Food fraud and vulnerability

EMA and consumer trust

Ask consumers if food fraud, including economically motivated adulteration (EMA), is a ‘new’ phenomenon and they may think about the current 2017 Brazilian meat scandal, the 2013 European horsemeat scandal or the 2008 Chinese melamine adulteration of milk powder, which hospitalized 52,000 children and killed six. However, as outlined in a 2014 U.S. Congressional Research Service report, EMA goes back thousands of years, with examples of adulterated wine, oil and spices.

EMA costs the global economy an estimated $49 billion (€46 billion) a year and has the potential to cause illness or death or simply defraud the consumer buying a product that is not what it claims to be. Even if food safety is not compromised, EMA can destroy consumer trust.

Food fraud and pet food industry

A 2015 Price Waterhouse Cooper-report detailed megatrends affecting consumer trust in their food. Amongst others, this highlighted both food safety and food integrity as concerns. With ‘pet parents’ now expecting the same standards of food safety and integrity in pet foods, these findings are equally important for our industry.

Pet owners and the sector were shocked in 2007, when the biggest recall in the history of the industry occurred, following use of Chinese wheat gluten adulterated with melamine and cyanuric acid. 

Widely used in pet food and sold based on protein content, ‘high’ protein wheat gluten commands a higher market price. 

Deliberate adulteration with cheaper material that artificially increases protein content, therefore opens the way to sell adulterated material for more money. The ‘melamine crisis’ was a clear-cut case of food fraud. Post-crisis, anecdotal evidence on social media indicated a greater interest in pet owners making their own ‘homemade’ pet food, due to loss of trust.

Raised standards

Since the 2007 crisis, and with pet parents’ greater expectations, standards of both food safety control and food fraud prevention have been raised in the pet food supply chain. This is evident with the development of the U.S. Food Safety Modernisation Act (FSMA) and enhancement of global third party food safety certification systems, like BRCv7, to include food fraud vulnerability assessment. 

FSMA imposes wide ranging regulatory requirements, including control of import safety and supplier verification. BRCv7 now includes greater focus on supplier management. 

Think like a criminal

An essential requirement of these ‘new’ food control systems is systematic assessment of where EMA can occur in the supply chain, a process facilitated using a tool called Vulnerability Assessment Critical Control Point (VACCP). VACCP is similar to ensuring safe food through application of Hazard Analysis Critical Control Point (HACCP) in that both use objective risk assessment. 

With EMA, VACCP helps identify which raw materials might be susceptible to adulteration (e.g. wheat gluten), where this might happen in the supply chain (e.g. a trader) and what controls are required (e.g. supplier quality assurance). Due to the complexity of supply chains, VACCP is not easy and requires a skilled team. It is also important to ‘think like a criminal’: what materials are worth adulterating for economic gain and where in the supply chain can this be most easily done? 

History shows that food fraud evolves as new opportunities present themselves. To maintain effectiveness, it is important to identify potential new EMA threats using ‘horizon scanning’. For example, increased EMA of identity preserved materials (e.g. ‘organic’) might be an area of concern with the continued humanization of pet food and one that might be identified through this process.

Recently seen in the pet food industry, it is also important to note that finished products can still be the subject of food fraud, with ‘fake’ super-premium products packed in similar packaging appearing in the market. 

Cloak and dagger approach

To complete our approach to pet food safety and trust, we also need to consider a process known as Threat Analysis Critical Control Point (TACCP). TACCP requires a ‘cloak and dagger’ approach to look internally on our own site at where malicious contamination might happen and implement controls.

In conclusion, humanization means we must now consider total pet food protection and help ensure consumer trust through a combined system, based on HACCP, TACCP and VACCP.