Tag Archives: labeling

Susanne Kuehne, Decernis
Food Fraud Quick Bites

In That Wine, There Is No Truth

By Susanne Kuehne
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Susanne Kuehne, Decernis
Wine, Decernis Food Fraud database
Find records of fraud such as those discussed in this column and more in the Food Fraud Database.
Image credit: Susanne Kuehne.

Booze bootleggers are still quite active since there is a lot of money exchanging hands in the high-end wine and liquor business. Fake premium Penfolds wines, which can fetch several hundred dollars per bottle, as well as acclaimed brands of adulterated whisky, were discovered and seized in a liquor store in Cambodia. Besides the fake beverages, the raid also uncovered fake labels and packaging materials.

Resource

  1. Australian Associated Press (November 28, 2019). “Fake Penfolds wine seized in raid on bootlegging operation in Cambodia”.The Guardian.

 

 

Production line, NiceLabel

Farm-to-Fork Transparency: How Digitized Labeling Can Prevent a Major Allergen Recall

By Lee Patty
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Production line, NiceLabel

For consumers and brands alike, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal. Therefore, to prevent a health and business disaster, best practices around allergen labeling must be top of mind. Luckily, technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.

No one wants to face a recall, but have you done enough to prevent one from happening to you? More than 650 food products were recalled last year in the United States alone. And one of the leading causes might just be the easiest to prevent: Undeclared allergens.

According to the Q2 2019 Stericycle Recall Index, undeclared allergens are the leading cause of U.S. food recalls, accounting for 48.4% of food recalls from the FDA and 62.9% of food pounds recalled by the USDA. This statistic becomes more alarming considering that roughly 11% of US adults have a food allergy, according to JAMA.

Enacted in 2004, the Food Allergen Labeling and Consumer Protection Act (FALCPA) stipulates that all packaged food regulated under the Federal Food Drug and Cosmetic Act (FFD&C) comply by listing major food allergens. “Major allergens” refers to milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soybeans, and for nuts and shellfish, the species must be declared.

For brands, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal, resulting in costly recalls or litigation. However, the impact to consumers can be even greater when one small mistake can cause serious illness, or worse, death. To prevent a health and business nightmare, best practices around allergen labeling must be top of mind.

However, with constantly changing legislation, this can be easier said than done. For instance, in a move that outpaced the FDA, Illinois issued a state law requiring sesame labeling. And in the UK, Natasha’s Law was recently introduced, requiring companies to label all food ingredients on fresh pre-packaged food after 15-year-old Natasha Ednan-Laperouse died of a sesame allergy from a sandwich that didn’t list all the ingredients.

The need for optimal allergen labeling is clear, so how can organizations ensure allergens are clearly labeled on their products and meet existing standards while preparing for future requirements?

Though the underlying principle behind a clear label is simple, the process of designing such labels can be multifaceted and difficult to streamline—especially if labels are designed, printed and managed by separate users across a franchise or store network. And this challenge is multiplied further when products reach across international boundaries. But technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.

Disorganized Sprawl: A Major Hurdle to Effective Labeling

When implemented properly, modern label management can cost-effectively centralize labeling, reducing inefficiencies and human error. However, before this can happen, there are a few common roadblocks that may make standardizing the labeling process challenging.

One issue may be a sprawl of legacy equipment that is not integrated into a cohesive network. For instance, a legacy labeling system may only support certain label printers while certain manufacturers of direct marking equipment may only support their own propriety brand of printers. In another sense, a lack of standardization can also make it difficult to efficiently integrate labeling with other business solutions like manufacturing execution systems (MES) and enterprise resource planning (ERP) systems.

A damaging impact of sprawl is adoption of a wide range of different labeling applications across various facilities. This will result in inconsistent label formatting, the need to create the same label multiple times, and the need to accommodate different systems and printers. Consequences of this may be a lack of centralized storage when everything is saved locally, complex user training encompassing many software programs, an increased burden on IT, and a great deal of extra administration and human intervention to maintain and update labels.

Another problem with a disorganized ecosystem for labeling is that quality assurance inevitably suffers because tracing a label’s history or implementing standardized approval processes can be difficult or impossible. To accurately track labeling, it’s necessary to have a production log stating where and when labels were produced and who produced them. Having such a log and using it effectively requires centralization or else it can become difficult to track different versions or enforce universal approval processes for altering templates.

Implementing Modernized Labeling to Improve QA

Modern label management systems can help suppliers and manufacturers standardize and control marking packaging or label production across an entire organizational ecosystem. These solutions feature a central, web-based document management system and provide a reliable storage space for label templates and label history. This will enable changes and updates to be tracked centrally, so local facilities can access uniform and accurate templates to produce labels.

An ideal label management system can also interface with a multitude of direct marking and labeling printers, even if they are from different manufacturers, and it can integrate labeling and direct marking with a business system’s master data, which eliminates manual data entry errors. This decreases upfront capital expenditures in more costly efforts to standardize equipment, provides a system that is easy to integrate with partners, saves costs generated from having to discard product or rework labels, and increases a company’s ability to implement unified, organization-wide labeling processes.

Centralized Labeling is Easily Delivered Through Cloud

To many, the thought of migrating legacy labeling to a centralized system or investing a large sum of resources into centralizing labeling may seem inordinate or daunting. However, cloud technology makes migrating to a modern label management system feasible for organizations of all sizes.

With the cloud, designing labels and ensuring quality assurance becomes far more accessible. Additionally, the software-as-a-service (SaaS) model doesn’t require the capital investments or operations and maintenance upkeep associated with costly IT infrastructure and is easily scalable depending on business needs. This is a game changer for small to medium sized businesses who can now benefit from a centralized labeling system because of the cloud.

The Benefits of a “Single-source-of-truth”

In addition to other benefits, integrating a modern label management solution with other business systems allows users to access a “single-source-of-truth.” This allows for enforceable, specific user roles with logins for each user as well as traceability and transparency across all factories that produce products. The traceability from being able to monitor a “single-source-of-truth” is a critical component to farm-to-fork transparency because it can provide an accurate production log overviewing label versions and changes, so companies can pinpoint the locations and causes of labeling inaccuracies and fix them instantly.

A modern label management system also enables organizations to nimbly respond to new regulatory requirements because alterations only need to be made in one location, new templates can be previewed before going to production, and nutrition and allergen functionality can be easily formatted so that it is clear and stands out to the consumer. This increases labeling consistency and accuracy, and saves time when rules change and when new products need to be incorporated during a merger or acquisition.

Futureproofing and Ensuring Consumer Safety with Allergen Labeling

In today’s world, food and beverage manufacturers must rise to the challenge of changing regulations while meeting the call of shifting customer demands and integrating themselves within greater business ecosystems and extended supply chains. In the case of allergen labeling, this may mean preparing labels for different countries, which have varying standards for labeling allergens like sesame, royal jelly, bee pollen, buckwheat and latex, or ensuring labels can be altered quickly when new products are rolled out or when bodies like the FDA revamp standards.

Companies that implement modern label management solutions position themselves to adapt to competition and regulations quickly, implement solutions that can easily be integrated with partners in a supply chain, and streamline quality control. This can help improve productivity, reduce labeling errors, increase collaboration, and prevent product recalls. But most importantly, it helps ensure the safety of consumers everywhere.

Doug MacDonald, Oracle Retail
Retail Food Safety Forum

To Protect Food Quality, Start With the Data

By Doug Macdonald
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Doug MacDonald, Oracle Retail

Last month, the FDA held a public meeting to discuss its New Era of Smarter Food Safety initiative, with a rallying call to create a more “digital, traceable and safer food system.”

FDA Deputy Commissioner for Food Policy and Response Frank Yiannas made it clear that the FDA is not replacing FSMA. Rather, the goal is to build on it, recognizing changes in the food industry over the last 10 years and the technologies available to tackle new challenges.

This isn’t surprising given continuing quality issues resulting in food recalls and shelf withdrawals. Last year, two major outbreaks of E. coli that were tied to consumption of romaine lettuce made a mark on industry perceptions, impacting customer trust, brand loyalty and the bottom line of companies involved were affected. Research by Allianz found recall costs could reach $10,000,000 for significant events.

To achieve the FDA’s goal of end-to-end traceability, the amount of information carried by every food item needs to increase, as will information about its location and condition in the supply chain. Grocers are at the sharp end of the food chain, meaning everything the FDA is proposing will impact them. As well as being merchandisers, they are brand-owners in their own right. They work directly with farmers and growers, they are directly involved in food safety, storage and distribution, and they feel the impact of recalls more than most. Unlike others in the food chain, they interact with consumers daily. This is important to note, since consumers are expecting communication on recalls immediately. In a recent study of more than 15,800 global consumers, 66% of respondents noted that they expect immediate notification of a product recall and another 28% stated they expect notification within a week.1 Furthermore, 88% said if a retailer immediately informed them of an issue, they would be more likely or slightly likely to trust them. The study also found that only 16% of consumers completely trust the product information provided to them from retailers today. In short, the impact of recalls extends far beyond the empty store shelf, and gives the industry even more reason to strive for safety.

High-Tech Next Steps

The FDA plans to publish a strategic blueprint early in 2020 of planned actions to meet its goal, but food brands and grocers need not wait to act. Proven technologies like brand compliance solutions, combined with emerging blockchain track and trace solutions and Internet of Things (IoT) sensors can add new depth and detail to traceability in the food supply chain, and these new technologies are already helping grocers and retailers keep consumers safe.

As retailers have sought a better means to track supply chain movements, blockchain technology has emerged as a potential way forward. Originally developed to manage financial transactions involving cryptocurrency, blockchain has proven to be capable of providing a verifiable record of the movement of goods through a supply chain. In fact, one major retailer has been piloting blockchain for more than a year and has already proven its value on produce items, cutting traceability times from more than a week to a matter of seconds. Some want to go even further and use IoT sensors to monitor the condition (e.g., temperature) of food products in the supply chain. Together, blockchain can help trace the path a product took through the supply chain and IoT can monitor the environmental conditions en route, providing a more cohesive picture of its supply chain journey.

But while supporting a few simple products with one ingredient and a one-step supply chain, such as fruits or vegetables, is one thing, scaling to address the needs of the average private brand retailer—now handling more than 10,000 active products from 2,000 production sites globally—is another. Managing the complexity of a product like tiramisu or a ready-made meal with dozens of ingredients, all coming from different sources, needs a different approach. To address the complexity, many are turning to brand compliance solutions—trusted, real-time repositories of information spanning the entire supply chain. For example, those using brand compliance solutions now have complete visibility of the ingredients in their private label products, helping them ensure labeling accuracy and transparency for consumers. Brand compliance tools also bring improved visibility of the food supply chain, enabling them to verify the status of manufacturing sites and respond quickly to food quality issues.

This combination of detailed product and supplier information makes brand compliance a foundational enabler for any blockchain/IoT-based initiative to improve supply chain visibility and traceability. For example, using brand compliance solutions, grocers can:

  • Confirm the ethical compliance of the supply chain at the point of selection or review, while using blockchain/IoT to monitor the ongoing conformance to these standards
  • Validate shelf life claims during formulation, while blockchain/IoT monitors logistical movement and environments to optimise products’ freshness
  • Record products’ formulation and ingredients to ensure safety, legal compliance and labeling accuracy, with blockchain/IoT monitoring the ongoing conformance to these standards
  • Rapidly identify potential risks across the entire formulation and supply chain, while tracking the affected batches to stores using blockchain and IoT

This convergence of static factual data (e.g., formulation, nutrition and allergens) linked to near real-time traceability and checking offers grocers confidence in the data and supports the consumer’s confidence of an actual product in their basket.

Looking Ahead

It seems clear that the food business is moving in the same direction as airlines and banks and becoming much more data driven. For grocers looking to keep pace, they will need to:

  • Treat data as a core competency. This means hiring information experts, investing for the future, and using data to identify ways to deliver better, safer products.
  • Create a customer-centric value promise. Grocers must go beyond regulatory compliance and use data to improve consumer transparency, support ethical sourcing initiatives, expand sustainable packaging and speed innovation.
  • Go above and beyond. Rather than waiting for FDA direction or simply complying with requirements, brands should take matters into their own hands, hold themselves to high markers and get started now.

In the future, improving the way that we manage the food supply chain is not just about how well we work with trucks and warehouses; it’s about how use information. The FDA’s initiative makes a clear statement that now is the time to modernize our food supply chains. As we look ahead to a new decade, the industry can come together to improve food safety and protect consumers, and we need not wait for the FDA’s blueprint or even the new year to get started.

Reference

  1. Setting the Bar: Global Customer Experience Trends 2019. (2019). Oracle Retail. Retrieved from https://go.oracle.com/LP=86024.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

In France, Appellation Matters, Not Just for Wine

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, Decernis, Strawberries
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

The 2013 horse meat and lasagna scandal, and the 2018 kiwi fraud issue are just some of the product traceability cases that are under public scrutiny in France. For the second time in France’s Lot-et-Garonne region, strawberries labeled French turned out to originate in Spain. Part of the harvesting labor was outsourced and was therefore more difficult to track. This makes it easier for mislabeling and food fraud to enter smaller-scale agricultural and agricultural cooperative businesses.

Resource

  1. Annick Berger (June 22, 2019). “Apres les faux kiwis, voici les fausses fraises francaises”. Capital.fr Retrieved from https://www.capital.fr/entreprises-marches/apres-les-faux-kiwis-voici-les-fausses-fraises-francaises-1342718
Daniel Erickson, ProcessPro
FST Soapbox

Establishing Preparedness Initiatives to Mitigate the Effects of Recalls

By Daniel Erickson
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Daniel Erickson, ProcessPro

Despite manufacturers’ best intentions to provide safe products for consumers, notifications about recalled products appear in news headlines with increasing regularity. The CDC reports that each year, 48 million Americans experience foodborne illnesses, resulting in a reported 128,000 hospitalizations and 3,000 deaths. Behind these statistics are recall trends that can lead to operational and financial instability, and a loss of reputation for companies in the marketplace. Proactive measures and tools adopted by experienced food and beverage manufacturers can help mitigate the potentially harmful effects of these product recalls by establishing preparedness initiatives.

Recall Essential Facts

A recall is defined as a request for the return of a product from the market due to a defect or safety concern resulting from a variety of issues including improper labeling or contamination, which places the manufacturer at risk of legal action. Product recalls can be issued by either the manufacturer or a governmental agency, but it is the sole responsibility of the company to properly recall and notify consumers of unsafe products. Recalls are categorized as either voluntary or mandatory, with the majority falling under the voluntary classification. In the case of a voluntary recall, a manufacturer has greater control over the process with less stringent procedures, review and paperwork. While both have the same potential for negative effects and significant legal costs, a voluntary recall is preferred by manufacturers. Implementing an industry-specific ERP solution with a documented recall preparedness plan and mock recall capabilities provide the necessary tools for either scenario, as recalls are inevitable in today’s manufacturing environment.

Recall Trends

In the USDA- and FDA-regulated markets, comparatively, there have been a slightly higher number of recall incidents in the beginning months of 2019 versus 2018. Mispackaging is identified as one of the primary recall issues, involving packaging a finished good into the wrong container. Another trending recall cause involves not properly identifying an ingredient on the packaging label. Both of these manufacturing errors resulted in the labels not providing an accurate reflection of the product, which could be potentially harmful to consumers if the undeclared ingredient(s) include one of the common allergens. Well-documented and properly executed internal manufacturing processes, in addition to an automated ERP solution, create checks and balances and assist in generating accurate, compliant packaging and nutrition fact panels to meet the requirements of consumers and regulatory bodies.

A third recall trend of 2019 is being driven by consumer complaints in regards to foreign materials such as metal fragments, plastics or rubber pieces in finished goods. This is caused by incomplete testing, lack of or faulty material detection equipment, including metal detectors, x-rays and other devices used during manufacturing. Due to an increasing number of these types of incidents, the USDA has issued a guidance document requiring manufacturers to maintain updated documentation of their internal procedures in their hazard analysis and critical control point (HACCP) plan. This guidance necessitates follow up with federal inspectors regarding any adjustments made to the plan. HACCP information recorded within an ERP solution helps to identify and control potential hazards before food safety is compromised—providing quality, consistent and safe consumables for the public.

Progress towards fewer FDA food and beverage recalls continues due to an increase in FDA inspections as well as manufacturers’ success in proactive measures to stay abreast of FDA requirements. However, bacterial pathogenic concerns including Listeria, Salmonella and E. coli continue to be prevalent recall culprits. This has resulted in the FDA utilizing the Whole Genome Sequencing (WGS) Program in an attempt to protect consumers from foodborne illness. By swabbing manufacturing environments and sending samples to WGS, the DNA strains are documented in a centralized public database—holding manufacturer’s accountable for processing and sanitation control. When an outbreak occurs, the database is able to locate possible matches that help health officials identify the source of contamination, and stop outbreaks more quickly, thereby avoiding additional widespread illnesses. As the database grows in size, so will the speed of investigations to determine the root causes of illnesses. This program has the potential to not only stop outbreaks from spreading but also includes proactive applications for increasing the safety of the food and beverage industry as a whole.

ERP’s Role in Recall Preparedness

An industry-specific ERP’s real-time forward and backward lot traceability, detailed record keeping, allergen/attribute tracking and efficient, documented processes support end-to-end recall management functionality to maintain compliance. With preventative measures such as establishing supplier relationships, conducting quality control testing and documenting quarantine procedures, an ERP solution works to identify gaps and prevent future recalls. Accurate product labeling is one of the key factors of recall prevention and food and beverage ERP software handles the intricacies of packaging and label creation, such as ingredient and allergen statements, nutrient analysis, expiration dates and lot and batch numbers—creating an audit trail that allows items to be located promptly in the event of a recall. As part of a sound food safety plan, mock recalls conducted regularly encourages familiarity with internal recall processes, as well as allows for adjustments to be made as needed. With a comprehensive ERP to generate lot tracking reports, manufacturers are able to identify and locate contaminated products in order to notify clients, vendors, consumers and government agencies quickly in the event of a recall—helping to minimize harmful effects in the marketplace as well as legal action.

The trends identified in recent recalls issued by the FDA and the USDA, thus far in 2019, demonstrate that manufacturers need to be proactive in how they respond in order to mitigate the detrimental effects that recalls can have on companies and to public health. With the increasing scrutiny from the FDA and USDA, along with an aware consumer base, it’s important for forward-thinking businesses to address the eventuality of a product recall with sound food safety and HACCP plans and an industry-focused ERP software solution that promotes, supports and helps manage preparedness and responsive action, if needed.

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FDA, USDA Formally Agree to Regulate Human Food Made from Cells of Livestock and Poultry

By Food Safety Tech Staff
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Today FSIS and FDA announced a formal agreement regarding the regulatory oversight of human food products derived from the cell lines of livestock and poultry. The agencies will jointly oversee regulation of these cell-cultured products to ensure both safe production as well as accurate labeling.

The agreement involves a joint regulatory framework in which the FDA will manage cell collection, cell banks, and cell growth and differentiation. During the cell harvest stage, FDA will transition oversight to FSIS and from there, FSIS will oversee production and labeling of the human food products that are derived from the cells of livestock and poultry.

“We recognize that our stakeholders want clarity on how we will move forward with a regulatory regime to ensure the safety and proper labeling of these cell-cultured human food products while continuing to encourage innovation,” said FDA Deputy Commissioner for Food Policy and Response Frank Yiannas in a USDA press release.

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FDA Report on E. Coli Outbreak in Romaine Lettuce Points to “Significant” Finding of Strain in Sediment of Water Reservoir

By Maria Fontanazza
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The November 2018 outbreak of E.coli O157:H7 infections linked to romaine lettuce caused 62 illnesses across 16 states. The FDA zeroed in on the Central Coast growing regions of northern and Central California as being responsible for the contamination. The outbreak was declared over on January 9 and yesterday FDA released the report, “Factors Potentially Contributing to the Contamination of Romaine Lettuce Implicated in the Fall 2018 Multi-State Outbreak of E.Coli O157:H7”, which provides an overview of the investigation.

The report states that a sediment sample coming from an on-farm water reservoir in Santa Maria (Santa Barbara County, California) tested positive for the outbreak strain of E. coli O157:H7. Although this particular farm was identified in several legs of the Fall 2018 traceback investigations that occurred in the United States and Canada, as well as being a possible supplier of romaine lettuce in the 2017 traceback investigations, the FDA said that the farm is not the single source of the outbreak, as there is “insufficient evidence”. The traceback suggests that the contaminated lettuce could have come from several farms, because not all tracebacks led to the farm on which the contaminated sediment was found.

“The finding of the outbreak strain in the sediment of the water reservoir is significant, as studies have shown that generic E. coli can survive in sediments much longer than in the overlying water. It’s possible that the outbreak strain may have been present in the on-farm water reservoir for some months or even years before the investigation team collected the positive sample. It is also possible that the outbreak strain may have been repeatedly introduced into the reservoir from an unknown source,” stated FDA Commissioner Scott Gottlieb, M.D. and Deputy Commissioner Frank Yiannas in a press announcement.

(left to right) Stic Harris, FDA; Matt Wise, CDC; Dan Sutton, Pismo Oceano Vegetable Exchange; Scott Horsfall, California Leafy Greens Marketing Agreement discuss the first E.coli outbreak involving romaine lettuce during a panel at the 2018 Food Safety Consortium. Read the article about the discussion.

Although the exact route of contamination cannot be confirmed, the FDA hypothesizes that it could have occurred through the use of agricultural water from an open reservoir, which has increased potential for contamination.

The investigation teams also found evidence of “extensive” wild animal activity and animal burrows near the contaminated reservoir, as well as adjacent land use for animal grazing, all of which could have contributed to the contamination.

Although FDA did not directly name the farm in the report, it provided a link about the recall that was initiated by the farm, Adam Bros. Farming, Inc., in December.

Considering the significant effect that the past two E.coli outbreaks involving romaine lettuce have had on both the public as well as the produce industry, FDA made several recommendations on preventive measures that leafy greens growers and industry can take to avoid such pathogenic contamination, including:

For growers:

  • Assessing growing operations to ensure they are in line with compliance to FSMA and good agricultural practices
  • Making sure that any agricultural water that comes into direct contact with the harvestable portion of the crop, food contact surfaces and harvest equipment is safe and sanitary
  • Address and mitigate risks associated with agricultural water contamination that can occur as a result of intrusion by wild animals
  • Address and mitigate risks associated with the use of land near or adjacent to agricultural water sources that can lead to contamination
  • Conduct root cause analysis whenever a foodborne pathogen is identified in the growing environment, agricultural inputs like water or soil, raw agricultural commodities, or “fresh-cut” ready-to-eat produce

For the broader industry:

  • The development of real-time procedures that enable rapid examination of the potential scope, source and route of contamination
  • All leafy green products should have the ability to be traced back to the source in real time, and information include harvest date. In November, FDA requested voluntary labeling [https://foodsafetytech.com/news_article/cdc-alert-do-not-eat-romaine-lettuce-throw-it-out/] to help consumers identify products affected during an outbreak
  • The adoption of best practices in supply chain traceability

Resources

  1. FDA report: “Factors Potentially Contributing to the Contamination of Romaine Lettuce Implicated in the Fall 2018 Multi-State Outbreak of E.Coli O157:H7”
  2. FDA statement from Commissioner Scott Gottlieb, M.D. and Deputy Commissioner Frank Yiannas
  3.  FDA investigation of source of E.coli O157:H7 outbreak linked to romaine lettuce
Karen Everstine, Decernis
Food Fraud Quick Bites

How Food Fraud Happens

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

The food industry has been hard at work over the past few years implementing food fraud mitigation plans in response to Global Food Safety Initiative (GFSI) certification program requirements. GFSI defines food fraud as:

“A collective term encompassing the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health.” (GFSI Benchmarking Requirements, 2017)

GFSI then further defines the terminology of food fraud by citing seven categories (shown in the following diagram).

GFSI, Food Fraud
Used with permission from GFSI

In the Food Fraud Database, we categorize food fraud records using the following terminology (with examples):

  • Dilution/substitution
    • Substitution of an entire fish fillet or partial dilution of olive oil with another oil
  • Artificial enhancement
    • Addition of melamine to artificially increase the apparent protein content of milk or the addition of coloring agents to spices
  • Use of undeclared, unapproved, or banned biocides
    • The use of chloramphenicol in honeybee populations (where not permitted) or the addition of hydrogen peroxide to milk
  • Removal of authentic constituents
    • The sale of “spent” spice powder (used in the production of an oleoresin) as a whole spice powder
  • Misrepresentation of nutritional value
    • Infant formula that does not contain the required nutritional content
  • Fraudulent labeling claims
    • Misrepresentation of label attributes related to production method (organic, kosher, halal, etc.)
  • Formulation of an entirely fraudulent product (using multiple adulterants and methods)
    • The sale of “100% apple juice” that consists of sugar, water, malic acid, flavor, and color
  • Other
    • This includes counterfeits, theft, overruns, etc.

Harmonization of food fraud terminology is frequently discussed, so I thought it might be useful to provide information on how our definitions relate to the GFSI terminology:

GFSI category “Dilution”: This category maps directly to our category dilution/substitution. The reason we combine these into one category is that the intent is the same: To replace the weight or volume of a product. This can occur either through partial or full substitution of a liquid product, a granulated product, or swapping an entire intact product such as a fish filet. One of the GFSI examples for substitution is “sunflower oil partially substituted with mineral oil”, which could just as accurately be described as dilution.

GFSI category “Substitution”: As noted above, this category maps directly to our category dilution/substitution. However, we would not consider the use of hydrolyzed leather protein in milk (one of the cited examples) to be dilution/substitution because it is not used to replace weight or volume. We would view that as artificial enhancement of the protein content of milk.

GFSI category “Concealment”: We do not include a category focused on concealment because all food fraud involves concealing some aspect of the true contents of the food. One of the examples cited in this category is “poultry injected with hormones to conceal disease.” The use of antibiotics, anti-fungal agents or other substances to reduce bacterial load or mask deterioration would be classified, in our system, as the use of undeclared, unapproved or banned biocides. The use of coloring agents on fruit to improve appearance would also be classified as artificial enhancement.

GFSI category “Mislabeling”: Since all food fraud is, to some extent, mislabeling, we reserve the use of the term fraudulent labeling claims to those label attributes that describe production processes (organic, kosher, etc.). With the exception of falsification of expiration dates, the other examples cited would not be classified by us as mislabeling. The sale of Japanese star anise, which is potentially toxic, as Chinese star anise (a different species) is dilution/substitution and a health risk to consumers. The sale of cooking oil that has been recovered from waste streams and illegally produced is also a form of substitution that poses a potential health risk to consumers.

GFSI category “Unapproved enhancements”: This GFSI category aligns nicely with our category artificial enhancement, and both examples cited are nicely illustrative of the concept, which involves the fraudulent addition of a substance specifically for its function (not as a replacement for weight or volume).

GFSI Category “Gray market production/theft/diversion”: The production and sale of food products through unregulated channels would all be classified in our category called other. Because these forms of food fraud involve the sale of food outside of regulatory control, prevention measures will generally be substantially different from the prevention of fraud within legitimate supply chains.

GFSI Category Counterfeiting: This GFSI category is similar to the gray market production/theft/diversion category in that it involves intellectual property infringement and production outside of regulatory control. It would similarly be classified in our other category.

Megan Nichols
Retail Food Safety Forum

How Can We Make Food Labeling More Consistent?

By Megan Ray Nichols
2 Comments
Megan Nichols

Consistent Inconsistencies

Current food labels may seem to possess a wealth of information, but they’re often challenging to read even if you know what you’re looking for. Additionally, studies have shown that even accurate food labels don’t work —they lead to no significant dietary changes. Even posting the calorie counts on fast food menus did little to change people’s eating habits.

It might sound as simple as telling consumers to read the ingredients labels on the items that they’re purchasing. The problem with this—aside from the fact that ingredients are often printed in a painfully small font—is that you almost need a degree in chemistry to understand the components. This confusion is a big issue with processed foods that contain a variety of chemicals to protect the flavor of the food and preserve it during storage.

When it comes down to it, choosing healthy foods isn’t the problem—or at least, not the only problem. Picking a healthy option isn’t as complicated as doing your taxes or choosing a mortgage when you purchase a home. We as consumers have plenty of information available to us when it comes to eating healthy. The problem is the fact that it’s easier and usually cheaper to choose the unhealthy option. You can buy a can of soda for $0.50, while a bottle of water often costs more than $1 at a soda machine or convenience store.

No One Reads Them Anymore

Another big issue with nutrition labels is that no one bothers to read them anymore. One survey found that two-thirds of young adults in the Minneapolis-St. Paul area don’t bother reading nutrition labels or worry about the nutrition content of what they’re eating.

While the survey didn’t explore why adults were no longer utilizing nutrition labeling, it’s likely due to a combination of consumer distrust and confusion. People either don’t trust that the labels contain accurate information, or they’re merely confused by the information presented in that format.

The Healthwashing Dilemma

How many times have you walked into the grocery store and chosen a brand based on whether or not it had “All-Natural” or “Organic” labels? Even if these phrases are written on the label, that doesn’t necessarily mean that the food contained within falls under either of those categories. That’s where the problem of healthwashing occurs.

Food packages will slap these labels on their product even if it doesn’t apply—a company can claim that their product is “all natural” and still use pesticides on it. Some businesses use products like pyrethrins, which are potentially dangerous pesticides derived from natural sources—specifically, the chrysanthemum flower.

Food companies don’t typically like to advertise this information because it might discourage potential consumers from choosing their brand, especially if the user is concerned about their health and is trying to remove all chemicals and pesticides from their food chain.

Fixing the Labeling Problem

What can we do to encourage consumers to pay attention to nutrition labels? The biggest challenge lies in making these labels more consistent and transparent. That task is more complicated than it sounds since there is no regulation or standardization in nutrition labeling. Clean labeling could be the solution.

Five key facets define clean labels — Simple ingredients lists, transparency in ingredients and packaging, no flowery language, accurate images and fresh food—are top priorities for consumers, with transparency being in the highest demand. However, these labels face the same problems as current nutrition labels—a lack of standardization. When asking more than 27,000 people in 31 countries what they thought clean labeling meant, more than a third had no idea, according to a report from Packaged Facts.

Many companies have started to transition to clean labels, but no law currently requires businesses to do so.

The Need for Change in Food Labeling Consistency

Food labeling could potentially help consumers make healthier choices if they were more accurate and easier to understand. Eliminating the flowery language that currently defines food labeling is one step in the right direction. The federal government— or, more specifically, the FDA— may need to step in as well to create standards that each company can be held to so that consumers know what exactly is in their food, no matter the brand.

Food labels are on nearly everything that we buy, except for fresh meat and produce. It’s time to create a standard and transparent label that everyone can understand.

Karen Everstine, Decernis
Food Fraud Quick Bites

“Natural Flavor” Claims

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

The company that produces the very popular flavored sparkling water brand LaCroix is facing a class action lawsuit that alleges false claims of the product being “all natural.” The suit alleges that certain flavor chemicals used in the beverage are, in fact, artificial ingredients. These flavor chemicals include limonene, linalyl propionate (linalool propionate), linalool and ethyl butyrate (ethyl butanoate). While these flavor chemicals can be synthesized, they are naturally occurring chemical constituents and can therefore be derived from natural sources.

The safety of the beverages is not at issue; this is a labeling question. The suit states that linalool is “used in cockroach insecticide,” which is inflammatory and misleading. Chemical compounds, including those used as food ingredients, naturally have multiple applications and this does not have any bearing on the question of whether they are safe to use in foods.

Presumably, the labeling issue of whether these flavor chemicals were naturally or synthetically derived will be addressed as the suit progresses. This suit does, however, highlight some of the challenges we have in tracking food fraud information related to flavors.

Flavors are big business. Appealing flavors enabled LaCroix to make unsweetened sparkling water explode in popularity. If you have been on the Institute of Food Technologists Annual Meeting expo floor, you have seen the prominent displays and creative food samples offered up by the big flavor houses. It is a competitive business and very proprietary. The FDA labeling requirements for flavors allow them to be listed generally as “spice,” “natural flavor,” or “artificial flavor” (or a combination of those). This makes tracking and standardizing public records of food fraud related to flavors challenging.

Our data includes more than 60 of food fraud related to flavors represented as “natural.” Most of these records are linked to vanilla extract or various essential oils. However, we have also captured a handful of records that address misrepresentation of synthetic flavor chemicals as naturally-derived. This includes records for linalool and ethyl butyrate, among others such as vanillin and linalyl acetate. However, none of these records describe publicly reported incidents of fraud for naturally-derived flavor chemicals. The records are based on peer-reviewed publications aimed at method development for authentication of natural flavors.

Added value claims such as “natural” tend to increase food fraud risk because the costs of production can be so much higher. While an ingredient like vanilla extract is certainly one example of this, we do not tend to see the same level of evidence of food fraud potential for naturally-derived flavor chemicals in public records. When our users need to conduct a food fraud vulnerability assessment for a natural flavor that is a proprietary blend of flavor chemicals, we suggest that they incorporate information from the entire natural flavors group into their assessment. Given the proprietary nature of flavor blends and FDA labeling requirements, it is not feasible for us to track every individual flavor blend in our database.

Fortunately, given the importance of flavors to the food industry, flavor companies have a vested interest in preserving their client relationships and public reputation by ensuring flavors labeled as “natural” qualify for that label claim.

Resources

  1. The Decernis Food Fraud Database is a continuously updated collection of food fraud records curated specifically to support vulnerability assessments. Information is gathered from the scientific literature, regulatory reports, media publications, judicial records, and trade associations from around the world and is searchable by ingredient, adulterant, country, and hazard classification.