occurs with any category of food or drink where price differentials occur.

1.2.2 Deliberate mislabelling

Deliberate mislabelling is possibly the commonest method to misrepresent a product. It is much

simpler to reproduce packaging, labelling, the trademark and general appearance of a product being

substituted than to physically reproduce the product as the latter procedure requires much greater

sophistication and specialist equipment for production.

Deliberate mislabelling is used to defraud the consumer by imparting the impression that the

product is of higher quality/nutritional value than is the case. A higher price can thus be charged than

would otherwise be possible. Mislabelling is involved in all categories of fraud in which counterfeiting is

involved.

1.2.3 Substitution

Substitution refers to the replacement of a product ingredient by another cheaper ingredient that

may or may not reduce the overall quality of the product. It may also involve the substitution of one

product for a cheaper product. The motive is to increase the apparent value of the product or reduce its

cost of production. Products most amenable to counterfeiting are those that are simplest to replace with

http://www.food.gov.uk/enforcement/workwithenforcers/foodfraud/



passable substitutes not easily detectable by the consumer. Common examples include substitution of

cheap bulk tea for prime quality leaf tea, low quality cheap rice for basmati rice substitution of cheaper

fish (bonito for tuna) or animal species for more expensive ones, battery eggs for free range eggs,

traditionally grown produce for organic and illegally brewed white spirits in place of vodka. It is associated

with mislabelling and allows a higher price to be charged than would be possible without the substitution.

It is carried out either by the producer of the genuine product or during counterfeiting operations.

1.2.4 Adulteration

Adulteration means different things in different countries. In EU countries it means the deliberate

addition of an ingredient to deceive the consumer into thinking that they are purchasing a better quality

product than is actually the case. In the US, adulteration can mean this, but also refers to accidental

contamination by dirt, unwanted animal products or prohibited antibiotics intended to improve the health

of livestock or fish being reared for market.

Adulteration is probably the most common area of food and drinks fraud carried out either during

processing or manufacturer of the product or by intermediaries or retailers. Examples include adding

water to increase the weight of meat products to obtain a higher price, addition of prohibited colouring

agents to either give the impression of greater freshness of meat products or increase the attractiveness

of other products. In other cases, meat and fish products may be contaminated with prohibited antibiotics

such as chloramphenicol deliberately added to feedstuffs to prevent infection and increase the product

weight.

1.2.5 Tipping

Tipping refers to the refilling of branded drinks bottles with inferior substitutes. It is most common

with white spirits where the fake product is virtually indistinguishable in appearance from the genuine

product. It is also referred to as refreshing which includes all forms of repackaging and replacement of

labels to deliberately mislead the consumer into believing that a genuine product is being sold. In a

survey of 10000 of public houses in the UK in 1999 8% of the premises visited were refilling or

substituting their spirits at an annual cost of £43 million before tighter enforcement activities reduced the

level to 2 in 2007, reducing annual losses to around £13 million.

1.3 Social and economic context

It is anticipated that increasing oil prices and competition for water and land will limit agricultural

production worldwide. While increasing populations and rising consumer incomes in emerging

economies such as the BRIC countries (Brazil, Russia, India and China) will increase demand for

premium foods (OECD/FAO, 2011). The joint report, from the Organisation for Economic Co-operation

and Development (OECD) and the United Nation‟s Food and Agriculture Organisation (FAO) contains

food price increase projections, which discount the impact of inflation (Figure 5.1, below). The

OECD/FAO estimates the price of maize will be 20% higher than in the previous 10 years over the

coming decade. It goes on to state that the price of poultry will be even more expensive, averaging 30pc

more and butter will be even higher, costing on average more than 45pc more over the next decade than

in the last.



Figure 5.1: Source: OECD and FAO; SMP: Skim milk powder; WMP: Whole milk powder reproduced from figure http://www.oecd.org/pages/0,3417,en_36774715_36775671_1_1_1_1_1,00.html accessed 18

th June, 2011

Rising prices and scarcity of raw ingredients means there is a pressure to use „alternative‟

materials in food production. Whilst counterfeiters are seeking not to harm but to hide the act for profit

there is a real public health risk associated with food fraud exemplified by the case of milk and pet food

adulterated with melamine to increase the apparent protein content. The melamine incident is by no

means the only example where counterfeiters‟ lack of food chemistry knowledge has had a serious effect

on public health. In 1981 an attempt to produce non-authentic olive oil with rapeseed oil, which was

denatured with 2% aniline (Del Pozo et al., 1997), affected more than 20,000 Spanish people and

tragically resulted in 300 deaths. However, in the vast majority of cases the issue is one of detecting

economic fraud. When an inferior product is passed off as a superior one or a premium product is

extended with cheaper ingredients,

Counterfeiting is a major problem in the global food and drink industry with the level of fraud

estimated at around $50bn a year in 2009 by John Spink, director of the Packaging for Food and Product

Protection (P-FAPP) initiative at Michigan State University (Food Quality News, 2009).

1.4 References

Del Pozo, V., De Andres, B., Gallardo, S., Cardaba, B., De Arruda Chaves, E., Cortegano, M.I., Jurado, A., Palomino, P., Oliva, H., Aguilera, B., Posada, M. and Lahoz, C.; Toxicol 118 (1997) 61-70

EUROPEAN COMMISSION; Brussels, 6 May 1998; COM(98) 276 final, PROTECTION OF THE FINANCIAL INTERESTS OF THE COMMUNITIES, FIGHT AGAINST FRAUD, Annual Report 1997, 2.1.2.4. Infringement of the embargo on British beef

The Food Safety Act 1990 (c. 16), Her Majesty's Stationery Office Ltd, London, UK

Food Quality News (2009) “More food fraud expected as prices rise” Jane Byrne, 17-Feb-2009. http://www.foodqualitynews.com/Public-Concerns/More-food-fraud-expected-as-prices-rise Accessed 10/02/11

Ladona, M.G., Izquierdo-Martinez, M., De la Paz, M.P., De la Torre, R., Ampurdanes, C., Segura, J. and Sanz, E.J.; Environ. Health Pers. 109 (2001) 369-375

OECD/FAO (2011) OECD-FAO Agricultural Outlook 2011-2020, OECD Publishing and FAO http://dx.doi.org/10.1787/agr_outlook-2011-en http://www.keepeek.com/Digital-Asset-Management/oecd/agriculture-and-food/oecd-fao-agricultural-outlook-2011_agr_outlook-2011-en accessed June 18

th 2011

http://www.oecd.org/pages/0,3417,en_36774715_36775671_1_1_1_1_1,00.html

http://www.foodqualitynews.com/Public-Concerns/More-food-fraud-expected-as-prices-rise

http://www.foodqualitynews.com/Public-Concerns/More-food-fraud-expected-as-prices-rise

http://www.keepeek.com/Digital-Asset-Management/oecd/agriculture-and-food/oecd-fao-agricultural-outlook-2011_agr_outlook-2011-en



Food fraud in the UK and elsewhere (Q01R0025) – Final Report

Section 2: The challenge of

2 THE CHALLENGE OF GATHERING INFORMATION ON THE INCIDENCE OF FOOD FRAUD AT

NATIONAL, EUROPEAN AND INTERNATIONAL LEVELS

2.1 Context

Fraud in the food and beverages sector, whilst perceived to have a major and increasing impact

during the global economic downturn, is almost impossible to quantify with any degree of accuracy. The

level and impact of fraud is often not documented systematically in national databases whilst local

records are difficult to access and verify. With the exception of the UK‟s Food Fraud Database, no

coherent method of recording incidents of food fraud has been adopted across all European National

enforcement agencies with the result that where figures do exist, reliable comparisons are not possible

and annual trends cannot be easily determined.

The estimated levels of counterfeiting derived from local reports and Custom statistics suggest that

the problem of counterfeiting and fraud in the food and beverages sectors is insignificant compared with

levels observed in the high value durable goods (e.g. TVs, computer monitors etc) and clothing and

shoes sectors. This is likely to be due to the low profit margins and greater logistical problems associated

with production, handling, transport and distribution of most food products (OECD, 2008). However, the

inherent safety risk associated with economic adulteration of food should not be overlooked. This can

have an enormous and long lasting social and economic impact on industry and consumers as in the

case of melamine in Chinese milk powder, which caused six infant deaths in 2008 and was estimated to

have made 300,000 babies ill (Financial Times, 2010) and cost billions of dollars in lost revenue and

recalls (AFP, 2008).

Statistics for Custom‟s seizures for food and beverages do not necessarily appear in records as

separate categories. This is the case even in some large economies, including the USA, where statistics

for seizures of food and drink are combined with other categories of goods, making it difficult to obtain

definitive figures of both volume and value in the trade of counterfeit food and beverages. The Pie-chart

below demonstrates this point as it displays the figures for food and drink combined with frauds relating

to tobacco in Europe (Figure 1, OLAF 2010)

Figure 2.1: Fraud and irregularities breakdown by good in 2009 (in million EUR) [reproduced from reference OLAF (2010)]

However, Custom‟s agencies within the European Union (EU) do record interceptions of

counterfeit and smuggled food and drink as a separate category but occasional misallocation of goods

from other sectors within this sector means that figures may be inaccurate. Furthermore, within the EU,



seizures of goods in this sector represent less than 1% of the total of cases/seizures and a single large

seizure in any single year will be likely to distort the figures (OLAF, 2010).

Despite this drawback, the accumulation of annual statistics over a number of years can allow

some inferences to be drawn on the main food and beverage products subject to fraudulent practices,

the extent of fraud within these products and the countries of origin of the counterfeit goods. This

information can lead to targeted interventions to eliminate or control the levels of food and drink‟s fraud in

these countries.

Whist relatively crude statistics are available for the EU, and to a lesser extent the USA, these are

among only a few economies where national statistics are both collected for these product categories

and accessible. Other countries either do not have the resources to devote to controlling crime in this

area, or consider the problem to be minor (and externalised) compared to other problems impacting on

their economies, which have higher priority for both police and customs agencies. Nevertheless, these

represent the two largest world economies and consequently data on food fraud collected in the EU and

USA can be extrapolated to provide rough estimates of the global extent of the problem. However, some

overview information was obtained directly from Government representatives in Australia, New Zealand,

Canada, Brazil and Thailand

Most incidences of food fraud are localised within national boundaries. This is especially so for

fresh foodstuffs which are often perishable and generally of low value compared to other counterfeited

goods and which must, therefore, be sold in relatively large volumes to make counterfeiting worthwhile.

They must also be sold quickly to minimise losses due to deterioration. Examples, could be the miss-

description of imported vegetables as „locally produced‟ or conventionally cultivated crops as „organic‟ to

obtain the premium prices associated with these food categories. Refrigerated fresh meat and fish,

processed foods and bottled drinks have a longer shelf life and, particularly in the case of alcoholic

drinks, a high value and profit margin, making it feasible to transport these goods across national

borders. Consequently, wines and spirits do attract highly sophisticated and organised counterfeiting as

recently demonstrated with fake Jacob‟s Creek wines entering the UK market place (FSA, 2011a) and a

Nationwide counterfeit vodka scam (FSA, 2011b).

Detection of fraud in the food and drinks industry at the local level often results from consumer

complaints regarding quality or poisoning of consumers as a result of adulteration with toxic ingredients

during manufacture or processing (e.g. methanol in spirit drinks, melamine in milk products). At national

borders, detection of fraudulent food and drink by customs‟ agencies in both the exporting and importing

countries often results from intelligence provided by the owner of patent or other rights to the products. At

EU borders, customs authorities can only take action after receiving a complaint from a right‟s holder and

even if they detect counterfeit goods independently, must locate the right‟s holder, who must then issue a

complaint within three working days for action to be taken by customs authorities.

Customs authorities are able to detect counterfeit food and beverages largely as a result of

intelligence gathered by the often large multinational food and drinks companies holding patents or

intellectual rights to the product brands being counterfeited. Thus names such as Nestle, Coca cola and

the brand names of a large variety of alcoholic products recur regularly in statistics on food and drinks‟

fraud. It is only these organisations acting alone or as members of consortia, such as the British Retail

Consortium, that have the financial capability of mounting intelligence gathering operations to identify

which of their products are being counterfeited and where the production of counterfeit products is taking

place. A recent OECD report (OECD, 2008) cited a multinational spirit producer who identified 30

economies in both developed and developing countries where customs seizures of counterfeit spirits had



been made over recent years and who claimed that a global counterfeit recognition programme was

maintained in more than 150 countries by a consortium of multinational spirit producers to deal with the

problem of counterfeit products. These organisations hold statistics on the levels and trends of fraud

affecting their own brands and these statistics comprise a large proportion of global estimates in the food

and beverages sector.



2.2 References

AFP (2008): „China milk crisis to cost billions, up to a year to restore confidence‟ (AFP) – Oct 6, 2008. Accessed March 2011

http://afp.google.com/article/ALeqM5htzunYYbxFYw-ceVXBWszNhOZVSg

Financial Times (2010): FT.com „China to crack down as tainted milk returns‟ By Patti Waldmeir in Shanghai. Published: February 2 2010.

Accessed Jan 2011 http://www.ft.com/cms/s/0/70158d4e-1012-11df-841f-00144feab49a.html#axzz1KoXC2sVe

FSA (2011a): Food Standards Agency, „Counterfeit Jacob's Creek wines‟ Tuesday 29 March 2011. Accessed April 2011

http://www.food.gov.uk/news/newsarchive/2011/mar/counterfeit

FSA (2011b): Food Standards Agency, FSA e News (the newsletter of the Food Standards Agency) , „Partnership working cracks

counterfeit vodka scam‟, Issue 012, April 2011

OECD (2008a): The Economic Impact of Counterfeiting and Piracy. Organisation for Economic Cooperation and Development (OECD)

2008.OECD 2, rue André Pascal 75775 Paris Cedex 16 France pp 397.

OLAF (2010): European Anti-Fraud Office: Statistical Evaluation of Irregularities- Own Resources, Agriculture, Cohesion Policy, Pre-

Accession Funds and Direct Expenditure -Year 2009. Report from the Commission on the protection of the European Union's financial

interests and the fight against fraud – 2009. Brussels, 14.7.2010, SEC(2010) 898 final

http://afp.google.com/article/ALeqM5htzunYYbxFYw-ceVXBWszNhOZVSg

http://www.ft.com/cms/s/0/70158d4e-1012-11df-841f-00144feab49a.html#axzz1KoXC2sVe

http://www.food.gov.uk/news/newsarchive/2011/mar/counterfeit



3 METHODS FOR GATHERING DATA

A list of individuals and institutions contacted for this study is given in Appendix 1. Information was

given under the understanding that in some instances there would be no further disclosure and

respondents were given the option to make Fera aware that the data should not be available through the

Freedom of information Act. The covering letter sent to potential respondents is given in Appendix 2.

Responses that were given in direct correspondence are referred to with the individual‟s organisation and

„private communication‟. More often than not the type of fraud is identified but not its frequency.

The information below is a more detailed breakdown of where information was obtained at

regional, national, European and International levels. In addition, UK, EU and US government websites

related to trade and public health were consulted as well as websites of trade associations, anti-

counterfeiting associations and internet-based food and drink news sites.

3.1 Direct contact with local and central Government agencies in the UK, Europe and Internationally

3.1.1 UK Food Standards Agency - Fraud Team

A meeting was held with the Food Standards Agency Food Fraud Team to discuss the

functionality of the FSA‟s National Food Fraud Database (NFFD) and the reported incidence of food

fraud in the UK in 2010. The NFFD enables collection and analysis of intelligence on food fraud in the

UK. The uses specialist intelligence management software that is also used by leading UK police forces,

the Welsh Food Fraud Co-ordination Unit and a number of other high profile global organisations. This

database is populated with intelligence on known or suspected food fraud supplied by local authorities,

port health authorities, members of the public, industry, other governmental departments and

international contacts of the Food Fraud Team. The intelligence is assessed using the „5x5x5‟

Information/Intelligence report forms, defined by the National Intelligence Model (NIM)1 e.g. reliability of

source, accuracy.

3.1.2 The UK Food Surveillance System (UKFSS)

The Food Standards Agency possesses a number of different databases and the Meat Hygiene

Service retains a separate database for enforcement at slaughterhouses and food businesses. The FSA

is working toward consolidating these separate activities into a single source of all data on a common

system. The UK Food Surveillance system (UKFSS) is a national database to record results of all food

and feed samples, submitted for analysis and/or examination by official control laboratories on behalf of

UK local authorities and port health authorities. The UKFSS database was developed by Health

Protection, Scotland. A Local Authority Enforcement Management System (LAEMS) database was also

developed so that FSA were able to summarise enforcement activities in annual reports to the EU. Work

is ongoing to combine the sampling side of UKFSS and LAEMS because they contained much common

source information. UKFSS stores local authority (LA) sampling data as part of the statutory control

program. Whereas LAEMS stores data on broader enforcement activities and these may include

1 http://www.food.gov.uk/multimedia/pdfs/board/fsa070907.pdf



inspection and sampling. The Meat Hygiene system is similar and includes inspection of dairies/milk

processors. Eventually all these systems will be linked with the expectation that a linked database

system will trigger actions more widely when issues are identified. UKFSS operates in real time whereas

LAEMS tends to be delayed because it focuses on the annual reporting cycle to the EU, but covers the

full range of LA activities. UKFSS contains all information from Northern Ireland and 90% of the

information from Scotland. In England the Public Analysts use the system but the Health Protection

Agency laboratories, that undertake the majority of the microbiological tests of the food supply are only

beginning to take part.

3.1.3 European Institutions

The most accessible databases on food fraud are those relating to customs seizures of counterfeit

goods. However, because the levels of counterfeiting relating to food and beverages are so low

compared to levels in other sectors, data are grouped with statistics from other sectors in many cases

(including US Customs). Data for food and drink seizures are treated as a separate sector by EU

customs (EC TAXUD) and so some information on levels of, and trends in, food fraud are retrievable,

along with information on the sources of counterfeit food and beverages and the main products involved.

3.1.4 International Institutions

In an attempt to find reliable information, searches were conducted on the global websites of the

World Trade Organization (WTO), the World Intellectual Property Organisation (WIPO), the International

Chamber of Commerce (ICC) and the World Health Organization (WHO). Food and Agriculture

Organisation (FAO) Infosan food safety database was also inspected for food fraud information.

3.2 Media

A scan of the popular press reveals many reports, anecdotal and otherwise, on incidents relating

to food and beverages fraud mainly relating to effects on health. These generally provide little validated

information on the economic effects of this fraud. More in depth research reveals that there is a paucity

of validated retrievable reports on the incidence and trends in the production and sale of counterfeit food

and drink and the resulting health and economic impacts of such fraud. Occasionally investigative

journalists or programme makers commission food fraud surveillance based on intelligence. Internet sites

such as „YouTube‟ can provide access to international news broadcasts on food fraud.

3.3 Retailers

The British Retail Consortium (BRC) is the lead trade association representing the whole range of

retailers, from the large multiples and department stores through to independents, selling a wide

selection of products through centre of town, out of town, rural and virtual stores. The BRC is the

authoritative voice of retail, recognised for its powerful campaigning and influence within government and

as a provider of excellent retail information. The BRC have the financial capability of mounting

intelligence gathering operations to identify which of their products are being counterfeited and where the

production of counterfeit products is taking place.



3.4 Other food authenticity and quality laboratories in the public and private sector

There are a significant number of laboratories involved in the detection of food fraud globally. In

the UK, this includes private laboratories, Public Analysts, university departments and government

agencies. As these facilities are commissioned by a wide range of stakeholders in the food sector they

could be utilised as a useful source of information on categories of food fraud being investigated, without

providing specific information about customers that could compromise confidentiality agreements.

3.5 Consumer groups

Which? is Europe‟s largest consumer rights organisation, with over 700,000 members. The

organisation is independent of Government and industry and funded through the sale of magazines,

books and online services. Which? accepts no advertising, payment or samples from any of the

companies whose products or services they test and consequently are highly respected for their

complete impartiality. The organisation focuses on consumer issues ensuring they are provided with

clear and concise information to make informed choices. This is achieved by reviewing products and

providing independent advice.


Section 4: Levels and trends in food and beverage fraud

4 LEVELS AND TRENDS IN FOOD AND BEVERAGE FRAUD

4.1 National information

4.1.1 Data from the FSA’s Food Fraud Team

Summary information from the FSA‟s National Food Fraud Database (NFFD) and the reported

incidence of food fraud in the UK was extracted and provided for this report. The reported incidence of

food fraud in the UK in between 2007 and 2010, on a monthly basis, is shown in Figure 8.1 below. The

number of incidents is derived from intelligence on known or suspected food fraud supplied by local

authorities, port health authorities, members of the public, industry, other governmental departments and

international contacts of the Food Fraud Team.

Figure 4.1: The reported monthly incidence of food fraud in the UK between 2007 and 2010. The figures are derived from intelligence on known or suspected food fraud supplied by local authorities, port health authorities, members of the public, industry, other governmental departments and international contacts of the Food Fraud Team

The graph appears to show significant increases in food fraud incidence between 2007 and 2010,

but this increase actually reflects the improved reporting of fraud cases and growing awareness of the

FSA‟s food fraud database and its function. In 2009 and 2010 the average levels of reported incidents

are fairly similar and therefore are likely to be a reasonable baseline for reporting subsequent changes in

the incidence of food fraud. The effective capture of food fraud data means that the predicted rise due to

pressure on the food industry brought about by the global economic recession should be evident in 2011

figures and this appears to be the case.



Figure 4.2: A pie chart depicting the relative proportions of different categories of food fraud reported in 2011.

The pie-chart in Figure 8-2 depicts the relative proportions of different categories of food fraud

reported in 2011. There was a significant increase in the total number of reported incidences of food

fraud in 2011 of 1321 cases compared to 908 cases in 2010. The major non-compliance, at 36% of

recorded cases, is counterfeiting that mainly relates to spirit drinks. The next largest category, at 15%, is

illegal importation mainly relating to meat followed by sale of unfit food at 9%. Counterfeiting of spirit

drinks and wine is of major concern to enforcement agencies and the drinks industry. The selling of

counterfeit spirits has a major impact on sales of genuine products and the tax revenue generated from

them. It also impacts on brand reputation and may cause long-term effects on genuine product sales.

One notable case was the nationwide distribution of the counterfeit Spar Imperial Vodka. Intelligence

produced using the Food Standards Agency‟s national Food Fraud Database, led to the raid of a self-

storage warehouse in the London Borough of Haringey (FSA, 2008). The raid found hundreds of bottles

of counterfeit Spar Imperial Vodka, other illegal wines and spirits, and sheets of counterfeit customs duty

stamps. The Vodka was found to contain potentially harmful levels of methanol. This highlights the

danger of poor quality counterfeit spirits that can lead to serious health effects, including blindness, if

consumed in large quantities. The counterfeit vodka manufacture and distribution was operated by

Sisecam Ltd and run by Mr Ahmet Turgut Oztas. He was sentenced to a 9-month suspended sentence,

with 200 hours unpaid work to be completed within 12 months or he would have to serve his prison

sentence. He was also ordered to pay £2000 by way of forfeiture towards the London Borough of

Haringey for the council‟s investigation work, plus a further £2000 towards legal costs.

4.1.2 The UK Food Surveillance system (UKFSS)

At a high level, the UKFSS splits into several categories such as “Chemical” and “Microbiological”

and by “Country”, and by “satisfactory/unsatisfactory”. The country can then be split into county and

individual cities. Some care had to be taken when using high level summaries. For example, a food that



had been sampled because of concerns over mycotoxins, might pass the chemical test for mycotoxins

but still fail for because of a labelling issue. The sample would then be recorded at a high level as a

“mycotoxin failure”. However the system permits a review of the original statement which will give full

information about the sample, why it was taken and the results of any findings. Closer examination of the

database therefore allows the reason for failure to be determined via the table of failcodes/outcomes.

The UKFSS contains a standardised list of food categories in “outcomes” tables. Some of these

are clearly of relevance to food authenticity issues e.g. “substitution”, which is further divided into fish,

meat, plant and other. A similar argument applies to the “labelling”. Category and others may be relevant

e.g. “radioactivity”, and “constituents”. Whilst the “fail code” indicates why a sample was found

unsatisfactory, e.g. too much or too little of something, a more valuable approach may be to consider the

“Det” tables. An example for a useful search which could be undertaken is “meat identification” which

gives as an example a lamb curry which actually contained beef. Different “Det” levels are available (1-

4), which provides an ever increasing level of detail. The structure includes setting the type of food, the

place, the food test and the authority.

The Det codes were examined in more detail using fish Identification issues in 2009 as an

example. At a summary level, it was straight forward to determine the number of times a year that fish

identification had been an issue for Local Authority‟s enforcement officers and hence obtain trend

information over time. The reason why there was an increase in fish identification issues in 2009 was

open to speculation – was it number of tests performed? Was there a coordinated surveillance exercise?

was it a result of the availability of easy to use lab-on-chip DNA technology, which has been widely

implemented in public analyst laboratories? Consequently, some background information is required to

interpret trend information recovered from the UKFSS. The exercise demonstrated that the Det tables

were likely to be particularly valuable in identifying “authenticity” issues and trends. The following DET

level 1 categories are relevant to food authenticity and labelling: Fat, fatty acids, Fish identification,

GMO, irradiated foods, labelling, meat content, meat identification and plant identification. Other DET

level 1 categories of possible interest to authenticity/labelling are Carbohydrate, Protein and Sterols.

4.2 Information from the European Union

The EU is the second largest economy (GDP 2009: € 12,256.48 billion) in the world after the US. It

is the only economy where there is some transparency in the statistics relating to food and beverages

fraud for internationally traded goods. Internal food and beverage fraud, where the illegal products do not

cross national boundaries, is much less transparent, and in some EU Member States, invisible. The

official statistics cover detection at EU borders by the customs agencies and so fraud occurring within

national boundaries such as the example of “tipping” above, or home produced alcoholic beverages, will

not be represented in the national statistics and which do not, therefore represent a true picture of the

extent of food and beverage fraud within the EU.

The importance of local production of counterfeit goods was emphasised in an OECD survey

(OECD, 2008). A major spirits producer considered that the distribution and sale of counterfeit branded

spirits was largely localised within national boundaries in which the counterfeiters sell directly to local

liquor outlets and bars. This avoids the problems and risks associated with crossing national borders

where customs authorities would be likely to be more vigilant when dealing with high value spirits subject

to high taxes.



EU customs statistics also give no information on the value of the fraud which includes loss of

revenue to the brand owner, loss of tax revenue to the state and loss of value and possibly adverse

health effects (with additional financial and social costs) to the consumer. These can be substantial,

particularly when adverse health effects caused by addition of poisonous substances (methanol in

alcoholic drinks, melamine in milk products) or omission of essential nutrients (e.g. substitution of corn

syrup for orange juice), are involved. Local statistics are at best fragmented, may be absent altogether in

some areas and trends cannot be observed due to failure to hold data on local, regional or national

databases.

There are often no uniform methods of counting or recording cases of food fraud and this is

exacerbated by the lack of an agreed terminology for different types of fraud either within the EU or

between the EU and third countries. Thus interceptions of smuggled cigarettes into the EU have

variously been counted on the basis of individual cigarettes, packets of cigarettes or packs containing

multiple boxes of cigarettes. In other cases, the shipping container has been used as a unit for recording

the quantity of counterfeit goods.

4.2.1 Information from EU customs seizures

Figures 8.3 and 8.4 respectively show annual statistics on the number of cases (Figure 8.3) and

number of seizures (Figure 8.4) of food and beverage products at EU borders. The number of cases

represents administrative actions as well as prosecutions resulting from complaints by rights holder for all

categories of fraud relating to food and drink. The number of seizures will be distorted from year to year

by different conventions on counting categories of products both nationally and supra-nationally.

Distortions are also likely when a low number of seizures involve large quantities of a single product in

any one year or when fluctuations in the cross border trade in a particular commodity increase or

decrease the likelihood of detection of counterfeit goods. This is evident in figures 1 and 2.

The number of customs administrative and legal cases relating to food and drinks detentions has

increased progressively from 2000-2008 with an 8-fold increase over the period. It is not clear whether

this is an indication of increased levels of trade in counterfeit food and drink products, an overall increase

in the level of trade within this sector or increased customs or right holder vigilance in identifying

counterfeit products.

Figure 4.3: EU Customs seizures 2000-2008: No. cases (EC Taxud 2000-2008)



The upward trend in the number of cases is not apparent when the fraudulent activity is expressed

in terms of the number of articles seized (figure 2). The likely reasons for this have been referred to

above.

Difficulty in retrieving information on the total volumes of trade in food and beverages across EU

borders and the value of this trade makes estimating the economic costs of the trade in counterfeit

products problematic.

Figure 4.4: EU Customs seizures 2000-2008: No. articles (millions) (EC Taxud 2000-2008)

Products traded illegally range from high value alcoholic beverages to relatively low value tea and

milk products. It is likely, therefore, that to obtain meaningful figures, it would be necessary to make

estimates of the value of the fraud estimated on a product-by-product basis, with financial information

provided by the rightholders. In this way, it would be possible to clarify trends in trade of counterfeit

products, and the associated costs of this trade for different product categories.

The counterfeit problem in cross border trade in relation to food and beverages is insignificant

when compared with the levels of counterfeiting in other product categories. Thus cases relating to

counterfeit food and drink products in the nine-year period from 2000 to 2008 averaged only 0.2% of the

total caseload of all counterfeit goods, whilst the number of counterfeit food and drinks products seized

represented less than 3% of the total counterfeit products seized.

4.2.2 European Anti-Fraud Office (OLAF)

The European Commission publishes a statistical summary of OLAFs activities and the detected

levels of fraud relating to all aspects trade (EC 2010a), which accompanies the Report from the

Commission to the Council and the European Parliament (EC 2010b). The areas of trade most affected

by fraud and irregularities in 2009, as in previous years, were TVs/monitors etc. (CN 85), Clothing (CN

61) and Tobacco products (CN 24). Cars/motors (CN 87) increased in importance when compared to

2008, as did Food (CN 16), Chemical products (CN 29) and Articles of iron and steel (CN 73)29. (See

Table 8.1 below).



Frauds relating to Meat, vegetables and food were in the „top-ten‟ chapter headings for 2007, 2008

and 2010. In 2009 the number of fraud cases relating to Food (CN16) totalled 86 with a value of

€12,747,855.

Table 4.1: Fraud and irregularities: ‘Top Ten’ chapter headings in 2007, 2008 and 2009 [reproduced from reference EC 2010a]

4.2.3 Origin of counterfeit food and drinks products entering the EU

The report on the Statistical Evaluation of Irregularities in the EU also provides an evaluation of the

geographical origin of ALL goods subject to fraud and irregularity. As in 2008, goods originating from

China, the US, Japan, South Korea and Bangladesh remain highly affected. Furthermore, the number of

fraud cases originating from Hong Kong, Vietnam and Argentina increased.

Table 4.2: Fraud and irregularities: breakdown by origin of goods [reproduced from reference EC 2010a]

.

Information specifically on the geographical origin of counterfeit food and beverages can be

obtained from EC TAXUD annual reports on customs seizures (EC Taxud 2000-2008). These reports

provide data on the basis of number of articles seized but information on the category of food or drink is

not routinely specified. Information on origin is derived from counts on the numbers of articles seized and

will likely be misleading for the same reasons reported for fluctuating annual counts of articles seized.

Nevertheless, some countries appear prominent as sources of counterfeit food and beverages on a

recurring basis. Thus Turkey is reported as the source of the greatest proportion of counterfeit food and



drink products five times out of the past nine years contributing from 20-46% of all counterfeit food and

drink seized by EU customs in those years. China is the only other country to feature prominently in the

customs figures from 2000-2008, appearing in the top eight sources of counterfeit products six times

over the nine-year period.

Table 4.3: Ranking of countries of origin of counterfeit food and beverages seized at EU borders 2000-2008 (EC Taxud 2000-2008).

4.2.4 Directorate General for Competition policy, Consumer Affairs and Fraud Control (DGCCRF).

An overview of the operations of this French Directorate. DG CCRF works closely with the OFT in

the UK. They have a specialist team dedicated to investigating internet trade. They evaluate the impact

of investigations to see if they result in changed behaviours.

4.2.5 Eurostats Comext database

Eurostat‟s Comext database reports trade statistics of product mobility between Member States of

the European Union and between Member States and third countries. At an international level, the

United Nations, through the Comtrade database, reports trade data from its member countries. This

report describes the definitions and the methodology used in these two international trade statistics, with

a view to understanding the reasons for discrepancies. Five case studies of trade data for selected food

commodities (i.e. frozen shrimps and prawns, fresh or chilled mackerel, cereals, live swine and intra-EU

trade) were examined in order to assess the potential of trade data for identifying emerging risks. The

Eurostat Comext database has been found to be a tool that could assist in the identification of emerging

risks in combination with data coming from other sources, including the Comtrade database. Expert

judgment is pivotal for selecting the most appropriate food commodities during a search, interpretation

and evaluation of the weaknesses of trade data, as well as their relevance to data from other sources.

Recommendations are made for the requirements of a system covering EFSA‟s mandate for automatic

scanning of the Eurostat Comext database. Such a system should provide alerts to the users, indicating

for example i) significant increase of the volume of a given product over time to a specific MS or EU in

total ii) new trade partners iii) new food or feed commodities entering the EU.

Source of counterfeit food and beverages (%of total) 2000-2008 Ranking/

Year 2000 2001 2002 2003 2004 2005 2006 2007 2008

1 Turkey

(20%)

Turkey

(33%)

China

(20%)

Chile

(18%)

India

(65%)

Turkey

(16%)

Turkey

(18%)

Turkey

(46%)

Indonesia

(51%)

2 Poland

(20%)

China

(17%)

Thailand

(20%)

Poland

(18%)

Philippines

(21%)

Ukraine

(10%)

Hungary

(7%)

China

(37%)

UAE

(26%)

3 China

(10%)

Africa

(11%)

Chile

(10%)

Turkey

(18%)

Tunisia

(4%)

Russia

(12%)

Tunisia

(6%)

Georgia

(3%)

Turkey

(6%)

4 Czech

Rep.

(10%)

Portugal

(11%)

Greece

(10%)

Ukrain

e

(12%)

Turkey

(3%)

China

(8%)

Singapore

(12%)

Other

(14%)

Morocco

(3%)

5 Japan

(10%)

Thailand

(11%)

Hong

Kong

(10%)

China

(6%) Other (7%)

Indonesia

(6%)

Other

(57%)

Other

(14%)

6 Lithuania

(10%)

Other

(17%)

Indonesia

(10%)

Egypt

(6%)

Other

(34%)

7 Spain

(10%)

Iran

(10%)

Spain

(6%)

8 Other

(10%)

Turkey

(10%)

Other

(16%)



4.2.6 European Rapid Alert System for Food and Feed (RASFF)2

RASFF is the Rapid Alert System for Food and Feed and was implemented to provide Member

State food and feed control authorities, such as the Food Standards Agency in the UK, with an effective

tool to exchange information about measures taken responding to serious risks detected in relation to

food or feed (RASFF 2010). This exchange of information helps Member States to act more rapidly in

response to a health threat caused by food or feed and in a coordinated manner.

Member States are required to inform the Commission if they withdraw or recall food or feed

products from their domestic markets in order to protect consumers‟ health and if rapid action is required.

They also have to notify the Commission if they agreed with a responsible operator that a food or feed

should not be placed on the market if the measure is taken on account of a serious risk to human or

animal health. The Commission immediately transmits the notification to all members of the network.

On a European level the RASFF information is generally derived from food or feed inspectors that

have investigated a product on the market or at the border. If it is found that a product is non-complaint

and needs to be reported inside the national system, the designated National authority decides if the

issue falls under the scope of the RASFF and reports it to the national RASFF contact point. The national

contact point verifies and completes the RASFF notification where necessary and forwards it to the

European Commission. It uses a RASFF notification form to provide details of the findings and measures

taken and adds relevant documents such as bills, lists of companies having received the products,

analytical reports, etc. Templates are used to collect all information on the RASFF notification form. The

diagram below (Figure 8.4) shows the flow of information in the RASFF.

Figure 4.5: EU – a schematic diagram showing the flow of information in the European Rapid Alert System for Food and Feed (reproduced fron the RASFF website http://ec.europa.eu/food/food/rapidalert/about_rasff_en.htm# accessed January 2011

Searching on subject „fraud‟ produced 100 results, mainly false health declarations, expiry dates

changed, specified risk material, illegal imports (falsified origin) e.g. suspicion of illegal import (possibly

2 https://webgate.ec.europa.eu/rasff-window/portal/

http://ec.europa.eu/food/food/rapidalert/about_rasff_en.htm

https://webgate.ec.europa.eu/rasff-window/portal/



fraudulent CVED documents) of bovine meat allegedly from Argentina and Brazil, via the United States

and via Bulgaria. Searching on subject „adulteration‟ produces 10 hits relating to addition of cheap

sources of sugar to honey, addition of synthetic acetic acid to balsamic vinegar and ammonium sulphate

to increase the apparent protein content of animal feed. Searching on „hazard category‟

adulteration/fraud is also possible but produces the same set of results.

4.2.7 Categories of food and beverage products seized by EU customs

Information from annual customs reports on the type of foods and beverage product seized as a

result of contravening intellectual property rights is fragmentary and incomplete. Product types are not

recorded in reports from 2005 onwards. This probably reflects the relative low levels of food and

beverages seizures compared with seizures of other products which, in turn, reflects the relative low level

of food and beverage fraud relative to fraud in relation to higher value products. Mis categorization is also

apparent in the figure in some years with Nike, Nintendo and Disney products erroneously included in the

data for food and beverage products.

The most commonly seized products are high value alcoholic beverages, particularly vodka and

whisky followed by products from multinationals producing products with well known, highly valued

trademarks.

A sanitised summary of the categories of food and drink products seized retrieved from EU

customs databases are given in Figure 8.4. These are indicative only and incomplete, but provide an

overview of the types of product in this sector which are commonly the object of fraudulent activity.

Table 4.4: Category of product type or producer ranked as percentage of total seizures 2000-2004 (adapted from EC TAXUD 2000-2004)

* Disney and Nintendo products included as categories of food and drink in 2000 and 2001

4.2.8 European Union’s Joint Research Centre (DG- JRC, Ispra, Italy)

The JRC role is to carry out cutting edge research where a high degree of innovation is key

requisite. They are also very active in networking across Europe with other research laboratories and

have a role in disseminating information to member states through various mechanisms‟ (e.g.

publications and conferences). One important mechanism is the network of customs laboratories from

member states and providing advice and support to OLAF when requested.

JRC used to have relatively close links with OLAF but these have not been maintained. JRC has

requested information from OLAF regarding any concerns they have over food fraud so that JRC can

develop relevant methods for enforcers. However, this approach has not produced the required dialogue.

Some of the food fraud issues that OLAF addresses are relatively straightforward, such as evasion of

duty payment on garlic from china by describing them as apples (Operation Wasabi, 2008).

Ranking/

Year 2000 2001 2002 2003 2004

1 Alcohol

(40%)

Guiness

(11%)

Alcohol

(67%)

Alcohol

(74%)

Alcohol

(21%)

2 Coca Cola

(10%)

Azol de

Extremadura

(11%)

BNIC

(17%)

Wrigley’s

gum(15%)

Coca Cola

(13%)

3 Confectionary

(10%)

Ferrero

(6%)

Other

(16%)

Coca Cola

(5%) Nestle (13%)

4 *Other (40%)

Nestle

(6%) Apples (5%)

Confectionary

(6%)

5

*Other (66%)

Other

(1%) Knorr (4%)

6 Other (43%)



JRC does have a close relationship with EU customs laboratories. An example of their work was

an investigation regarding grape alcohol being sold to the USA. The shipments were regularly diverted

to the Caribbean for „technical reasons‟. Isotopic testing of the alcohol arriving in the U.S.A revealed that

the alcohol was derived from a different source than that leaving Europe. Cane alcohol was being

substituted and shipped from the Caribbean and the original grape alcohol returned to Europe for

reshipment. This 11MEuro fraud was uncovered using isotopic testing.

It is unclear how OLAF identifies which food fraud issues to investigate. However, we can

speculate that it is from import/export statistics. OLAF is good at harmonising common operations but is

very operationally focussed. This enables it to work well with customs laboratories. However, OLAF is

not always fully aware of the latest operational tools. They are not knowledgeable about recent analytical

advance in food fraud detection and tend to choose their support laboratories based on previous

experience as OLAF tend to work on the same issues for a number of years e.g. garlic, honey,

cigarettes.

The JRC has suggested that a network of competence for analytical techniques is required.

Customs laboratories tend to perform routine analysis and need other research laboratories to develop

and validate new methods. They also need others to define the problem and decide what can be done

about it. Dr Claude Guilliou of the JRC chairs a scientific committee for a network of customs

laboratories. The customs laboratories do very little coordinated research and development of methods

but this network provides a structure for cross European coordination of action. Customs laboratories are

useful because they are appointed organisation so it is easy for them to work together but they are also

limited by being tied by National issues. As the network of Customs laboratories is not an „official layer‟,

it is difficult for the European Commission to interact with them. Whereas, for wine, there is a network of

competent labs. It has been suggested that OLAF and JRC should coordinate the identification of which

food fraud questions need to be asked and share with a network of laboratories that can conduct the

necessary research and development to generate relevant methods. In effect the JRC could act as an

interface between research and operational activities within customs. DG JRC are keen to be involved

and perhaps lead an international coordination activity for the dissemination of information concerning

food frauds that are underway and the methods to be used to detect them.

4.2.9 European Food control laboratories

There are a number of government and private laboratories actively involved in the detection of

food adulteration throughout the European Union. The following laboratories have given an indication of

some of the commodities they have been investigating in 2010.

4.2.9.1 Eurofins Scientific (France)

The authenticity of fruit juice continues to be an issue in European and international markets.

Concerns are often associated with juices of high value such as pomegranate because of purported

health benefits. In preliminary laboratory research and clinical trials, juice of the pomegranate may be

effective in reducing heart disease risk factors, including LDL oxidation, macrophage oxidative status,

and foam cell formation (Kaplan et al., 2001; Aviram et al., 2004; Esmaillzadeh et al., 2004). The graph

below (Figure 8.5) represents the percentage of non-compliant juices tested by Eurofins Scientific

(Nantes) in 2010 (Dumoulin, 2011). However, it should be noted that this graph does not represent the

incidence of fraud in the retail market as these results are from samples that were selected for analysis



because of suspicion about authenticity by traders, retailers etc. A typical non-compliance for

pomegranate would be the undeclared addition of water that has arisen through „washing‟ the pressed

fruits to aid extraction of the juice.

Figure 4.6: Percentage of non-compliant juices tested by Eurofins Scientic (Nantes) in 2010. This graph does not represent the incidence of fraud in the retail market as these results are from samples that were selected for analysis because of suspicion about authenticity by traders, retailers. Data provided by through personal communication - Dumoulin (2011).

4.2.9.2 German authenticity control laboratory (Anon.)

The following is an account of adulteration issues tackled by a leading German food authenticity

control laboratory in 2010. There have been several incidences of adulteration of Eastern European

brandies with ethanol derived from maize and/or cane (C4-plants). These products are sold in Germany

through "Russian" food shops. Adulteration of sweet wines from South-eastern European countries (e.g.

Croatia, Serbia, Slovenia and Macedonia) by addition of cane or corn plant sugars. Industrially

produces citric acid has been used to adulterate lemon juice concentrates and water has been added to

exotic fruit juices such as pomegranate juice. The geographical origin of eggs has been mislabelled and

so too has the origin of vegetables and fruits e.g. tomatoes. The production origin of vegetables and

fruits has also been mislabelled e.g. conventionally cultivated described as organic to obtain higher

market prices e.g. sweet peppers, cauliflower and broccoli. Industrially produced vanillin has been used

and described as natural vanilla from beans in ice cream and dairy products such as yoghurt. The

German laboratory anticipates that adulteration of wine will be on the increase again due to poor grape

harvests for the 2010 vintage in Italy and Germany.

4.2.9.3 Fondazione Edmund Mach-Istituto Agrario di San Michele all'Adige (ISMAA, IT)

The Istituto Agrario San Michele promotes and carries out research, scientific experiments,

education and training activities as well as providing technical assistance and services to private

companies. It has an active food research and innovation centre that develops methodology and carries



out surveillance on food adulteration and mis-description. IASMAA collaborates with the Italian Anti fraud

Department of the Ministry of Food, Agriculture and Forestry. Their report for 2010 is not available but

the following frauds were detected in 2009. Fifteen separate incidences of wine adulteration were

detected. These wines were declared non-authentic because they contained added sugar, water or

industrial carbon dioxide and the producers were successfully prosecuted. Two samples of fresh passata

(puréed and sieved tomato) were found to be illegally produced from diluted tomato and a PDO olive oil

substituted with an oil of inferior quality from a different Italian region.

4.2.9.4 Austrian Institute of Technology (AIT)

The Austrian Institute of Technology (AIT) is Austria's largest non-university research institute and

an application-oriented research and development company, employing more than 850 people in various

locations across Austria. The centre in Tulln hosts the Health & Environment Department, which

conducts research and surveillance in food authentication. In 2010, they have conducted investigations

into the geographical origin of lemons, eggs, saffron spice, wine, vegetable oil and the adulteration of

honey.

4.3 Information from International sources

Food fraud is a global problem and consequently, is taken seriously by the relevant National

Government Departments and international organisations around the world. The World Customs

Organisation (WCO) estimated 5-7% global trade in counterfeit products in 2004 ($512billion). Of this

figure it was estimated that approximately $49 billion was accounted for by counterfeit food and

beverages. The following sections are a short account of the economic adulteration issues in food

supplies affecting the United States of America, Canada, New Zealand, Brazil, Argentina and Thailand.

4.3.1 Organisation for Economic Co-operation and Development (OECD)

According to a 2007 report from the Organisation for Economic Co-operation and Development

(OECD), fruit such as kiwis, conserved vegetables, milk powder, butter, ghee, baby food, instant coffee,

alcohol, drinks, confectionary, and hi-breed corn seeds are some of the most faked food and drink items.

The OECD report found that alcohol products are the prime targets for counterfeiters in the drinks sector,

both because of their brand value and the high tax and excise component of the final price. the OECD

report noted that counterfeiters are becoming more nimble in responding to these technical solutions,

emphasising that counterfeiters were being aided and abetted in this by ever improving and cheaper

manufacturing, computing and printing technology.

4.3.2 Greg Noonan (Food and Drug Administration, USA) - Authenticity in Food, US Perspective3

Enforcement of food authentication in the United States of America is undertaken through the

Federal Food, Drug, and Cosmetic Act (FD&C Act, 2005). Adulteration issues which have affected the

U.S are the adulteration (addition of water, exogenous sugars, colours and fruit acids to pomegranate

juice, lemon juice, orange juice and apple juice. The substitution of fin fish with other species is also a

recurring problem. The addition of sweeteners such as high fructose corn syrup and sorghum syrup to

honey and maple syrup is also of on-going concern.

3 IAM/ MoniQA Workshop, Budapest, Hungary, Methods for Food Identification and Authenticity-Characterizing the Unknown, 6 March 2011



4.3.3 The Anti-Counterfeiting and Product Protection Program (A-CAPPP) Michigan State University

(USA)

Michigan State University created the first academic body focusing upon the complex strategic

global aspects of anti-counterfeiting and product protection of all products, across all industries, in all

markets and strategies to work effectively to detect, deter, and respond to the crime. Their goal is to

serve as an international hub for evidence-based anti-counterfeit and product protection strategy.

In 2009, Dr. John Spink, Associate Director of A-CAPPP and Assistant Professor in the School of

Criminal Justice received a US Department of Homeland Security grant through the National Centre for

Food Protection and Defence (NCFPD) for a project Defining the Public Health Threat of Food Fraud.

This was the first scholarly report to define the term and provide a rigorous review of the public health

threat. The outcome has been well received and has been implemented by agencies. This project

defined food fraud as an autonomous concept to be included with food quality, food safety, and food

defence.

A key of the food risk matrix is shifting a focus to the motivations or causes of the fraud and not

just on intervention and response. The fraudster is a human actor seeking economic gain, which is much

different than countermeasures or motivations in food safety and food defence. The report deconstructs

the food fraud opportunity using the time tested criminology concept of the “crime triangle” which

includes factors of victim, fraudster, and guardian gap. As the causes of the fraud are considered for

each factor, countermeasures can be identified that will not only detect, but deter the fraud vulnerability

in the first place. With his co-author, Douglas C Moyer, the report was published in 2011 by the NCFPD

and in a Journal of Food Safety article (In Press, 2011).

Other objectives and aspects of the A-CAPPP include the provision of scholarly, analytical,

conceptual, and scientific leadership in combating product counterfeiting that impacts public health and

safety, businesses and economies, the environment, and national security. The A-CAPPP has a portfolio

consisting of high-impact research projects defining the dialogue in academic, corporate and policy

circles in areas such as risk, standards, and governance; scale and externalities; consumers;

perpetrators; prevention and enforcement; and processes of anti-counterfeiting and product protection. It

also provides training and technical assistance, learning opportunities, online classes, consultations, and

facilitation of public/private organizational and collaborative interdisciplinary programs in the emerging

area of anti-counterfeiting strategy. The program focuses upon consumer packaged products in a variety

of industries and sectors including, but not limited to, pharmaceutical, healthcare, food, beverage,

automobile, and consumer electronics.

4.3.4 Stan Bacler (Canadian Food Inspection Agency, CFIA) - Food Authenticity Testing Activities4

Canada has a significant commitment to its food authentication programme. CFIA routinely caries

out surveillance of domestic and imported products. Canada is a major producer of Maple syrup and it is

relatively expensive product (£16/kg). Maple syrup has a naturally high sucrose content and so there is

potential for addition of other cheaper sources of sucrose. CFIA routine testing includes sugar profiling

4 IAM/ MoniQA Workshop, Budapest, Hungary, Methods for Food Identification and Authenticity-Characterizing the Unknown, 6 March 2011



and Isotope Ratio Mass Spectrometry, eg. Detection of cane or corn sugars, retrograde sugar by-

products of refined sugar. In addition CFIA routinely tests imported honey, fruit juices (e.g. orange,

apple, grape, grapefruit, pear, lemon, lime, and pomegranate juice), vegetable oils (olive, pomace,

Sesame, almond, hazelnut, and walnut) and chocolate (for cocoa butter substitutes). Additional, testing

includes spices, flavours (vanilla extract), Tonka beans (contain coumarin, a potential health risk), meat

and fish species. There was also concern in Canada regarding the addition of hydrolysed leather protein

to milk. There is also interest in geographical origin verification interest particularly for Canadian ice wine

exports.

4.3.5 Dr Paul Dansted (New Zealand Ministry of Agriculture and Forestry NZ-MAF) - Food Assurance

Programmes

Domestic food fair-trading is primarily regulated through civil law and commerce legislation. The

NZ-MAF has an interest in ensuring NZ‟s reputation as a trusted supplier of food is earned and

protected. NZ rely on traceability systems to verify origin, but testing as fallback, with appropriate

sampling plans.

4.3.6 Shirley Abrantes (Brazilian National Institute of Quality Control in Health, INCQS) - Authenticity

in food – what does this mean to Brazil?2

Brazil utilises a number of official methods to monitor the quality of its own food products. For

example, Soybean oil Fatty acid composition (AOCS CE 1-91 GC); added water in meat (EC Official

Journal, 1993); gravimetric Sugar Sucrose content (AOAC 925.46); direct polarimetric determination of

coffee starch granules (AOAC, 98, 16 Vol II, 1995); detection of added cane sugar/corn syrup to orange

juice by carbon isotope analysis (AOAC 982.21); honey hydroxy methylfurfural (IFU method nº 69, 1996)

and milk glycomacropeptide determination by size exclusion HPLC (MAPA Port. 124).

4.3.7 Veronica Torres Leedham (National Health Service and Agri-Food Quality, SENASA) -

Authenticity in food – what does this mean to Argentina?2

SENASA undertakes routine authenticity testing of a number of products, such as the presence of

soy protein in meat products; the identification of species of animal origin in meat products; dextrin in

honey (adulteration with syrup); sucrose in honey, fatty acid profiles in vegetable oil; identity and purity of

food additives. SENASA employs several analytical techniques including microscopy, histology and

immunological techniques, DNA analysis, HPLC and GC.

4.3.8 Wongkwan Jitnupong (National Health Service and Agri-Food Quality, SENASA) - Authenticity

in Food – what does this mean in regional perspective?

FVM-Ku routinely monitors the authenticity of meat species in cooked products using ELISA and

DNA based methods. Although, Islam is a minority faith in Thailand, food products are tested in

accordance with Halaal regulations for the presence of pork.



4.3.9 Isoforensics (USA)

IsoForensics Inc. of Salt Lake City, Utah, USA (isoforensics.com) is a small analytical services and

region-of-origin modelling company that has primarily been addressing needs in the intelligence and law

enforcement communities. Founded in 2003, the basis of the company is the pioneering research on

stable isotope analyses at natural abundance level in the environment by Professors Thure Cerling and

James Ehleringer at the University of Utah. Some members left the university research environment to

continue application opportunities in a more closed environment. Employees conduct mission-focused

research addressing fundamental questions about authenticity, origins, and quality determination. As part

of this effort, the company analyzes the stable isotope ratios of a variety of materials in order to aid

forensic investigations.

IsoForensics Inc. routinely assists law enforcement agencies and organizations with

determinations of regions-of-origins of unidentified murder victims, with testing adulteration and

substitution in regulated products, and with verifying food and commodity origin claims. The company

currently offers high quality analyses including fruit juice verification, food adulteration testing,

pharmaceutical authentication, and water source and quality testing. IsoForensics Inc. is also actively

involved in determining the local, regional, and imported regions-of-origin of a variety of materials

including waters, juices, milk, and other beverages; meats; wools, cotton, and other fibres; and regulated

animals and animal products. In the past year, the company has analyzed honey and olive oils as well as

several types of not-from-concentrate and reconstituted juices.

4.4 Media

4.4.1 Television broadcasts

In the majority of cases media coverage of food fraud incidents is in response to press releases

from the FSA or local area Trading Standards investigations. Occasionally, investigative programmes do

provide original information about food mis-description, adulteration or substitution. These investigative

pieces may be in response to consumer concerns, industry tip-offs or may be curiosity driven. For

example, In December 2010 the BBC‟s Panorama programme commissioned the analysis of the origin of

pork in sausages that were labelled as British. The investigation revealed that the pork was not British in

one of the retail samples analysed. The results of such investigations could result in further action by

being required by enforcement authorities to assess the extent of the problem.

4.4.2 Internet

Internet sites such as YouTube provide access to international news on food fraud. For example,

American Channel 5 WPTV news details the Food and Drug Administration (FDA) and the Custom‟s and

Border Protection (CBP) activities to control food fraud. Only 1% of the 11 million products imported into

the U.S. every year are routinely tested for economic adulteration (YouTube 2011).

4.5 Trade press

Food Quality News is dedicated to publishing breaking International news on food safety and

quality control and as such provides a useful source of world-wide information that could be used for

horizon scanning. The on-line publication regularly covers food authenticity, origin and fraud cases. For



example, the use of stable isotope data to verify the regional origin of American milk supplies and

differentiate between Organic and conventional milk (Food Quality News, 2010). Food Quality News

accesses published scientific data, communications and interviews from around the world, such as

European Spirits Organisation, concerns over the significant number of fake spirits sold in China posing

a severe risk to the health of the country's consumers as well as the industry's profits (Food Quality

News, 2007).

4.6 Consumer groups

4.6.1 Which?

The consumer rights organisation, “Which?” does not follow a formal strategy to identify sources of

food fraud or mis-description. However, Which? occasionally targets food fraud as a specific area of

concern for its magazine or other reports. It is an issue that Which? regularly identifies as part of their on-

going work. There are several ways that Which? becomes aware of issues of food fraud or mis-

description, including:

- Direct contact with Trading Standards Officers or Public Analysts who alert Which? of issues to

investigate (Which? have held meetings with TSO and PAs specifically for this purpose).

- Contact with counterparts in other countries who may highlight areas that they are working on,

which have implications for UK consumers.

- Investigations or testing projects that that Which? undertake or commission highlighting problems

such as inaccurate or misleading labelling for example.

- Information provided by members who may contact Which? with problems that they have

identified.

- Joint testing projects with other consumer organisations (eg. through International Consumer

Research and Testing who are based at Which?)

4.7 Trade Associations

4.7.1 Grocery Manufacturers Association (GMA)

The United State‟s Grocery Manufacturer‟s Association published a report in 2010, in collaboration

with a global consulting firm A T Kearney, entitled “Consumer Product Fraud: Deterrence and Detection”.

The major findings were that greater collaboration and information sharing could help the food industry

tackle food fraud. As a consequence industry could save $50m-$80m a year by sharing supplier audits,

and suggested that although leading companies already share information on an informal basis, they

could collaborate on many more levels.

The report also suggested that the food industry could follow the example of the pharmaceutical

industry in the U.S. for instance, which has a consortium involving biotech and pharmaceutical

manufacturers and suppliers to facilitate information sharing. In the same way, the food industry could

establish a clearinghouse of suppliers, collaborate to create monograph standards for ingredients –

which can be a prohibitively expensive process when companies aim to develop their own set of

ingredient standards – and develop a shared library of reference samples.



4.8 References

Aviram M, Rosenblat M, Gaitini D, et al. (June 2004). "Pomegranate juice consumption for 3 years by patients with carotid artery stenosis reduces common carotid intima-media thickness, blood pressure and LDL oxidation". Clin Nutr 23 (3): 423–33. doi:10.1016/j.clnu.2003.10.002. PMID 15158307.

Dumoulin Marcel (2011) Results from a presentation made at the IAEA in Vienna, April 2011.

EC 2010a – COMMISSION STAFF WORKING DOCUMENT; “Statistical Evaluation of Irregularities- Own Resources, Agriculture, Cohesion Policy, Pre-Accession Funds and Direct Expenditure -Year 2009”, Brussels, 14.7.2010, SEC(2010) 898 final.

EC2010b – REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT; “Protection of the European Union's financial interests-Fight against fraud-Annual Report 2009”; Brussels, 14.7.2010, COM(2010)382 final.

EC Taxud 2000-2008 - EC Taxation and Customs Union

Esmaillzadeh A, Tahbaz F, Gaieni I, Alavi-Majd H, Azadbakht L (2004). "Concentrated pomegranate juice improves lipid profiles in diabetic patients with hyperlipidemia". J Med Food 7 (3): 305–8. doi:10.1089/1096620041938623. PMID 15383223.

FD&C Act (2205) http://www.fda.gov/RegulatoryInformation/Legislation/FederalFoodDrugandCosmeticActFDCAct/default.htm Accessed 15

th February 2011

Food Standards Agency (2008) Fraud database leads to vodka raid http://www.food.gov.uk/news/newsarchive/2008/sep/vod Accessed January 2011

Food Quality News (2007) Spirits group calls for Chinese counterfeit crackdown By Neil Merrett, 27-Nov-2007

Food Quality News (2010) Goodbye milk fraud, hello origin tracking by Jane Byrne , 23-Apr-2010

Kaplan M, Hayek T, Raz A, et al. (1 August 2001). "Pomegranate juice supplementation to atherosclerotic mice reduces macrophage lipid peroxidation, cellular cholesterol accumulation and development of atherosclerosis". J Nutr. 131 (8): 2082–9. PMID 11481398. http://jn.nutrition.org/cgi/pmidlookup?view=long&pmid=11481398.

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001R2065:EN:HTML Source: Miller, D.D. & Mariani, S. (2010) Smoke, mirrors, and mislabeled cod: poor transparency in the European seafood industry. Frontiers in Ecology and the Environment. 8: 517-521 Accessed 15

th February 2011

Operation Wasabi (2008) http://ec.europa.eu/anti_fraud/wasabi/i_en.html accessed March 2011

RASFF 2010 - http://ec.europa.eu/food/food/rapidalert/about_rasff_en.htm# accessed January 2011

YouTube 2011 - http://www.youtube.com/watch?v=lpGFfzPvWOU accessed January 2011

http://www.fda.gov/RegulatoryInformation/Legislation/FederalFoodDrugandCosmeticActFDCAct/default.htm

http://www.food.gov.uk/news/newsarchive/2008/sep/vod

http://ec.europa.eu/anti_fraud/wasabi/i_en.html

http://ec.europa.eu/food/food/rapidalert/about_rasff_en.htm

http://www.youtube.com/watch?v=lpGFfzPvWOU


Section 5: Other areas

5 OTHER AREAS

5.1 Categories of food and beverage products identified from other sources

Information on categories of food and drink from other sources is not easily retrievable because

information on the levels of fraud are combined with other product categories because of the relatively

low incidence and specific food and drink products are not always listed in annual reports of customs and

other government organisations. In addition, the problem of lack of agreement on the definition of

counterfeiting and adulteration between countries referred to earlier makes comparisons difficult. Thus

USA customs include all categories of contamination whether deliberate or otherwise as adulteration.

Reports of fraud are often based on investigations by the industries affected. Thus, there appears to be a

recurring problem with mislabelling of fish and shellfish products with cheaper, more common species

being substituted for scarcer and thus more valuable species. There also appears to be a recurring

problem with contamination of meat and fish products with the prohibited antibiotic chloramphenicol used

during production to reduce infections, as well as with prohibited dye products to enhance the

appearance of the final product. However, there appear to be few definitive studies quantifying the extent

and economic costs of these activities.

A study of the economic effects of counterfeiting carried out in 2007 (OECD, 2008) concluded that

the“OECD survey has shed very little light on the actual magnitude and scope of counterfeiting in the

food and drink sector.”

Nevertheless, the survey did identify alcoholic drinks as the main target for counterfeiters in the

drinks sector because of their brand value and the high tax and excise component of final price. This

observation obtained from industry sources complements and supports information from EU records.

Other frequently counterfeited products according to OECD include: kiwi fruit, conserved vegetables, milk

powder, butter, ghee, baby food, instant coffee, tea, rice, non-alcoholic drinks, confectionary and hi-

breed corn seeds.

5.2 Health effects relating to counterfeit food and beverages

There is a paucity of public health literature relating to counterfeit goods. Data is fragmented and

of variable quality and includes anecdotal evidence, information from media reports, industry and

association bulletins and government reports. In a study in this area, Forzley (2003) concluded that:

“Direct evidence of the costs and public health consequences of counterfeit goods cannot be

found”. Despite this conclusion, food and beverages fraud has a clear human health perspective for

which national and global data is difficult to access because of the lack of national databases. Because

of the paucity of data publicly available in a study of the health and safety implications of the use of

counterfeit goods for a single year (2000), Forzley (2003) had to expand the scope of the study to include

reports covering the period 1995 to 2001.This is despite repeated reports at the local and national levels

of cases of poisoning from the consumption of counterfeit food and drink. The most frequent and

damaging occurrences relate to the consumption of counterfeit and “home-brewed” spirits, particularly

vodka, which appears to be a particular problem in parts of Eastern Europe. But recent cases of the

adulteration of milk products in China with melamine, to simulate higher protein levels, and the

subsequent sale of these products locally and internationally, resulting in the poisoning of large numbers

of people (and animals), emphasises the potential dangers resulting from the consumption of counterfeit

food and drink.



5.3 Estimates of Economic Effects of food and beverages fraud

It is clear from conclusions from OECD (2008) survey and the study by Forzely (2003) that there

are no firm statistics available on the cost of fraud in the food and beverages industries. In a fact finding

mission in 2007 to obtain information available on fraud in the EU foods and drinks trade the chairman of

the UK independent Food Fraud Task Force concluded that: “The true extent and cost of food fraud is

largely unknown in other Member States”. Information is also difficult to obtain relating to food and drink

counterfeiting in the UK. A widely quoted figure of 10% representing an annual cost of £ 7 billion to the

UK food and drink industry is apparently not based on any published research and is largely anecdotal.

World Customs Organisation (WCO) estimated 5-7% global trade in counterfeit products in 2004

($512billion). Of this ~$49 billion was accounted for by counterfeit food and beverages (Spink, 2009).

Estimates of fraud relating to food and drink are generally derived from surveys carried out or

financed by large generally multinational; producers, industry consortia or anti-counterfeiting bodies.

Many such estimates come from seizures of goods at national borders after intelligence from industry

sources identifies shipments of potentially counterfeited products. Other estimates are based on

anecdotal information or perceptions by the industries affected generally by limited local data

extrapolated to give national, supranational and global estimates.

A wide-ranging survey carried out in 2006 (Gallup, 2007) provided data on perceptions of industry

sources and consumers on the level of counterfeiting of foodstuffs and drink in the former Soviet Union,

Latin America and Asia (table 3) concluded that the sale of counterfeit foodstuffs ranged from an

estimated 4.8% of total sales in Asia to 34.5% in the countries of the former Soviet Union.

Table 5-1: Purchases of known or suspected counterfeit items in 2006 (Anon. 2007)

Comparable estimates for beverages, including both alcoholic and non-alcoholic drink ranged from

2.9% for Latin America to 23.6% in the former Soviet Union. No attempt was made in this survey to

provide an estimate of the monetary value of these levels of counterfeiting in relation to the total level of

economic activity in the food and drink sectors in these regions, although, this would emphasise the

scale of the problem.

Action instigated against counterfeiting of alcoholic drinks by the European Brands Association

resulted in the seizure of more than 1 million items and the closure of 148 counterfeit production sites

with an annual production capacity of 155,000 cases of alcoholic spirits with a potential revenue value of

19 million euro. Estimates from Russia suggested that the levels of counterfeiting of food and alcohol in

Region

Product Former Soviet

Union (FSU)

Latin

America Asia

Alcohol, Soft

drinks, Mineral

water

23.6% 2.9% 3.6%

Food 34.5% 10.2% 4.8%



2003 were 36 and 40% respectively with a combined annual cost of ~USD1 billion (CIPR, 2003). Data

provided by manufacturers and retailers in the United Arab Emirates (UAE) suggests that counterfeit

products represent 0.33-5% of the total market of 3.5 billion USD (2005 figure) for food and non-alcoholic

beverages, equalling 10.5-175.0 million USD. Counterfeiting in this sector was thought to represent

around 3.1% of the total of all counterfeit products on sale (KPMG, 2008).

Sources in Italy (Federazione Italiana dell‟Industria Alimentaire) reported sales of EUR 2.6 billion

of counterfeit food products in 2002 (Anon, 2002). This figure includes both clear attempts to defraud but

also include products which had not been counterfeited and were not, therefore, illegal, but in the opinion

of Italian producers carried labels that could have led to the belief that consumers were purchasing a

particular product produced in Italy.

Few attempts have been made to estimate the global costs of food and drinks counterfeiting and it

is difficult to extrapolate data from national estimates and the data available are not sufficiently robust to

provide statistically acceptable estimates.

One widely quoted estimate from the World Customs Organisation (WCO) was that around 5-7%

of global trade in 2004 was in counterfeit products with a value of $512 billion. Of this, counterfeit food

and beverages accounted for approximately $49 billion (Spink, 2009).

Another estimate by the International Chamber of Commerce for 2002 was that on a worldwide

basis almost 5% of all products are counterfeit (Anon. 2002). The proportion of this figure attributable to

food and drink fraud was not stated. The data from which these estimates were made is difficult to

access and evaluate although it presumably derives from industry surveys.

5.4 References

Anon, 2002, Federazione Italiana dell‟Industria Alimentaire (FEDERALIMNETARE0) Viale Pasteur 10, 00144 Roma, www.federalimentare.it , 2002

Forzley, M. (2003). Counterfeit Goods and the Public‟s Health and Safety, 2003. Intellectual Property Institute, 906 Pennsylvania Avenue,

SE Washington, DC 20003. (www.iipi.org).

Gallup, 2007. Global Consumer Awareness, Atitudes and Opinions on Counterfeiting and Piracy. Third Global Congress Combating Counterfeiting and Piracy. 31 January, 2007, Geneva, Switzerland. The Gallup Organization, Princeton, NJ, USA.

KPMG 2008. Economic Impact Study Analyzing Counterfeit Products in the United Arab Emirates. Report of a survey carried out on behalf of the Brand Owners Protection Group (BPG), Jan. 2008, 43 pp.

OECD (2008): The Economic Impact of Counterfeiting and Piracy. Organisation for Economic Cooperation and Development (OECD)

2008.OECD 2, rue André Pascal 75775 Paris Cedex 16 France pp 397.

Spink, J. (2009). Food Profiteering and the counterfeit product threat. In Feeding our Hungry planet Michigan State University Symposium

presentation.

http://www.iipi.org/


Section 6: Horizon scanning

6 HORIZON SCANNING – CONTINUED AND EMERGING FOOD AUTHENTICITY ISSUES

Commodity prices may be a useful general indicator of the likelihood of economic adulteration.

Scarcity of commodities and basic ingredients may be a result of poor harvest, increasing transportation

costs, increased demand from emerging economies etc. and the overarching burden on food suppliers to

maintain their contractual obligations to large retailers to supply foods at a fixed price mean ther may be

enormous pressures to extend or by cheaper raw materials. The Organisation for Economic Co-

operation and Development and the Food and Agriculture Organisation (OECD-FAO) have an

Agricultural Outlook database. This database is available under the „Topics‟ tab and then „Agriculture and

fisheries‟. tab of the OECD website www.oecd.org and contains agricultural commodity data for

production, price, consumption, import and export. The database includes historical data back to 1970,

where available, and projections to 2020. It is possible to browse the OECD-FAO Agricultural Outlook

database using 3 basic queries sorted by commodity (i.e. agricultural product), country (including

regions e.g. European Union) and variable (e.g. production, price, consumption, import, export). This

system could be used for the basis of a commodity price based system of horizon scanning for food

fraud and adulteration.

6.1 Counterfeit spirits and illicit spirit drink production

Up to a quarter of licensed premises in some parts of the UK have been found to have counterfeit

alcohol for sale. Trading Standards officials, who carry out spot checks, suggest it is a significant and

growing problem. Trade sources say fake alcohol is being made by organised gangs on an industrial

scale. This has been exemplified by the tragic deaths of five mean after an explosion at a suspected

illegal vodka factory in Lincolnshire (BBC 2011a). Furthermore, illegal alcohol stills are often poorly

controlled and may result in spirits that contain toxic concentrations of methanol that can cause blindness

after prolonged consumption. It is estimated that alcohol fraud costs the UK around Â£1bn a year in lost

revenue. Methods are available to assess spirit brand authenticity and the botanical origin of ethanol

present in wines and spirits, but the development of rapid „through the bottle‟ technologies would be

particularly advantageous to rapidly survey the extent of the problem in the retail market.

6.2 Counterfeit wine

This issue is related to the production of illicit spirits (paragraph 10.1 above). Large numbers of

counterfeit Jacob‟s Creek wine were identified by Trading Standards Officers in April 2011 (BBC, 2011b).

The counterfeit wine labels, whilst highly sophisticated in their artwork, contained two typographical

errors that allowed them to be easily identified. It is likely that other unidentified fraudulent products are

being sold in the UK retail market. If the counterfeiters had produced a label that did not contain any

typographical or grammatical errors this fraud would have been harder to detect. Validated methods to

confirm the authenticity of wine are well established. Using rapid non-targeted proton-NMR screening

techniques and isotopic analysis would allow a survey of wine products to be undertaken to assess the

level of fraudulent wines and spirits on sale in the UK retail market place. Unidentified fraudulent

products can cause long-term damage to brand reputations as some consumers will inevitably choose

http://www.oecd.org/



not to buy effected products again rather than question the vendor about the quality of the product they

have purchased.

6.3 Meat and Bone Meal/ Processed Animal Protein (MBM/PAP)

The Agriculture Commissioner for the EU, Mariann Fischer Boel, recently warned at an EU

Commission meeting that a shortage of soybean meal for animal feed could add to financial problems for

EU livestock producers. In addition, animal feed shortages have now hit the United States. Levels of

grain stocks are falling and the outlook for next year has not improved. This is now manifest in the corn-

consuming livestock feed chain, which can no longer sustain affordable supplies for producers of beef,

milk, poultry, and eggs (Executive Intelligence Review, 2011). Pressure will be growing to utilise animal

by-products in the form of Meat and Bone Meal/ Processed Animal Protein (MBM/PAP). There is

anecdotal evidence that feeding of animal protein is already occurring in some domestic and imported

meat and fish production industries. Although methods have been developed to assess whether

MBM/PAP is present in animal feed (SAFEEDPAP, 2011), there is still a requirement to develop methods

to assess whether animals have been feed MBM/PAP during production, when there is no access to the

feed, as is often the case for imported meat and fish. This is especially pertinent since the European

Commission is considering amendments of certain TSE control measures, without endangering

consumer health or the policy of eradicating BSE.

6.4 Pineapple and pomegranate juice

The economic adulteration of premium commodities such as fruit juice has been an ongoing

problem for many years. It has recently come to light through technological advances in isotopic

methods that the adulteration of pineapple juice with cane sugar has been going undetected. The

widespread adulteration of pomegranate juice with added water and sugar continues to be a major

problem due to the high demand and purported health benefits of this juice. Established methods now

exist for both of these juices that could be used to assess the level of fraud in the UK retail market.

6.5 The declared geographical origin of meat

There is general concern in the meat industry regarding the declared geographical origin of meat

when it is sold through restaurant outlets. This authenticity issue is often associated with terms such as

„locally produced‟; „locally produced organic‟ and „home-made‟. Most consumers are coming to realise

the environmental and economic benefits of eating local produce and are prepared to pay a premium for

these foods sourced locally. Consequently, unscrupulous traders have spotted a marketing niche with an

economic incentive to pass off cheaper meat as locally produced (Daily Mail, 2010). The development of

methods to verify the declared origin of uncooked meat are now being established and recognised but

they have not been validated for cooked meats (Defra Report FA0205, 2011). Research is therefore

required to establish the validity of the isotopic fingerprinting of meat geographical origin for cooked

meats.



6.6 Manuka honey and other honey authenticity issues

There are growing concerns over both the quality and geographical origin of Manuka honey.

Awareness of the basis of the non-peroxide activity test, that gives rise to the Unique Manuka Factor

(UMF) rating, means that there is an increasing likelihood of physical and chemical manipulation of

honey to give a higher apparent UMF rating for inferior Manuka honey. Recent analytical developments

have provided the basis for definitive testing of Manuka honey authenticity (Fera, 2011). However, the

extremely high premium prices associated with Manuka honey mean that the economic incentives still

exist to try and subvert even highly sophisticated authentication techniques.

A recent survey in the United States showed that pollen has frequently been filtered out of

products labelled "honey" (Food Safety News, 2011a) The food safety divisions of the World Health

Organization, the European Commission and other National authorities state that without pollen there is

no way to determine whether the honey came from legitimate and safe sources. A survey of honey on

sale in the UK for pollen content could be conducted by the Public Analyst with further checks on the

botanical source of the sugars using validated techniques (AOAC method 998.12, 1998).

.

6.7 Sustainable palm oil origin

It is known that the traceability of palm oil and its derivatives presents industry with a significant

challenge to ensure their supplies are from sustainable and ethical sources. Palm oil production has

been documented as a cause of substantial and often irreversible damage to the natural environment.

Its impacts include; deforestation, habitat loss of critically endangered species such as the Orangutan

and the Sumatran Tiger and a significant increase in greenhouse gas emissions. Palm oil producers

have been accused of various human-rights violations, from low pay and poor working conditions to theft

of land and murder. The oleochemical industry modifies palm oil and its fractions using hydrolysis to

produce fatty acids and glycerine, and trans-esterification to produce fatty acid methyl esters (FAMEs) for

biodiesel. These FAMEs are often further modified to give a wider range of derivatives used in the food

and cosmetic industries for example. A pilot study based on the use of stable isotope technology has

been used to differentiate palm oil produced in West Africa, Brazil and South East Asia (Van der Veer et

al, 2011). Genetic methods have also been adapted to oils that have not been heavily processed, such

as extra virgin olive oil, such that PCR and DNA analysis can be performed to identify the species of

olive (Pafundo et al., 2005). It is therefore possible that similar techniques could be applied to palm oil to

identify species and possibly geographical origin. The major challenge is to refine these methods to

obtain a test that will work at a much higher spatial resolution within specific countries and ultimately

down to farm level.

6.8 Illegal fishing and fraud along the fish supply chain.

Eighty percent of marine fish stocks are fully or over exploited and there is also great concern

about the levels of discarded catch. Furthermore, widespread illegal fishing is a known threat to marine

biodiversity & ecosystems, it undermines sustainable stock management and has lead to a significant

social and economic impact on the fishing industry. In addition, the mislabelling of fish species is

widespread and has received a great deal of media attention, which effects consumer confidence and

trust in the fishing industry (TheFishSite, 2011). DNA barcoding is a well established technique for the



determination of fish species and had been adopted widely by the enforcement community in the UK.

However, new developments have allowed genetic population markers to be used to determine the

geographical origin of fish in some instances (FishPopTrace, 2011). In addition, stable isotope and trace

element analysis of fish otoliths (ear bones) have also been shown to be a reliable tool to distinguish the

origin of fish and in combination with chemical analysis has been used to distinguish between farmed

and wild fish (Martinsohn, 2011).

6.9 Vanilla and other food flavours

Vanilla is one of the most widely used flavours and fragrances in both the food and cosmetic

industries. The demand for nature identical vanillin (the major chemical constituent of vanilla flavour) is

high. Vanillin produced from the bio-fermentation of clove oil (Eugenol) may be described may be

described as nature identical but Eugenol that has undergone synthetic chemical conversion to vanillin

may not. Differentiating the production pathway to confirm claims of „nature identical‟ are challenging

and methods are required to establish the method of production for vanillin and other food additives and

flavours claiming to be „natural‟ or „nature identical‟.

6.10 Spices (e.g. mustard and saffron)

Mustard is obtained by crushing and sifting the seeds of Sinapis nigra and Sinapis alba. The

majority of commercially sourced mustard is cultivated in Canada. The retail product usually sold as

mustard is a mixture of mustard, made with water, and vinegar into a paste and ready for use. There is

concern over the authenticity of mustard and the mis-use of common adulterants such as radish seed

and peasemeal (pea flour). Other prevalent forms of adulteration include partial extraction of oil from

mustard seeds before releasing into the market, addition of cocoa nut shells, Terra alba, „Martius yellow‟

(Potassium dinitro naphthalate). The presence of admixtures can be identified by microscopic

examination of the sample. Wheat flour and starch is readily identified by iodine test. Genuine mustard

contains about 5% of ash of which 1% is soluble in water. In the presence of organic impurities the ash

content increases generally up to about 4%. These simple chemical tests can be used to establish the

authenticity of mustard paste and mustard seeds.

The adulteration of high value spices in general is of concern including products such as saffron,

where geographical origin is also an issue because of cheap non-European imports being used as

substitutes for high value Spanish, Italian and Greek saffron. A recent pilot study has demonstrated the

applicability of chemical and stable isotope fingerprinting to determine the origin of saffron, which could

be developed and applied in a surveillance exercise in the UK (Maggi et al., 2011).

6.11 Botanical source of acetic acid in Balsamic vinegar

Traditional balsamic vinegar (Aceto Balsamico Tradizionale) is aged for a minimum of 12 years.

There have been cases reported in other parts of Europe that identify artificial products derived from a

combination of grape juices, vinegar, and caramel colours or „cooked grape musts‟ that attempt to

replicate balsamic vinegar. Balsamic is a product that is growing in popularity in the UK and does attract

a premium price tag. Validated and collaboratively tested methods exist to identify the botanical source

of the acetic acid in the vinegar and whether the water present is derived from grapes or tap water



(Thomas & Jamin, 2009). These methodologies could be used to undertake a survey of UK retail

balsamic vinegars to verify the source of the acetic acid and water present.

6.12 Melamine alternatives giving a high ‘apparent’ protein content in foods

There is anecdotal evidence that other high nitrogen content organic compounds, that are cheap

and plentiful, are being sourced to increase the value of foods and food ingredients that are sold on the

basis of their apparent nitrogen content. For example the term "biuret" describes a family of organic

compounds with the functional group -(HN-CO-)2N-. Biuret is also used as a non-protein nitrogen source

in ruminant feed where it is converted into protein by gut microorganisms. It is less favoured than urea,

due to its higher cost and lower digestibility, but this characteristic also slows down its digestion and so

decreases the risk of ammonia toxicity.

Development of field based technology such as lateral flow devices may be applicable to the

detection of melamine and its potential alternatives because of the availability of suitable aptamers.

Aptamers are oligonucleic acid or peptide molecules that bind to a specific target molecule such as

melamine or biuret. A simple field based extraction protocol could be developed for products such as

infant formula or milk powder and applied to a lateral flow device containing a melamine or biuret specific

indicating apatamer.

6.13 Hydrolysed leather protein in milk

Media reported the abuse of hydrolysed leather protein in milk products in the Canadian mainland.

Hydrolysed leather protein is reportedly made from hydrolysing scrap leather and added to milk products

by unscrupulous manufacturers to increase protein content. This illegal practice causes food safety

concerns since metallic contaminants used in the manufacturing process of leather might be present in

the milk products. Because chromium III (Cr[III]) is used as a tanning agent in the production of leather,

the hydrolyzed leather protein should contain elevated levels of Cr (with the main species being Cr[III]

and Cr[VI]) even after the Cr removal process. Cr(VI) is a known carcinogen and can irritate or damage

the respiratory tract, gastrointestinal tract, and skin. Inductively coupled – plasma mass spectrometry

could be used to test for the presence of elevated concentrations of different species of chromium in

target commodities such as infant formula and milk powder.

6.14 Palm sugar authenticity

Palm sugar was originally made from the sugary sap of the Palmyra palm or the date palm. Now it

is also made from the sap of the sago and coconut palms and may be sold as "coconut sugar." When the

palms are 15 to 20 years old they start flowering and it is only then that they yield the sap from which

palm sugar is made. Palm sugar is analogous to maple syrup in that it is a premium product derived from

tree sap and has a high sugar content. Consequently, it is potentially subject to adulteration with

cheaper sources of refined sugar such as cane sucrose. Apparently it is common practice to add small

amounts of cane sugar to palm sugar during its production. The cane sugar might be used to „seed‟ the

crystallisation of the palm sugar crystals. The addition of added sugar is declared on some of the retail

products but not all.



The Association of Official Analytical Chemists method for the determination of C4 sugars in honey

(AOAC method 991.12) was successfully adapted for palm sugar analysis (Defra report FA0207).

Assessment of the carbon stable isotope composition of bulk palm sugar and the extracted protein

fraction showed that significant quantities of exogenous cane or corn derived sugars are being used to

adulterate and extend retail products on sale in the UK. Between 50% to 70% of the sugars present in

the retail samples of palm sugar were derived from cheaper sources of refined sugar such as cane

sucrose or high fructose corn syrup and not from the sap of the Palmyra, Date, Sago or Coconut palms.

A surveillance exercise of retail palm sugar products could be undertaken on the basis of the developed

methodology to assess the extent of palm sugar adulteration in the UK.

6.15 Authenticity of Halal food products

A much greater emphasis is now being placed on the authenticity of Halal foods. Compliance with

Shariah law at the „molecular level‟ is now being recommended by bodies such as JAKIM (Jabatan

Kemajuan Islam Malaysia) that are providing Halal certification worldwide. For the implementation of

Halal product certification and Halal quality assurance in the supply chain, reliable analytical methods are

required. However, established analytical methods for Halal verification of food, cosmetic, and

pharmaceutical products are relatively few. So far the use of conventional GLC and HPLC systems has

been successful in a limited number of cases (Marikkar et al, 2005), and some investigations have also

been carried out on the use of thermo-analytical (Marikkar et al, 2001) and infra-red spectroscopic

(Rohman and Che Man, 2010) techniques. Of particular interest to the Halal Products Research Institute

is the use of stable isotope analysis to differentiate the source of ethanol and acetic acid in vinegar.

Products from petrochemical sources are permitted whereas those derived from the wine or spirit

industries are not. The source of gelatine is also of concern for Halal authentication as methods to verify

the animal source of gelatine are not straightforward due to the lack of DNA. Pork products are not

permitted in Halal food and porcine collagen is the most common and cheapest source of gelatine.

However, recent developments in proteomic analysis permit the source of gelatine to be reliably

determined (Grundy et al, 2009).

6.16 Organic food authenticity

Whilst the founders of the organic farming movement placed considerable value on close links

between producers and consumers, the demand for organic produce has widened this gap. The organic

sector is becoming increasingly dominated by corporate players that may not share some of the less

tangible benefits of the organic philosophy. Notwithstanding the pros and cons of this evolution of the

organic retail sector, the globalisation of organic markets must inevitably place an increased burden on

certification/inspection bodies and traceability systems on which the authenticity of the organic produce

depends. Six years ago, Siderer et al. (2005) proposed the introduction of supplementary analyses and

tests of organic merchandise in order to verify labelling claims. There have been several cases of organic

food fraud in the media (Mail online, 2011) including those relating to organic manures adulterated with

synthetic nitrate fertiliser (Food Safety News, 2011).

There are a range analytical techniques that have been advocated as having the potential to

discriminate between different facets of organic and conventional cultivation to verify labelling claims.

These include; established and validated techniques such as pesticide and veterinary drug residue



analysis, stable nitrogen and oxygen isotope analysis to differentiate between crops grown with the

application of synthetic (inorganic) nitrogen or manure based fertiliser; trace metal analysis to establish

markers for mineral supplementation or the possible effects of arbuscular mycorrhizal fungi association in

organic soils; metabolite profiling, fluorescence microscopy, phosphorus nuclear magnetic resonance

spectroscopy and other potential analytical techniques. Despite the fact that many of these techniques

are not yet definitive, they can still provide useful intelligence on the level of fraud with the caveat that

there may be high rate of false negative results. Nevertheless, no single analytical surveillance exercise

has ever been undertaken to assess the level of Organic food fraud in the UK retail market.

6.17 Internet purchasing of speciality foods

The purchase of medication through the internet is known to be rife with fraudulent activity, such

as the supply of pharmaceuticals without active ingredients. However, the purchase of speciality foods

over the internet, that are difficult to obtain locally, should be done with equal caution if the supplier is

unknown to the purchaser. typically food authenticity surveillance exercises do not monitor boxed food

sales and they should be included in future exercise to assess the potential for food fraud.

6.18 Gross crude adulteration

There is evidence of gross crude adulteration occurring in food products imported into the UK.

The identification of „synthetic milk‟ composed of urea, liquid detergent, sugar, vegetable oil and water

was reported in India (Paradkar et al., 2007). Another example would be spices such as turmeric, which

may be adulterated with, Lead chromate (which adds colour and density to the product); Metanil yellow

dye or any starch based bulking agents such as flour or rice powder or industrial starches. Except flour or

rice powder, the other adulterants are toxic and pose considerable risks to health when eaten at regular

intervals for a long period of time. Whilst methods of detection are relatively straightforward, some types

of crude adulteration have not targeted because they have not been a problem in the UK for decades.

6.19 Food irradiation

If used properly food irradiation offers a safe means of destroying food-bourne bacteria. In the

latest E. coli outbreak, centred in Northern Germany, 26 deaths and over 2,000 infections occurred.

During the outbreak, linked to contaminated bean sprouts, food safety experts discussed the use of food

irradiation in “the battle to destroy illness causing bacteria” (FAO, 2011). Older attitude studies in the

United States demonstrated that given science-based information, from 60% to 90% of consumers prefer

the advantages „irradiation-processing‟ provides. When information is accompanied by samples,

acceptance may increase to 99%. However, in much of Europe (and in contrast with the USA) these

developments have been treated with considerable suspicion by consumers (Dennis, 1998).

However, as with genetically modified foods there is a requirement to provide consumers with

clear and concise information so that they can make informed choices about the food they purchase. If

irradiation of food does become more widely accepted then there will be a requirement for methods to

verify whether food has been irradiated or not as some consumers may choose not to buy these foods

despite the benefits of the decreased risk of bacterial contamination. There are many standardised



chemical and microbiological methods for detecting irradiated food, many of which have CEN

accreditation (Delincee, 1998).



6.20 References

Anon, 2002, Federazione Italiana dell‟Industria Alimentaire (FEDERALIMNETARE0) Viale Pasteur 10, 00144 Roma, www.federalimentare.it , 2002

AOAC method 998.12, 1998, C-4 Plant sugars in honey internal standard stable carbon isotope ratio method.

BBC 2011a, „'Growing problem' of illegally distilled alcohol‟, http://www.bbc.co.uk/news/uk-england-14151509 Accessed July 2011.

BBC 2011b, „Fake Jacob's Creek wine seized in off licences‟, http://www.bbc.co.uk/news/uk-england-12992242 Accessed May 2011.

Daily Mail, 2010, „The great local food scam: How restaurants up the price on items actually sourced elsewhere‟, http://www.dailymail.co.uk/news/article-1315397/Local-food-scam-Restaurants-price-items-sourced-elsewhere.html Accessed January 2011

Defra Report FA0205, 2011, „British Beef Origin Project (BBOP)‟. Report Available at http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18069&FromSearch=Y&Publisher=1&SearchText=FA0205&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description Accessed October 2011.

Defra Report FA0207, 2011, „Identification of an internal isotopic reference compound in palm sugar to improve the detection of cane sugar addition‟, Report Available at http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18071&FromSearch=Y&Publisher=1&SearchText=palm&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description Accessed October 2011.

Delincée, H., 1998, „Detection of food treated with ionizing radiation‟, Trends in Food Science & Technology, Volume 9, Issue 2, 73-82

Dennis, M.J., 1998, „Recent developments in food authentication‟, Analyst, 123, 151R–156R

Executive Intelligence Review, 2011, http://www.larouchepub.com/other/2011/3837no_feed_no_food.html Accessed September 2011.

FAO, 2011, Food and Agriculture organisation, „Food Irradiation - a better way to kill microbes associated with food borne illness‟, Available at: http://www.fao.org/ag/portal/ag-archive/detail/en/item/80215/icode/?no_cache=1 Accessed October 2011.

FishPopTrace, 2011, Brochure „Traceability of Fish Populations and Fish Products: Advances and Contribution to Sustainable Fisheries‟ Editors Gary Carvalho, Eoin Mac Aoidh and Jann Martinsohn. Available at: http://fishpoptrace.jrc.ec.europa.eu/c/document_library/get_file?uuid=c21ccbef-029f-43da-b1cd-ade11e743301&groupId=10226 Accessed October 2011.

Fera 2011 – Food & Environment Research Agency, „Manuka honey testing‟, http://fera.defra.gov.uk/foodDrink/foodConfidence/honeyAnalysis.cfm Accessed September 2011.

Food Safety News, 2011a, „Tests Show Most Store Honey Isn't Honey. Ultra-filtering Removes Pollen, Hides Honey Origins‟ by Andrew Schneider, Nov 07, 2011. Available at: http://www.foodsafetynews.com/2011/11/tests-show-most-store-honey-isnt-honey/?utm_source=newsletter&utm_medium=email&utm_campaign=111107 Accessed October 2011.

Food Safety News, 2011b, „Organic Fertilizer Maker Charged with Fraud‟, available at: http://www.foodsafetynews.com/2011/03/organic-fertilizer-maker-accused-of-using-chemicals/ Accessed March 2011.

Guardian (2011) Wine alcohol strength 'systematically' understated on labelling http://www.guardian.co.uk/lifeandstyle/2011/jul/05/wine-alcohol-strength-understated Accessed 6

th July 2011

Gallup, 2007. Global Consumer Awareness, Atitudes and Opinions on Counterfeiting and Piracy. Third Global Congress Combating Counterfeiting and Piracy. 31 January, 2007, Geneva, Switzerland. The Gallup Organization, Princeton, NJ, USA.

Grundy et al., 2009, „Proteomic technique for identifying the species origin of gelatines‟, available at: http://thefera.co.uk/showNews.cfm?id=403 Accessed October 2011.

KPMG 2008. Economic Impact Study Analyzing Counterfeit Products in the United Arab Emirates. Report of a survey carried out on behalf of the Brand Owners Protection Group (BPG), Jan. 2008, 43 pp.

Maggi et al., 2011, „Geographical origin differentiation of saffron spice (Crocus sativus L. stigmas) – Preliminary investigation using chemical and multi-element (H, C, N) stable isotope analysis‟, Food Chemistry 128, 543–548

Mail Online, 2011, „Organic food fraud: One in six restaurants lie about the origin of their offerings‟ Available at: http://www.dailymail.co.uk/news/article-1363664/Organic-food-fraud-One-restaurants-lie-origin-offerings.html Accessed March 2011.

Marikkar, J.M.N., H.M. Ghazali, Y.B. Che Man, T.S.G. Peiris, and O.M. Lai. 2005, „Distinguishing lard from other animal fats in admixtures of some vegetable oils using liquid chromatographic data coupled with multivariate data analysis‟, Food Chem., 91: 5–14.

Marikkar, J.M.N., O. M. Lai, H. M. Ghazali and Y. B. Che Man. 2001, „Detection of lard and randomized lard as adulterants in RBD palm oil by differential scanning calorimetry‟ J. Am. Oil Chem. Soc., 78: 1113–1119.

Martinsohn, J., 2011, presentation at Food Safety and Authenticity 2011, 18-20 October, Crowne Plaza Brussels - Le Palace: „Molecular Technologies to Combat False Labelling – From Ocean to Fork‟

Pafundo, S. et al., 2005, „Traceability of Plant Contribution in Olive Oil by Amplified Fragment Length Polymorphisms‟ J. Agric. Food Chem., 53, 6995-7002

http://www.bbc.co.uk/news/uk-england-14151509

http://www.bbc.co.uk/news/uk-england-12992242

http://www.dailymail.co.uk/news/article-1315397/Local-food-scam-Restaurants-price-items-sourced-elsewhere.html

http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18069&FromSearch=Y&Publisher=1&SearchText=FA0205&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description

http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18069&FromSearch=Y&Publisher=1&SearchText=FA0205&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description

http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18071&FromSearch=Y&Publisher=1&SearchText=palm&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description

http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18071&FromSearch=Y&Publisher=1&SearchText=palm&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description

http://www.larouchepub.com/other/2011/3837no_feed_no_food.html

http://www.fao.org/ag/portal/ag-archive/detail/en/item/80215/icode/?no_cache=1

http://fishpoptrace.jrc.ec.europa.eu/c/document_library/get_file?uuid=c21ccbef-029f-43da-b1cd-ade11e743301&groupId=10226

http://fera.defra.gov.uk/foodDrink/foodConfidence/honeyAnalysis.cfm

http://www.foodsafetynews.com/2011/11/tests-show-most-store-honey-isnt-honey/?utm_source=newsletter&utm_medium=email&utm_campaign=111107

http://www.foodsafetynews.com/2011/11/tests-show-most-store-honey-isnt-honey/?utm_source=newsletter&utm_medium=email&utm_campaign=111107

http://www.foodsafetynews.com/2011/03/organic-fertilizer-maker-accused-of-using-chemicals/

http://www.guardian.co.uk/lifeandstyle/2011/jul/05/wine-alcohol-strength-understated

http://www.guardian.co.uk/lifeandstyle/2011/jul/05/wine-alcohol-strength-understated

http://thefera.co.uk/showNews.cfm?id=403

http://www.dailymail.co.uk/news/article-1363664/Organic-food-fraud-One-restaurants-lie-origin-offerings.html



Rohman, A., Che Man, Y.B., Ismail, A., & Hasim, P. 2010, FTIR spectroscopy combined with chemometrics for analysis of lard in some vegetable oils. Cyta-Journal of Food, 9: 96–101.

SAFEEDPAP, 2011, Feed Safety Platform, „Species-specific detection of processed animal proteins in animal feed‟ http://www.feedsafety.org/activities/safeedpap.php?menu=2 Accessed June 2011.

Spink, J., 2009. Food Profiteering and the counterfeit product threat. In Feeding our Hungry planet Michigan State University Symposium presentation.

Siderer, Y. et al., 2005, „Need for research to support consumer confidence in the growing organic market.‟, Trends in Food Science and Technology. 16, 332-343.

The FishSite 2011, „ICIJ Identify Continuing Threat Of Hake Hoax In Spain‟, http://www.thefishsite.com/articles/1231/icij-identify-continuing-threat-of-hake-hoax-in-spain Accessed October 2011.

Thomas, F. & Jamin, E., 2009, „2H NMR and 13C-IRMS analyses of acetic acid from vinegar, 18O-IRMS analysis ofwater in vinegar: International collaborative study report, Analytica Chimica Acta 649, 98–105

Van der Veer, G., et al, 2011, Poster Presentation “Geographical provenancing of palm oil”, RIKILT – Institute of Food Safety P.O. Box 230, NL6700 AE, Wageningen, The Netherlands

7 CONCLUSIONS AND RECOMMENDATIONS

There is a clear difference between the number and type of food authenticity and food fraud cases

detected and reported by the enforcement community in the UK and the frequency and breadth of issues

investigated by private sector laboratories around Europe. There is a significant information and intelligence

gap in this area that is derived from insufficient information sharing between the food industry and the

enforcement community leading to undetected food fraud in the UK. The key to consumer protection is the

rapid sharing of information and intelligence, about suspected and actual incidence of food fraud and

adulteration, between the food industry and the enforcement community, without prejudice. Partnerships

between government and trade associations should facilitate information sharing and enforce laws and

regulations.

There is also a technology gap between the methodologies made available through the LA Public Analyst

and the leading analytical food authenticity research establishments. This means the most up to date methods

are not always available and/or LAs are not aware of the techniques on offer in the fight against food fraud and

food adulteration. A forum for enforcement officers to access the latest information on methods to determine

food authenticity is required e.g. workshop at the TSO/EHO‟s annual conference.

It would be appropriate to establish a European network of competence for analytical techniques in food

authentication, on a commodity basis, so that the latest technology and appropriate expertise can be readily

accessed. This would be analogous to the appointment of National Reference Laboratories for food

authentication as with for example pesticide, veterinary drug, dioxin, and heavy metal analysis. The appointed

food authenticity NRL could also train PAs in the relevant technology when appropriate.

Funding from the Commission‟s Directorate-General for Research and Innovation for a COST action

(European Cooperation in Science and Technology) could be sort to initiate an anti-food fraud intelligence

network, at the European level. Once established this AFFI network could seek to establish international links

at all levels between enforcers, practitioners, government bodies and consumer protection organisations. Its

aim would be to disseminate information through a specific food fraud alerting service to all relevant

international stakeholders and could be linked into existing systems such as RASFF.

http://www.feedsafety.org/activities/safeedpap.php?menu=2

http://www.thefishsite.com/articles/1231/icij-identify-continuing-threat-of-hake-hoax-in-spain

http://www.thefishsite.com/articles/1231/icij-identify-continuing-threat-of-hake-hoax-in-spain


Section 7: Results and discussion

The FSA‟s Food Fraud Team and Defra‟s Food Authenticity Branch could forge links with the U.S. Food

and Drug Administration‟s „Pathway to Global Product Safety and Quality‟ (FDA,2011). The FDA, in close

partnership with its foreign counterparts, plans to assemble global coalitions of regulators dedicated to building

and strengthening the product safety net around the world. With these coalitions, FDA intends to develop a

global data information system and network in which regulators worldwide can regularly and proactively share

real-time information and resources across the global market place.

Introduce a system of „horizon scanning‟ of emerging food fraud issues by examining correlations between

commodity prices and links with levels of fraud and differences between production and traded volumes. This

would be a move towards a proactive rather than reactive intelligence led system of detection of food fraud and

would be highly desirable. This links with recommendations for the requirements of a system covering EFSA‟s

mandate for automatic scanning of the Eurostat Comext database. Such a system should provide alerts to the

users, indicating for example i) significant increase of the volume of a given product over time to a specific MS

or EU in total ii) new trade partners iii) new food or feed commodities entering the EU. Furthermore, whilst

commodity adulterant or commodity specific analytical tests are useful, high throughput non-targeted screening

methods are the key to moving towards a proactive rather than reactive national analytical food authentication

system and have implications for food defence.

Recent opinion suggests that organised crime syndicates are increasingly behind cases of food fraud and

adulteration. Consequently, the detection and prevention of food fraud requires strategic planning and

investment within both local and central government with an proportionate and sustainable budget.

7.1 References

FDA (2011) Pathway to Global Product Safety and Quality http://www.fda.gov/AboutFDA/CentersOffices/OC/GlobalProductPathway/default.htm accessed 11 July 2011

8 OTHER SOURCES CITED

Anon, 2002. Federazione Italiana dell‟Industria Alimentaire (FEDERALIMNETARE0) Viale Pasteur 10, 00144

Roma, www.federalimentare.it , 2002.

Anon. 2003. A Brief Overview of Counterfeiting. International Chamber of Commerce, Jan. 23, 2003

(http://www.iccwbo.org).

Anon. 2007. Purchases of known or suspected counterfeit items in 2006. In: 3rd Global Congress Combatting

Counterfeiting and Piracy 31/01/07. Geneva, Switzerland.

Anon. 2008a. The Economic Impact of Counterfeiting and Piracy. Organisation for Economic Cooperation and

Development (OECD) 2008.OECD 2, rue André Pascal 75775 Paris Cedex 16 France pp 397.

Anon. 2008b.Economic impact study analyzing counterfeit products in UAE. pp 42. Brand Owners Protection

Group 2008

http://www.fda.gov/AboutFDA/CentersOffices/OC/GlobalProductPathway/default.htm


Section 7: Results and discussion

BASCAP 2009. The Impact of Counterfeiting on Governments and Consumers. Executive Summary of a report

commissioned by BASCAP: Business Action to Stop Counterfeiting and Piracy. May 2009.

http://www.iccwbo.org/bascap

CIPR, 2003. Coalition for Intellectual Property Rights (CIPR); quoted by www.foodanddrinkeurope.com

31/10/03)

EC Taxation and Customs Union (EC Taxud 2000-2008).

Forzley, M. (2003). Counterfeit Goods and the Public‟s Health and Safety, 2003. Intellectual Property Institute,

906 Pennsylvania Avenue, SE Washington, DC 20003. (www.iipi.org).

Gallup, 2007. Global Consumer Awareness, Atitudes and Opinions on Counterfeiting and Piracy. Third Global

Congress Combating Counterfeiting and Piracy. 31 January, 2007, Geneva, Switzerland. The Gallup

Organization, Princeton, NJ, USA.

KPMG 2008. Economic Impact Study Analyzing Counterfeit Products in the United Arab Emirates. Report of a

survey carried out on behalf of the Brand Owners Protection Group (BPG), Jan. 2008, 43 pp.

Spink, J. (2009). Food Profiteering and the counterfeit product threat. In Feeding our Hungry planet Michigan

State University Symposium presentation.

8.1 Additional sources consulted

European Anti-Fraud Office (OLAF)

European Brands association (AIM)

International federation of Spirits Producers (IFSP),

International Security Management Organisation (ISMA), Post Office Box 623 Buffalo, IA 52728

International Trademark Association (INTA), 655 Third Avenue, 10th Floor, New York, NY 10017-5617 USA

INTERPOL General Secretariat200, quai Charles de Gaulle69006 LyonFrance

US Food and Drugs Administration (www.fda.gov)

World Customs Organisation, Rue du Marché, 30 B-1210 Brussels Belgium.

World Intellectual Property Organization (WIPO) 34, chemin des Colombettes CH-1211 Geneva 20,

Switzerland.

9 ACKNOWLEDGEMENTS

This research was financed by the UK‟s Department for Environment, Food and Rural Affairs, Food Authenticity

Programme as part of their Food Authenticity Programme. The views expressed here are those of the authors

and do not necessarily reflect the views of Defra. The authors would like to thank all those individuals and

organisations that contributed to the information used in this report.

the identification of sources of information...

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