Food Fraud and its Impact on the Flavors and Fragrances Industry

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Types of Food Fraud

Assuring the authenticity of food and food ingredients should be part of any food quality and safety management system. For this reason the Global Food Safety Initiative (GFSI) as well as the US FDA (21 CFR 117.130(b)(2)(iii)) require food fraud mitigation strategies. Effective food fraud mitigation strategies begin with identifying where food is vulnerable to fraud. To identify vulnerabilities in flavors and flavor ingredients, one must first understand the different types of food fraud. Although there are many different forms of economically motivated fraud of food, they can be summarized into seven categories:

• Concealment – Covering defects or other undesirable properties with an undeclared ingredient.
  • Example: Applying food coloring to fruit to disguise blemishes or make it appear fresher.
• Counterfeiting – Cheap copies of branded food sold as the known, branded product. Intentionally making a label or name very close to a familiar brand can also be considered counterfeiting. This later type of counterfeiting is sometimes called simulation.
• Dilution – The volume or weight of food is misrepresented by adding an inert, undeclared ingredient.
  • Example: Adding beet fibers or dried marigolds to saffron or watering down milk.
• Diversion –Diverted materials lack the supply chain control and traceability necessary to ensure food safety and misrepresent their legitimacy to consumers. This broad category that includes:
  • Diverting products from legitimate markets to those for which they were not intended.
  • Unreported overproduction of material then sold in an unreported manner.
  • Outright theft and resale of foodstuffs.
• Mislabeling – Intentionally changing the label to disguise a product or ingredient.
  • Example: Changing the expiration date beyond the accepted parameter.
• Substitution – Using a lower cost ingredient with similar properties in lieu of the declared ingredient.
  • Example: Listing a cheap vegetable oil as extra-virgin olive oil or declaring horse meat as beef.
  • Partially substituting a cheaper ingredient is also form of dilution, such as partially substituting corn syrup in honey.
• Unapproved enhancement – Adding an undeclared ingredient to give appearance of desirable properties.
  • Example: Adding melamine to milk to artificially increase its perceived protein content.

Food Fraud Vulnerability

Vulnerability analysis is a recommended way to identify and prevent food fraud. First, each ingredient in the food manufacturer’s supply chain should be assessed based on three criteria:

• Ease of committing or concealing fraud
  • Is the fraud difficult to detect?
  • Is there an easy way to commit the fraud?
  • Is the supply chain complex, making traceability difficult?
  • Is the food/ingredient stored in an unsecure manner with easy access?
• Economic incentive for fraud
  • Is the food/ingredient high in cost?
  • Is there a large market for the food/ingredient?
  • Is there a recent, significant increase in cost (e.g. tariffs)?
  • Is there a recent, significant decrease in availability (e.g. low crop yield due to draught or storms)?
• Historical or known incidents of fraud
  • Does the food/ingredient have a history of fraud?
  • Does the manufacturer/supplier have a history of fraud?
  • Does the country/region of origin have a history of fraud?

The more “yes” answers on the list above greater the incentive or opportunity for food fraud, and thus the greater the risk of fraud. When reviewing honey or olive oil, for example, every bullet elicits a yes response, likely accounting for the relatively high number of incidents of fraud for these ingredients. Where foods are determined to be vulnerable to fraud, mitigation strategies should be implemented to identify or reduce the risk of fraud. The mitigation strategy should be specific to likely food fraud. For example, if a risk of dilution or substitution is considered, testing to confirm purity should be performed. NMR analysis of honey, for instance, can be used to confirm the material has the expected sugars, amino acids, and other molecules in the expected ratio for pure honey.

Natural Flavors

When evaluating flavors and fragrances ingredients for likelihood of fraud, the same questions should be asked as those for food. For most aroma chemicals, purity and identity can be determined with a high degree of confidence significantly reducing the risk of fraud. A vulnerability analysis of flavor ingredients, however, shows natural flavors and essential oils are at risk for food fraud.

For natural flavors, the biggest risk is substituting or partially substituting a natural flavor with its synthetic counterpart. Synthetic aroma chemicals may have similar purity and organoleptic properties as their natural analog, but may be considerably lower in cost. Natural raspberry ketone (also called frambione or 4-(4-Hydroxyphenyl)-2-butanone) may cost 7 to 8 times that of synthetic frambione. For some ingredients the price differential between natural and synthetic is even more pronounced. Vanillin, one of the popular flavors in the world, may exhibit a hundred fold price difference, or more, for the natural verses the synthetic material. As such the conformance to natural requirements should be verified.

Testing and verification of natural status should be established as a food fraud mitigation strategy for natural flavors. Factors such as price differences between the natural and synthetic ingredient, historical incidents of fraud, and traceability of the ingredient supply chain may help determine the frequency of testing and verification.

Carbon-14 analysis is currently considered the industry benchmark for natural origin verification. Carbon-14 is a naturally occurring, but unstable isotope of carbon. The concentration of carbon-14 in natural products matches that of atmospheric carbon-14 at the time of plant growth. However, some factors may influence the natural concentration of carbon-14. Since the atmospheric concentration may change over time, materials derived from wood sources grown over decades may not match the current carbon-14 signature concentration. There may also be some regional impact where factors such as heavy industrialization my influence carbon-14 levels. A well-documented supply chain will help answer questions that may arise from carbon-14 analysis. Despite its shortcomings, carbon-14 is one of the best methods to verify natural product origin.

Although carbon-14 can verify an aroma chemical is of natural origin, this technique does not elicit any information on manufacturing or processing methods. Although the US regulatory definition of natural flavors require that the flavor be derived from natural (animal, botanical, or microbiological) origin (21 CFR 101.22(a)(3)), other regulatory bodies may restrict the manufacturing processes or reagents used to declare a flavor as natural. The EU, for example, requires that only “traditional food preparation processes” are allowed in manufacturing natural flavors ((EC) No 1334/2008 art. 3.2.(c)). A thorough understanding of the regulatory requirements and the available verification techniques are required to thoroughly review authentication methods.

Essential Oils

Another factor to consider when interpreting the risk of food fraud is the complexity of the flavor. With more components in a flavor comes a greater opportunity for fraud. Essential oils can be very vulnerable to fraud so additional scrutiny should be applied. Natural vanilla extract could be diluted, for example, and the dilution masked by addition of synthetic vanillin and other flavor ingredients. Most essential oils are complex mixtures but can lose components during processing. Like vanilla extract, synthetic flavors could be added to substitute for those lost components. Although many oils are stable for long periods of time, some may have components that can decompose giving undesirable aroma characteristics. In fraudulent oils, these undesirable fragrances could be masked by addition of aroma chemicals. Oils from some geographic regions may command greater demand and cheaper oils from other regions could be fraudulently labeled. Some simple oils could be completely reformulated with synthetic ingredients. Garlic oil, for example, consists of dozens of components, however, it is primarily composed of five or six sulfide compounds. Synthetic blends of those primary components could be fraudulently passed off as natural oils.

If an essential oil is expensive, and the supply chain is complex, the risk of food fraud may be significant and a mitigation strategy should be employed. Fingerprint analysis by gas chromatography or infrared spectroscopy along with carbon-14 analysis can help to identify fraudulently labeled essential oils.

Oils and spices are also vulnerable to dilution. Spices are particularly vulnerable because it may be difficult to obtain good homogenous samples and verification methods are more limited. Regardless of the material in question, there are some value added characteristics of flavor ingredients unscrupulous suppliers may attempt to leverage that cannot be verified in a laboratory. Kosher, halal, and organic certification all may command a premium price, but may be difficult or impossible to analytically verify. Relying on suppliers who use only reputable third party certification of their products helps reduce the risk of food fraud.

Summary

The best defense against food fraud is building strong, transparent relationships with reputable suppliers. On-site audits, regular documentation review, and requirements for reputable third-party certifications all reduce the risk of economically motivated adulteration. The frequency and type of reviews/audits can be determined by a risk based approach including a vulnerability analysis.

A risk-based approach should be used to determine the vulnerability of ingredients and supply sources to economically motivated adulteration. The frequency and types of verification activities should be determined based on the supply chain risks involved. Food fraud erodes consumer trust, adds unneeded costs to the food market, and may even cause serious harm. All parties in the flavors and fragrances supply chain should integrate a robust food fraud prevention program into their food safety and quality systems to minimize these occurrences. Food fraud can impact every one of us and we should all do our part to aid in its elimination.