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Would a temporary ingredient substitutions be considered food fraud?

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Posted 22 March 2019 - 06:11 PM

Hi all, 


Quick question: Would a temporary ingredient substitutions (ie if there is a supply issue with normal ingredient) be considered food fraud? As we grow we are trying to find backup suppliers and trying to figure out what using those "backups" would mean NFP wise. Our product is sold direct to consumers and I just haven't found any clear answers anywhere else on the proper way to handle these types of supply issues. I hope this isn't a silly question, just a little lost  :wacko:



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Posted 22 March 2019 - 06:54 PM

No, it would not be.


Considering that you have or will have a supplier approval program you would follow your own guidelines for how to qualify an emergency supplier.

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Posted 25 March 2019 - 09:45 AM

It's really going to depend on the nature of the temporary ingredient as compared to the normal ingredient, in the context of the overall product.
If you're buying a genuinely like-for-like replacement from an alternative source then that's absolutely fine, but if you're e.g. swapping an organic ingredient for a non-organic ingredient then that is not acceptable unless you've got approval to do so from your organic body.

If you're making a specific claim then it could also be considered food fraud - for example, if you label that your product uses "100% British Beef" then swapping to another source would be fraudulent unless you change your labels.


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Posted 25 March 2019 - 11:40 AM

As pHruit mentioned, it's important to compare the two products and check for anything that can affect your product or invalidate claims. Allergens can be a tricky one; often customers require products free of certain/all allergens and substituting one ingredient from one supplier to another may affect the direct allergen content or even may-contain.

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