FAQs: Food Fraud Mitigation Guidance (FFMG)

Food fraud has been around for a long time and is a global problem, to combat it requires collaboration between governments, global trade organizations, manufacturers, and the public. What are some of the actions or initiatives being taken to combat this problem?

A number of organizations around the globe have undertaken initiatives to combat food fraud. The following are some examples, but this is not intended to be a comprehensive list.

  • In the U.S., regulations developed to implement the FDA Food Safety Modernization Act include new provisions for the prevention of food fraud-related hazards.
  • The European Commission has recently held a series of high level meetings with different stakeholders and has founded a new group with a focus on Food Authenticity, and the Food Integrity project is funding research on food fraud.  Professor Chris Elliott at Queens University was commissioned by the UK government to publish a report on food fraud following the horsemeat scandal. The European Commission’s JRC has also started publishing a monthly report on food fraud.
  • The Chinese Food Safety Risk Assessment Center (CFSA) has established an expert group to address food fraud and to administer the “black list” of substances that are not allowed for use in foods (created as a result of the melamine scandal).  
  • The Global Food Safety Initiative (GFSI) formed a food fraud think tank and recently added to its Guidance Document the requirements for food fraud vulnerability assessments and control plans. 
  • The U.S. Pharmacopeia (USP) has brought together collaborative panels with experts from industry, government, and academic stakeholders to develop solutions to combat food fraud (e.g. databases, vulnerability assessments, mitigation guidance, testing standards, and training programs).
1. What would be a best practice to investigate food fraud?

The work to deal with food fraud often does not end once you uncover potential food fraud, and organizations may find it useful to enlist the help of forensics labs and other organizations that specialize in investigating food fraud in supply chains.

2. How can we look at fraud when auditing our suppliers Isn't this a highly skilled forensic type of audit we are not skilled in?

Auditing is one of many strategies that can play a critical role in mitigating food fraud vulnerabilities. To be most effective in dealing with food fraud, auditing should include anti-fraud measures such as those outlined in the USP Food Fraud Mitigation Guidance.  Examples include conducting a “should cost” analysis and using unannounced audits. Sometimes fraud is easily uncovered if the records don’t match (e.g., product “volume” coming into the factory doesn’t agree with “volume” produced). Auditors are now trained to look more specifically for indicators of food fraud in documentation, but there is a recognized need to enhance the training available to auditors to uncover food fraud, and to review food fraud mitigation plans to include criteria to ensure that audits are robust.

3. Are there examples of food fraud that are considered acceptable because it's been used for a long time... way before we coined the phrase food fraud?

Food fraud is not acceptable in any form, as this term necessarily describes the purposeful adulteration or mislabeling of food products for the purpose of economic gain. The definition is premised on the notion that buyers or consumers will not be getting what they expect.  Marketplace norms and consumer expectations frequently overlay applicable legal requirements as they relate to what is considered “acceptable” in the marketplace.  Where products comply with applicable laws and requirements and also adhere to established marketplace norms, these cases are not encompassed in the definition of “food fraud.” 

4. To be effective should we make purchasing responsible for doing the vulnerability assessment

Dealing with food fraud should be approached from a multidisciplinary perspective involving different departments and different management levels within an organization.  It is up to individual companies to determine how best to allocate resources to their vulnerability assessments, taking into account their own structure and the expertise that different parties in the organization may contribute to the process.  

5. Where can we find a database of foods or ingredients that are more likely to be adulterated?

The USP Food Fraud Database (FFD 2.0) is one such resource that is accessible online (www.foodfraud.org) and that contains over contains over 5000 records, 3600 ingredients, 1100 adulterants, and 2200 primary source references.

6. How do we access the USP database to assess vulnerability? Is there a cost associated with it?

The USP Food Fraud Database (FFD 2.0) is a tool containing a collection of historical data and data analysis tools that are used in an entity’s vulnerability assessment. For example, the information extracted from the database can be used to evaluate the susceptibility of food ingredients or product formulations to food fraud, and to assess the risk of associated potential hazards. To access the FFD 2.0 go to www.foodfraud.org or contact USP at foods@usp.org. Yearly subscriptions are available for purchase. 

7. Is it considered food fraud if product is labeled as champagne or tequila and is sold as such but not from that region?

Not all foods are subject to requirements expressly governing appellation of origin, i.e., requirements restricting the use of specific terms to specific areas of production.  In the absence of clear requirements related to geographical indication, determining the appropriate name or composition of a food product in the marketplace can be complicated. Such decisions can take into account a variety of factors, such as national and local laws and requirements, marketplace norms, and consumer expectations, among others. There are cases in which the use of label terms to mislead consumers as to the origin of a food product would constitute “food fraud,” but it is not possible to develop a bright-line rule or general definition to describe all such cases.

8. If a company declares an allergen that is not present in the product, is it considered labeling food fraud?

Companies are responsible for labeling their products in compliance with applicable legal and regulatory requirements, including those related to declaring the presence of allergens. In some cases, companies may determine that it is appropriate to notify consumers of the potential presence of allergens, even where such allergens are not intentionally added to the food product.  Such determinations are fact-dependent, and it is not possible to generalize about their appropriateness or permissibility. The decision to include voluntary or “precautionary” allergen labeling on a food product does not necessarily constitute “food fraud.”

9. How do you properly handle incidents of food fraud to ensure no recurrence in the industry (other suppliers, even worldwide repercussions)

Unfortunately, the risk of food fraud cannot be eliminated entirely because the complexities of the food chain make it susceptible to fraudulent activities carried out in unpredicted and innovative ways. Food fraud prevention should be a dynamic system that is continuously evaluated and validated, in which new data are fed back into the system and used to help identify gaps, improve vulnerability assessments and optimize mitigation strategies.

10. What's the difference between all the tools?

There are various tools in the market that can help companies assess their vulnerability to food fraud and that provide guidance on mitigation strategies. Some examples are:

  1. Databases containing historical data, such as the USP Food Fraud Database 2.0, Food Protection and Defense Institute Database and HorizonScan. The information extracted from the databases is used, for example, to evaluate the susceptibility of food ingredients to food fraud.
  2. Vulnerability Assessment tools, such as SSAFE/PwC, EMAlert and USP’s Food Fraud Mitigation Guidance. These allow the industry to identify vulnerabilities in the supply chain. The USP Food Fraud Mitigation Guidance also includes a framework for performing an impact assessment and creating an EMA risk mitigation plan.
11. Why is it not considered food fraud with the truffle oil issue? Most truffle oil being passed off as authentic is a chemical reaction of several oils?

Many foods are not subject to “standards of identity,” i.e., requirements that specifically prescribe appropriate names and compositional criteria.  In the absence of clear requirements, determining the appropriate name or composition of a food product in the marketplace can be complicated.  Such decisions can take into account a variety of factors, such as national and local laws and requirements, marketplace norms, and consumer expectations, among others.  There are cases in which whole or partial substitution of food products would constitute “food fraud,” but it is not possible to develop a bright-line rule or general definition to describe all such cases.

12. How much can we rely on government to catch fraud?

Dealing with food fraud effectively requires all stakeholders (industry and government) to work together in a collaborative effort. As examples, governments can:

  1. Support activities aimed at uncovering and responding to existing food fraud incidents, such as developing training, inspection, and enforcement protocols that are specific to food fraud.
  2. Establish a legal framework that includes compliance requirements specific to food fraud and that imposes appropriate penalties for food fraud infractions.
  3. Facilitate the establishment of preventive measures through the publication of guidelines and the provision of training opportunities. 

Ultimately, the government is one entity among many that must work together to address the threat of food fraud.

13. Why is it not considered food fraud with 90% + of wasabi we buy being horseradish rather than actual wasabi?

Many foods are not subject to “standards of identity,” i.e., requirements that specifically prescribe appropriate names and compositional criteria.  In the absence of clear requirements, determining the appropriate name or composition of a food product in the marketplace can be complicated.  Such decisions can take into account a variety of factors, such as national and local laws and requirements, marketplace norms, and consumer expectations, among others. There are cases in which whole or partial substitution of food products would constitute “food fraud,” but it is not possible to develop a bright-line rule or general definition to describe all such cases.