What is Food Fraud?
According to Spink and Moyer “Food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.”.
Therefore, it is necessary to differentiate between unintentional and intentional scenarios in food safety management: Unintentional scenarios represented by the “classical” hazards are being controlled via HACCP systems since many years. Intentional scenarios may result from ideological motivations – here we are talking about threats that are managed in Food Defence programs.
Regulatory Requirements and Food Safety Management Standards
Regulation (EC) No 178/2002 of the European Parliament and of the Council names in its general objectives beneath the high level of protection of human life, health and the consumers’ interests the safeguarding of fair practices in food trade along the supply chain. Furthermore, the legislators refer to international food safety management standards: where these standards exist or their completion is imminent, they shall be taken into consideration in the development or adaption of food law.
By this, food safety management standards, especially GFSI (Global Food Safety Initiative) recognised standards, represent state-of-the-art and useful approaches for food business operators to ease their fulfilment of due diligence. Within the GFSI-framework the FSSC 22000, IFS Food, BRC and SQF constitute the most important ones. All of them rest upon the principles of HACCP, Food Safety Management Requirements and Good Industry Sector Practice Requirements and the most recent GFSI clauses contain the topic “Food Fraud”. Together with HACCP and Food Defence Systems it is necessary for food business operators to establish a VACCP System (Vulnerability Assessment of Critical Control Points) to mitigate and minimise risks from identified food fraud vulnerabilities.
Food Fraud in the Juice Sector – Literature and SGF/IRMA’s Experience in 2017
Periodically together with other foodstuffs (e.g. honey and olive oil) fruit juices rank in the top 10 of economically motivated adulteration of food. In 2014 Johnson reported fraudulent activities like water addition, cutting down expensive juices with cheaper ones or addition of sugars.
As far as the authenticity of semi-finished fruit juice products is concerned, we could find only 2% of the analysed samples from 2017’s audits at SGF/IRMA members being in the atmosphere of food fraud (substitution, addition, tampering, misrepresentation and misleading statements).
Noteworthy observations in 2017 were especially the addition of foreign fruits, the addition of sugar, the addition of citric acid, the addition of water and detectable contents of sulphur dioxide in organic grape juices / juice concentrates.
Even if this low percentage sounds like negligible impacts for our sector – being concerned with such fraud could cause serious, especially as consumer organisations and media are very aware of the topic food fraud. Nevertheless, a high-level market transparency in raw material and intermediates production is proven by these results from our control work and demonstrate the high addiction of SGF certified companies to authenticity, quality and safety.
How to protect yourself against Food Fraud with SGF International e.V.?
Successful strategies for our industry are necessary to meet these challenges and to avoid scandals and bad news for the fruit juice business. Therefore, a holistic view in raw material procurement is necessary and the VACCP team should be composed of representatives of the departments being involved in all key processes from raw material purchase to the release of the final product.
Risky raw materials could be described as being expensive, rarely available and analytically insufficient described. A further factor contributing to risky purchases lies in the chemical composition of fruit juices / juice concentrates and their wide variation (geographical and/or harvest-specific characteristics). Nevertheless, putting every fruit juice or every supplier under general suspicion is not only unfair, but also very expensive considering analytical and/or audit costs.
To reduce quality costs a suitable approach to (self-) protection from food fraud consists in active participation in the Voluntary Control System, as well as making use of the services for members offered by SGF. In the meantime, these added values have been acknowledged by FSSC 22000: “supplier certification (forward and backward) by sector specific control systems which are specialized to prevent or mitigate food fraud can substitute own analytical routine screening. An example is supplier certification via a voluntary certification scheme in the sector of fruit and vegetable juices and purees⁴.” The footnote directly refers to the Voluntary Control System of SGF.
There is more to active participation in the Voluntary Control System than just a successful audit and unobjectionable analyses of the samples taken during the audit. Following the continuous process suggested by U.S. Pharmacopeia, SGF services may support especially the pre-screening, vulnerability assessment and the development of the preventive control plan:
- The Pre-Screening describes the process of collecting all purchased raw materials and intermediates and the identification of potential risks. SGF’s Business Reports, bi-monthly News and Early Warnings keep our member companies regularly informed about quality deviations in semi-finished and consumer goods – valuable information to support member companies in possible adjustments of sampling schedules and analytical scopes.
- In the Vulnerability Assessment the differentiation between controllable and uncontrollable factors is key. Controllable and safeguarded factors are e.g. the supply chain, audit strategies or the susceptibility of quality assurance methods. These factors are supported by SGF Audits along the supply chain from tree to bottle, by SGF’s analyses randomly applied on samples taken during our audits.
- The Preventive Control Plan is key to get on track at risky raw materials. With the help of risk-oriented and susceptible analytical scopes based on SGF’s experience, possible damages of food fraud are mitigated. Evaluation of analytical results may be supported by the use of SGF’s Database of Authentic Samples and SGF’s Technical Hotline.
About SGF International e.V. and the Voluntary Control System
The SGF history is characterised by the fact that already in the 1970s, the sector image was in jeopardy from product adulterations and unfair competition. As a result, the “Schutzgemeinschaft”, an association to protect the fruit juice industry, was then set up as an instrument of industrial self-control in order to restore clean, fair market conditions and connecting quality-conscious players in the global juice industry.
For more than 40 years now, SGF International e.V. has played an active role when it comes to combatting food fraud, developing effective strategies in order to help the individual member with self-protection measures, protect the branch image and particularly promote fair competition. SGF is therefore the only system in the world to combine independent system and product controls, taking consistent measures to prevent the recurrence of non-conformities, even including court action if necessary.
The control system that permits the traceability of a juice “from the tree to the bottle” is based on voluntary participants who open the doors of their semi- and finished goods facilities for the SGF auditors and allow samples to be taken of the semi- or finished goods from on-going production and from the warehouse for corresponding testing, together with hygiene audits of the plant facilities.
The “complete control chain”, from processing the fruit through to the finished product can provide verification of perfect quality within next-to-no time, even if natural changes resulting from origin, growth or variety characteristics cause deviations from normal expectations. At the same time, it is easy to detect, localise and prove illicit product manipulation. Any infringements against the food regulations or against the rules of the system trigger corrective action by the SGF with corresponding follow-up inspections.
|||Spink, J., and Moyer, DC.,2011. Defining the Public Health Threat of Food Fraud. Journal of Food Science, 2011, Volume 75 (Number 9), p. 57-63.).
|||Global Food Safety Initiative, 2014. GFSI Position on Mitigating Public Health Risk of Food Fraud
|||Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety
|||Global Food Safety Initiative, 2017.GFSI Benchmarking Requirements. GFSI Guidance Document Version 7.2
|||Moore, J., Spink, J., and Lipkus, M., 2012. Development and Application of a Database of Food Ingredient Fraud and Economically Motivated Adulteration from 1980 to 2010. Journal of Food Science, Volume 77 (Number 4), p. R118-R126.
|||Johnson, R., 2014. Food Fraud and “Economically Motivated Adulteration” of Food and Food Ingredients. report, January 10, 2014; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc276904/: accessed November 9, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.
|||SGF International e. V. Sure-Global-Fair (SGF), 2018. Business Report 2017 (https://www.sgf.org/fileadmin/user_upload/public_download/Downloads_english/Business%20Reports/Business_Report_2017.pdf)|
|||FSSC 22000, 2018. Guidance on Food Fraud Mitigation. Version 1, Number 2171848
|||U.S. Pharmacopeia Appendix XVII: Food Fraud Mitigation Guidance