The life science business of Merck KGaA, Darmstadt, Germany operates as MilliporeSigma in the U.S. and Canada.

Food Fraud
Impact on Flavors

Luke Grocholl
 Sun Up Foods – A Case Study

01
Sun Up Foods, Inc.

Unsweetened Orange Juice

Concentrate –
A Model Success Story
 Established in 1985 with ~$5
million USD annual sales
 By 1990 sold $100 million USD
annually
− Success in a volatile market
− Grew by a strategy of
competitive pricing
A Hidden Ingredient

Beet Sugar Syrup

 Color difficult to detect in orange juice concentrate
 Sugars similar to the natural sugars in orange juice
 Beet sugar syrup much less expensive
 The “unsweetened” orange juice concentrate was 10% -
20% sugar beet syrup
Built to Deceive

Elaborate Scheme
 Beet sugar delivered at night and stored in
hidden tanks
 Tanks hidden behind an electrical control panel
 Sugar fed to the orange juice in stainless steel
pipes hidden inside a fake PVC drainage system

Criminal Charges FCC Forum, December 2014

 7 Executives charged
− $200,000 in fines
− Owner sentenced to 104 months in prison

Estimated impact on consumers was $22,000,000 (₹1,500,000,000) and at least one

negative medical reaction to the sugar
 What is Food Fraud?

02
Food Fraud – Deception for Profit

Economically Motivated
 The intentional mislabeling, misbranding, or
misrepresentation of food for economic gain.
 Estimated consumers overcharged up to $50
Billion* annually due to food fraud.
 Destroys consumer confidence.
 May introduce significant health risks

*Forbes, April 12, 2018

Food Fraud May Result in More Than Just Economic Harm

2008 Chinese Milk Scandal

 Melamine added to milk products to give false
indication of higher protein content
− Prime target was baby formula
 Melamine can cause kidney stones and renal
failure
 300,000 victims in China
− 54,000 babies hospitalized
− 6 infants died
 Major crackdown
− 3 Business leaders sentenced to death
− 2 executed, 1 suspended
− 3 Business leaders sentenced to life in prison
− Sold the melamine
 Substitution

Dilution
Concealment

Food
Counterfeiting Fraud Mislabeling

Unapproved
Enhancements Grey Market Production
Diversion theft
Food Fraud Descriptions
Substitution
 Using a lower cost ingredient
with similar properties in lieu of
the listed ingredient
− Honey substituted with cane
sugar
Dilution
 Adding an undisclosed, inert
ingredient
− Colored, dried grass added to
saffron
− Sunflower oil diluted with
mineral oil
Concealment
 Adding an undisclosed
ingredient with the intent to
cover-up undesirable properties
− Adding undisclosed coloring
to fruit to cover defects
Counterfeiting
 Passing off a lower value
material as a higher value
material
− Colored/flavored corn syrup
sold as honey
Mislabeling
 Intentionally changing the label
to pass off lower cost material
as higher cost product
− Labeling (toxic) Japanese star
anise as Chinese star anise
− Identifying recycled cooking
oil as vegetable oil
Unapproved Enhancements
 Adding an undeclared material
to give the appearance of
desirable properties
− Adding melamine to give false
impression of protein content
Grey Market Production / Theft / Diversion

Non-counterfeit food sold outside of

normal channels
 3rd party manufacturer sells excess unreported stock 3rd Party manufacturer
 Sale of stolen food or ingredients Represents inherent risk.
 Food diverted from legitimate buyer
Highest risk associated with
 Food sold under intentionally deceptive packaging with the some regions/countries.
intention to misrepresent
 Food Fraud Prevention

03
How to Prevent Food Fraud
VACCP: Vulnerability Assessment, Critical Control Point

1
Identify vulnerabilities within
the supply chain

2
VACCP works in conjunction Establish a critical control point
with food safety and quality
to identify fraudulent food
systems.

3
Monitor and test the system for
continual improvement
Vulnerability Assessment – Information to Consider

Historical Incidents Emerging Concerns Economic Factors

Is there a history of fraud? Have situations changes that Have overall price/value recently
may lead to fraud? increased?

Complexity of Supply Storage/Distribution Material Value and

Chain Facility Location Market Size

Can the fraud be traced? Is the storage/distribution facility Is the material very valuable
easily compromised? and/or feed into a large market?

Existing Control Ease of Access to

Measures Availability Materials

Is it easy or difficult to commit Is the food readily available? Is it easy to access the materials
food fraud? to commit food fraud?
Comprehensive Food Quality System

Food Safety
Quality Systems
(GMP – 21 CFR 117)
(ISO 9001)
(HACCP/HARPC)

Food Defense
(21 CFR 121)
Food Fraud
(VACCP)
(VACCP)

16
 Flavor ingredient
vulnerability

04
Vulnerability Assessment Example – Synthetic Flavoring Substance
Mitigation Strategy
Fraud Risk Detectability
Needed?
Low - Economic value is tied to organoleptic
Concealment properties, which would be impacted by High No
concealment

Counterfeiting Low – Non-authentic material is easily detected High No

Dilution Low – Low purity material is easily detected High No

Mislabeling Low – Mislabeled material easily detected High No

Substitution Low – Substituted substances easily detected High No

Low - Materials economic value is tied to their

Unapproved
organoleptic properties, which would be impacted High No
Enhancements
by enhancements

Little economic motivation for fraud OH

Benzyl alcohol
Vulnerability Assessment Example – Natural Flavoring Substance
Mitigation Strategy
Fraud Risk Detectability
Needed?
Low - Economic value is tied to organoleptic
Concealment properties, which would be impacted by High No
concealment

Counterfeiting Low – Non-authentic material is easily detected High No

Low to Moderate - Natural material could be

Dilution Moderate Yes
diluted with the synthetic analog
Moderate - Natural flavors are generally more
Mislabeling Moderate Yes
expensive to produce than synthetic flavors

Substitution Low – Substituted substances easily detected High No

Low - Materials economic value is tied to their

Unapproved
organoleptic properties, which would be High No
Enhancements
impacted by enhancements
O
Economic motivation for fraud O
HO ~100x cost
due to price difference between HO
of synthetic
synthetic and natural H
H
H3CO
H3CO
Vanillin Natural Vanillin
 Critical Control Point – Natural Validation
Carbon 14 Analysis

CO2

O2
14CO
2
Natural abundance: 1 ppt
C + 1ppt 14C
Half life: 5,730 years

Botanical derived materials have a 14C ratio almost equal to natural, atmospheric
abundance
Critical Control Point – Natural Validation

All natural origin: 90% - 105% expected 14C

Synthetic / natural mix: <90% expected 14C

Synthetic origin: No 14C

Sampling, material origin, and analytical factors result in some variation in results, but
overall origin can be determined
Continual Improvement

Monitor the System

Is it working as planned?

Test the System

Put intentional failures through the
system. Did the system identify and
stop them?

Corrective Actions
What changes do you make where
opportunities or failures are found?

22
Mitigation Strategy Example – Natural Flavouring Substance

Criteria
Acceptance Limit Frequency Monitoring Activity Corrective Actions
Measured
Annual verification –
Select 5 random natural
Natural Sampling frequency?
90 – 105% Expected products released in
verification: Every third batch Sampling method?
Ratio calendar year and
Carbon 14 Ratio Test lab?
review C14 testing
frequency and results

Determined by
vulnerability assessment –
will vary by material and
other factors.
• Source/origin
• Cost of material
• Historical incidents
 Essential Oils

05
Vulnerability Assessment – Essential Oils

Example: Lavender Oil

 Complex mixtures
− Typically consists of dozens of components
− ~20 different components mostly at <1% with
linalool >30%
 Many components also available as synthetics
 Quality can vary considerably depending on
feedstock, harvesting, and processing
 Often high cost
Varieties of Lavender Oil

The Good Scents Website lists 46 different

lavender oils (thegoodscentscompany.com)

Lavender oil authentication

challenges
 GC results and organoleptics
vary based on the type/origin of
oil
 Organoleptics vary based on
type/origin of oil
 IR spectrum very similar for all
types of lavender oil

Synthetic enhancements very difficult to detect

26
Vulnerability Assessment Example – Essential Oil

Mitigation Strategy
Fraud Risk Detectability
Needed?
High - Off-notes could be concealed with added
Concealment Low Yes
ingredients.
Moderate – Synthetic mixture could be passed
Counterfeiting Moderate Yes
off as an essential oil
High – Dilution with odorless mineral or
Dilution High No
vegetable oil.
High – Similar oil of a lower value passed off as
Mislabeling Low Yes
higher value oil.

Substitution Low – Not a risk for essential oils High No

Unapproved High – Synthetic top-notes or bottom-notes

Low Yes
Enhancements added
Counterfeit Example – Garlic Oil

Garlic Oil Counterfeit Garlic Oil

 Consists of dozens of primarily  4-6 components
sulfur-containing components − Primarily diallyl sulfide and
− Most <1% concentration other linear sulfides

S
S

S
S S

S
S S

S S
S S

Satyal, P., et al., Foods. 2017,

6(8), 63.
Verification tests – Essential oils

Verify physical parameters

 Specific gravity, viscosity, solubility
 Identifies dilution
Compare to fingerprint analysis
 IR, RAMAN, Gas Chromatography
 Identifies counterfeit
Test naturalness
 14C Analysis
 Identifies counterfeit

Economic motivation – high-quality essential oils can be very expensive and subject to
volatile market drivers - the risk for fraud
 Supply Chain Control

06
Supply Chain Control

Greenland
Russia

Sweden
Canada
Germany

United States

China

Brazil

South Africa
New Zealand
Managing The Supply Chain
 In person supplier audits
 Risk-based
 Reputable third part audits
 Reliable food safety schemes
 Short supply chain with visibility to the original
manufacturer
Other Value-Added Claims

Supply chain control may be the only method

if no test exist to verify value-added claims
 Summary

07
Summary

Vulnerability
Economically assessment
Motivated Many types can identify
of food fraud risk

The right tests Comprehensive

(control points) Some types of risk-based
can identify fraud are only approach is best
fraud controlled defense
through supply
chain control
Questions
?