Food Fraud and its Impact on the Flavors and

Fragrances Industry
By: Dr. Luke Grocholl, Regulatory Affairs Expert, Sigma-Aldrich - Flavors & Fragrances

Rare items and those of historic significance are highly sought by collectors and connoisseurs. Rare spirits are
no exception. At a recent auction a single bottle of 1903 Laphroaig whiskey sold for $129,000 (€113,000).
Unfortunately for the buyer, the bottle was found to be a fake. The unlucky collector was the victim of food
fraud; the practices of intentionally misrepresenting food for economic gain. It is not just collectors of rare and
expensive alcohol who are impacted. Food fraud is estimated to cost global consumers 30-40 million dollars
(26-35 million Euro) every year. Although economically motivated, the impact of intentionally adulterating
food for economic gain can result in serious, adverse health impact or even death as the infamous 2008
Chinese melamine scandal unfortunately illustrated.

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.

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