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Fraud control measures for suppliers of packaging materials

food fraud packaging material

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ilonar

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Posted 25 October 2018 - 01:55 PM

My company is IFS Food certified and as I was trying to explain again the meaning of Food Fraud to a supplier of packaging materials, I thought I would ask this questions here:

 

Am I the only one who notices that food packaging materials manufacturers/brokers have no idea what food fraud means and that they should also assess  their own suppliers and raw materials to see how vulnerable they are to fraud?

 

The most common answer was "we don't do food, only packaging material" I started writing long emails explaining the terminology and my reason for asking and explaining about IFS v 6.1. Then the answer came :" we don't do anything". I know that this question sounds a little bit retorical, but if we as food producer companies are requested by a GSFI standard to assess the vulnerability of our packaging material suppliers to fraud (including if they have fraud control measures), then whey aren't these companies already asked to do a vulnerability assessment? 

 

By the way, Food Fraud means : Food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.



Sweet'n'low

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Posted 25 October 2018 - 02:16 PM

As a somewhat new SQF practitioner at a food packaging manufacturer, we take the GMP's and SQF code that pertain to our business processes serious. We do a vulnerability assessment and mitigation plan at least semi-annually. The common answer you receive to me sounds like a cop out to taking the initiative in ensuring customers that the product is considered safe. 



Hoosiersmoker

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Posted 31 October 2018 - 03:09 PM

We're a food packaging manufacturer and we were just granted an exemption from the Food Fraud portion of the code by our AB. After a VA we determined there was no opportunity for fraud, composed an exemption request letter outlining the findings of the VA and expanding the explanation for each raw material and finished products. Our AB agreed and granted the exemption. Even though it is not a required element for food packaging, you still have to prove due process arriving at the determination. We also added an annual re-assessment or a re-assessment if our circumstances change that might increase our vulnerability.



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Charles.C

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Posted 31 October 2018 - 10:34 PM

My company is IFS Food certified and as I was trying to explain again the meaning of Food Fraud to a supplier of packaging materials, I thought I would ask this questions here:

 

Am I the only one who notices that food packaging materials manufacturers/brokers have no idea what food fraud means and that they should also assess  their own suppliers and raw materials to see how vulnerable they are to fraud?

 

The most common answer was "we don't do food, only packaging material" I started writing long emails explaining the terminology and my reason for asking and explaining about IFS v 6.1. Then the answer came :" we don't do anything". I know that this question sounds a little bit retorical, but if we as food producer companies are requested by a GSFI standard to assess the vulnerability of our packaging material suppliers to fraud (including if they have fraud control measures), then whey aren't these companies already asked to do a vulnerability assessment? 

 

By the way, Food Fraud means : Food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.

 

Also see this thread -

 

https://www.ifsqn.co...ls/#entry132937


Kind Regards,

 

Charles.C


CMHeywood

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Posted 05 November 2018 - 03:29 PM

There needs to be a better definition of how food fraud relates to packaging as a separate item.

 

If the intent is to prevent food from being fraudulently declared as something that it is not, then the packaging by itself should not be food fraudulent.

 

If someone uses packaging that is not their brand, or uses packaging to declare the food as something that it is not, then this is food fraud.

 

If materials in the packaging are not "food grade" (per intended use), then this is a violation of food contact regulations (fraudulent claims about the packaging but not fraudulent claims about the food).

 

If the materials in the packaging or the packaging are declared to be something it is not (e.g. barrier vs. non-barrier), then this is criminal fraud, not food fraud.

 

If the packaging manufacturer provides what their customer has ordered, where is the food fraud?  Unless there is collusion, I don't see how the packaging manufacturer can control how their customer uses the packaging products.

 

I think the definition should be "...or fraudulent use of food packaging...".

 

The one thing that packaging manufactures can do:  shred or destroy any waste or scrap that has printing that identifies a brand or a food product to prevent a third party from fraudulently using the material.



Gerard H.

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Posted 06 November 2018 - 08:39 AM

Dear Ilona,

 

There may be fraud with the grades, composition and functionality of the packaging:

  • Grades - For example thinner packaging layers
  • Composition - Other substances than mentioned / Other migration properties / Or even use of inferior materials
  • Functionality - Modification of the protection properties (barriers) 

All the above can be done for economic gain.

 

If your suppliers don't take their responsability, you build a "declaration type" questionnaire for them with a general statement and some boxes (with all the relevant topics) to be thicked and to be signed by the responsible person.

 

Kind regards,

 

Gerard Heerkens



Hoosiersmoker

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Posted 06 November 2018 - 12:50 PM

ilonadlb, First let me say Food Fraud is one of the most misunderstood and confused elements of recent years. I have seen many companies start down the fraud path and end up with food safety measures in stead or even include food safety issues in their food fraud plans. Your Food Defense directives will handle all of those issues and it becomes one more thing to have deductions taken for.

Gerard H. All specifications are part of annual contracts signed with all raw material suppliers. In our case we purchase directly from manufacturers and all shipments are sealed, inspected and verified authentic. We include anti-fraud language in our supplier assessments also. That being said, anyone, anywhere in the chain can say one thing and do another including us. Typically in our case considering raw materials, there is VERY little room for economic gain considering the volume we purchase and the rates we enjoy as a result. We're talking fractions of a cent per ton as well as the loss of that business and their reputation should we discover substitution, a risk larger companies are not willing to take. The sheer physical size of most raw materials requires expensive, specialized equipment that make it unattractive for diversion plus the tamper evident trailer seals used. We do inspections and testing on all raw materials during each step in the process from intake to release of finished product, and reject and purge all out of spec materials which prevents potential upstream fraud from carrying through to our product. We do periodic web searches to determine if our product is being re-sold or counterfeited and use Trello to track any food fraud incidents within our industry sector.

 

CMHeywood

The one thing that packaging manufactures can do:  shred or destroy any waste or scrap that has printing that identifies a brand or a food product to prevent a third party from fraudulently using the material.

CMHeywood: Absolutely! We have an extensive recycle program that includes all of the elements you described as well as require an LOD and guarantee from all recyclers annually describing the exact method and disposal they will employ for all trademarked scrap they receive from us.



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CMHeywood

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Posted 06 November 2018 - 03:01 PM

Gerard, I agree with you that undeclared changes in grade, composition or functionality of packaging can be fraudulent, but I disagree that this is food fraud. 

 

Not all fraudulent activities for economic gain are food fraud.  Selling fake Rolex watches would be an example.

 

My point is that food fraud should be concerned only with fraudulent misrepresentation of the food product. 

 

Fraudulent misrepresentation of grade, composition or functionality of packaging would be covered under existing laws that deal with fraudulent transactions, such as selling fake Rolex watches, or claiming that kraft paper bags are high barrier packaging suitable for retort.

 

We don't need a food fraud program stacked on top of already existing laws that deal with fraudulent non-food products.



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Charles.C

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Posted 07 November 2018 - 03:00 AM

Some intriguing speculations. Rolex watches certainly seem unassociated with food other than maybe through  JIT.

 

How about a few explanative references to GFSI, etc, ie  those who are (supposedly) the logical foundation for which all this "mess" seemingly has to comply ? Or the FSMA although they seem to have avoided placing significance priority on this phemomenon.

 

Plus perhaps a few links to actual published articles on food fraud related to packaging. I believe they do exist.


Kind Regards,

 

Charles.C


Gerard H.

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Posted 07 November 2018 - 09:34 AM

Hello,

 

Thanks, the thread and the guideline are here below:

 

https://www.ifsqn.co...raud-guideline/

https://www.ifs-cert...-Guide_1805.pdf

 

Kind regards,

 

Gerard H.



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CMHeywood

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Posted 07 November 2018 - 05:33 PM

I had mentioned fake Rolex watches as an example of product fraud. 

 

Gerard, it is interesting to note that the document in your links is titled "Product Fraud", not "Food Fraud".

 

Fraud is a large category (including activities such as posing as a police officer).  Product Fraud is a subset of Fraud in general.  Food Fraud is a subset of Product Fraud.

 

I am claiming that fraudulent claims about packaging by itself (grade, composition or functionality) is Product Fraud, and not Food Fraud. 

 

What about a situation where a supplier has made fraudulent claims about the packaging, but the food is accurately described?  I would consider this to be product fraud and not food fraud.

 

Laws and regulations about Product Fraud have been in existence long before Food Fraud became a hot topic.  I don't think we should conflate the two.







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