To what extent that you are obligated for food fraud activities?

According to CFIA, food fraud happens when a food is intentionally misrepresented.

Questions: If I am not misrepresenting food products that I make, that means I am not conducting food fraud activities?

Answer: That is not true. You are responsible for any product that you manufactured, processed and labelled. This is inclusive of imported products.

Let’s understand the many ways food fraud can happen:

• Substitution: The products are substituted with items other than what is labelled. For example, cod products are substituted with pollock product
• Adulteration/ Counterfeiting or DIlution: Low-value ingredients are mixed, undeclared and labelled as high-value ingredients. For example, honey in sugar, sunflower oil in olive oil or use of Sudan dye for spices such as chilli powder
• Mislabelling: Products are not labelled correctly. For example, uncertified products labelled as certified organic, net weights are not met.
• Making false claims or misleading statements:  Products do not meet labelling claims requirements and/or misleading consumers. For example, claiming products as made in Canada but the ingredients are sourced from other countries and do not meet the threshold for “made in Canada” claims.

So, what does food fraud means to me and to my business?

Legal obligation: If you are a food importer and food manufacturer, you are ultimately responsible to ensure that the product that you manufacture and/or import meet the Canadian Food Safety Regulations and other countries of sale/use. Even if the food fraud activities occur at the stage of purchasing, you are responsible and liable for the food fraud activities.

Reputation /Food brand: Consumers, in the 21st century, expect transparency and link transparency with branding. Consumers often purchase food products based on product claims. Mislabelling and false product claims shake the consumer trust in your brand, even if it comes from your supplier -it is your brand!

Fact: Food fraud is hard to detect just by looking at the product. It may be tested with chemical and DNA testing.

The question is how you can protect your food business and risk?

GFSI program such as the SQF system call for food fraud programs that include the following

• Risk identification: Identifying food ingredients and product risk based on likelihood ( history, crop failure or shortage, pricing etc.) and how easy it is to be substituted or replaced (format, declaration, claims etc)
• Risk mitigation plan: Based on product risks level, food fraud may be prevented by purchasing from a trusted supplier, verification through Certificate of Analysis, regular supplier audit and product sampling, etc.

Tips: Remember to have procedures to mitigate internal food fraud opportunities. For example, conventional products may be sold as organic products, if internal procedures are not available to control internal food fraud risks.

The challenge with food fraud risk assessment and risk mitigations are 

• It takes a lot of time to assess. Your time = $$$
• Your internal team may have a blind spot for risk assessment, a food safety consultant may be able to identify the crucial missing link that may affect your food brand