9 replies to this topic

[matthewcc]

Hello all,

 

We have completed our food fraud vulnerability assessment for SQF certification and identified fruit juice concentrates that we use as components as having a high level of food fraud risk from historical/news accounts (fraudulent adulteration, substitution, and dilution) and also because they are in the form of liquids, which tends to cause the loss of any visual/macroscopic traits that would allow food fraud detection.

 

So, my question is, because I have been getting a lot of resistance from coworkers and upper management to adding a test that would detect food fraud of the common types that would affect fruit juices, would any of the following offer sufficient food fraud mitigation for food fraud for SQF Code 2.7.2?:

• Organic certification audits that our fruit juice supplier goes through
• Supplier approval process
• Organoleptic (appearance, odor, and taste) evaluation of the juices

 

We manufacture dietary supplements in the United States and have certification for food safety from SQF and GMP from NSF.

 

I apologize in advance if this has been covered already in the forums (I was unable to search the forums because of a database error).

 

Thank you,
Matthew

[G M]

I'm not sure any of those really address fraud mitigation, although the specifics of your supplier approval process could cover some types.

 

I would expect a general chemistry panel type analysis to cover the dilution and a few others.  Do a few in the beginning with a new supplier, then at random later on if everything is acceptable.  In house or third party, but not results the supplier provides.

[matthewcc]

Thanks, another aspect of this is I am told that, because we are using fruit juice concentrates "only" as flavorings, not as active ingredients, then this means we are not required to perform authenticity tests that mitigate against food fraud risk.  (I am not sure I have expressed that properly, but this idea could originate from 21 CFR 111.75 differences between requirements for dietary ingredients and those for components.)

 

Anyway, what are your thoughts on how the use of a juice concentrate as only a flavoring and not as an active ingredient would affect what we need to do to mitigate against food fraud risk?

[Brothbro]

If food fraud is identified as a risk, you would need to perform some kind of testing to mitigate that. Off the top of my head you could perform identity testing on the juices to look for common adulterants, but I know this type of testing can be expensive especially when looking for multiple sources. By dilution, does that mean diluting an expensive concentrate with a bit of some cheaper juice to bulk it up a bit? It'd be hard to justify that simply tasting the product would be able to detect that. I'm not experienced with juice chemistry tests, but I don't know how acidity/%solids testing would detect that either. If chemistry works I'd stick with that because it'll be much cheaper and could even be done in-house with minimal investment.

 

I don't think you could handwave fraud risk by saying the juice concentrates are simply flavoring rather than an active ingredient, the regulation states that all components have to be vetted in a certain way, to my knowledge it makes no differentiation on whether the component is a "active ingredient" or not. Since ingredient statements have to be truthful, you'd need to somehow verify that the juice used only contains the fruit you're saying it does.

 

The regulation does state that you can rely on a supplier's COA as long as you're qualifying those results periodically, provided the supplier is performing fraud testing themselves. So in a sense the supplier approval process could account for this. You would just have some extra hoops to jump through for suppliers of components with high risk of fraud.

Edited by Brothbro, 28 January 2025 - 11:38 PM.

[SQFconsultant]

We center on this one primarily in addition to the other 2 with the first being more subjective as it is supplied by the supplier. 

 

• Organoleptic (appearance, odor, and taste) evaluation of the juices

Edited by SQFconsultant, 29 January 2025 - 12:50 AM.

[GMO]

I think there are a few ways you can look to mitigate this and it depends on where in the supply chain you've identified the risk.

 

You can look to your supplier's controls.  How do they ensure authenticity?  Do they do any testing themselves?  Is there an organisation you can join who are doing routine in market testing that you can see?  There are a few in the UK not sure about the US.

 

How do you qualify your supplier and make sure their standards of quality continue to be good?  Do you audit them?  Do you do regular scorecard reviews?

 

Then I'd also look as to tampering en route.  So is the juice supplied in tamper evident packaging?  

 

I would expect periodic testing either at your supplier or with you to look at taste, pH and Brix to look for gross contamination.  

 

But most of all I'm not familiar with this being a high risk on the scale of things like olive oil, honey or beef.  What has made you think it's such high risk?  

[matthewcc]

One main reason that we identified fruit juices as being at high risk of food fraud is because of sources such as the following that indicate that fruit juices are historically, recently, and frequently frauded by fraudulent adulteration, substitution, and dilution (examples of news, government/regulatory, and scientific sources, respectively):

 

• https://trello.com/c...d-coconut-water (It's in the high risk category according to those who summarize news stories relating to food fraud.)
• https://blog.foodfra...14-R43358-2.pdf (It's on the government's radar in the US and could be the focus of regulatory action at some point. Not that we are in Europe, but according to the European Committee on the Environment, Public Health and Food Safety, fruit juices are included in the top 10 food products that are most at risk of food fraud.)  Check this out, too; it is recent and interesting/shocking:  https://www.justice.gov/opa/pr/fruit-juice-manufacturing-company-and-its-former-president-plead-guilty-food-safety-crimes
• https://www.mdpi.com...-3049/24/6/1014 (Analytical work is dedicated to detecting juice fraud. This is particularly interesting to me since my background is in chemistry.)

 

Another main reason is that the form of the juices, being liquids, contributes to the ability to conceal any economically motivated food fraud.  For example, it would be virtually impossible to fake a whole lemon or banana, but once something is in the form of a liquid, all the macroscopic traits are obliterated, and you can't even use microscopic analysis like you could with a powder.  This is why a lot of what I read focuses on color or taste schemes like adding an artificial colorant or sweetener, respectively, to try to fool the senses of someone evaluating a juice for authenticity.  The more scientific papers recognize the need to perform analytical testing that cannot be fooled, e.g., UV and fluorescence spectroscopy.  For example, "The detection of citrus juices’ adulteration is particularly challenging due to the similarity of citrus juices in terms of organoleptic and physicochemical characteristics and molecular composition." Quality and Authenticity Control of Fruit Juices-A Review https://www.mdpi.com...-3049/24/6/1014  Connected to this is that some juices, being more expensive than others, causes them to be at higher risk of food fraud--e.g., orange juice is sometimes blended with cheaper juices such as those of grapefruit or lemon.  I don't know how to compare to olive oil or honey in terms of food fraud risk.  They are all liquids, so there is that in common.

 

The final main reason that is more specific to one supplier is an issue we had with the supplier asking our purchasing (and no one in QC or QA) if we were OK with shipping their frozen juice concentrates on a non-frozen carrier, against their recommended transport conditions of less than zero degrees Fahrenheit.

 

This is just a general overview, but I would also point out that juices are only one of the categories of components that are at high risk of food fraud. Others such as powders can be at high risk too, but we already perform other testing on those such as microscopic analysis to mitigate against food fraud risk. I brought up juices in part because you can't run microscopic analysis on them to detect food fraud.

 

I think there are a few ways you can look to mitigate this and it depends on where in the supply chain you've identified the risk.

 

You can look to your supplier's controls.  How do they ensure authenticity?  Do they do any testing themselves?  Is there an organisation you can join who are doing routine in market testing that you can see?  There are a few in the UK not sure about the US.

 

How do you qualify your supplier and make sure their standards of quality continue to be good?  Do you audit them?  Do you do regular scorecard reviews?

 

Then I'd also look as to tampering en route.  So is the juice supplied in tamper evident packaging?  

 

I would expect periodic testing either at your supplier or with you to look at taste, pH and Brix to look for gross contamination.  

 

But most of all I'm not familiar with this being a high risk on the scale of things like olive oil, honey or beef.  What has made you think it's such high risk?  

[GMO]

Thanks.  I suppose thinking with the head that I used to have a site with 100s of ingredients, we couldn't test them all, we wouldn't do microscopy on it all or taste tests or chemical tests and we were buying in multiple spices and dried herbs.  We'd get some sampling from time to time with food forensics (UK though) and also have shared results from other sites. 

 

But ultimately you cannot test something safe.  And what's more if they are supplying the product as an aseptic bag in box or drum, you won't easily be able to sample it on arrival.  Don't even bother asking them to send you a separate sample, it's not even worth the time testing it.  Anyone willing to commit fraud will be willing to send you a sample of the echt stuff just to then adulterate the actual ingredient.  

 

You could do all kinds of testing and if you have a genuine fear of adulteration then it's probably worth working with a lab to develop the right ones for you.  But for gross contamination I'd still use pH, Brix and organoleptic.  But as I've said, that's going to be difficult to do at intake.

 

This is the kind of company we'd use, not sure if there's something similar in the US.

 

Food Testing Laboratory UK | Food Forensics

[tadelong]

Anyone willing to commit fraud will be willing to send you a sample of the echt stuff just to then adulterate the actual ingredient. 

This is a good point! We have 18-tonne tanks of layer feed. The supplier used to send along 250g sample bags as 'proof.' Not only were they essentially useless from a fraud detection standpoint, they did not exhibit the actual issues we face, ie buildup of fine powder clogging the augers.
 

[Karenconstable]

This is a tricky one, Matthew, because as you said, the concentrates are being used as flavourings in supplements, not as major ingredients of food products.

 

You're right that there is a long history of food fraud in juice concentrates, so you're right to say fraud is likely to occur. 

 

Controversially, you could also argue (perhaps, I don't know enough about how the concentrates are used to say for sure), that any fraud is unlikely to have a food safety impact on consumers.  And this could be used to reduce the overall vulnerability to medium risk, rather than high risk, which would reduce the amount of testing needed in your mitigation plan. 

 

For example (and again, I don't have enough informaton about your situation to say you should do this), a manufacturer might include comments in their vulnerability assessment like this:

 

(a) fraud in fruit juice concentrate typically takes the form of dilution with water, added exogenous sugars, undeclared flavour additives or use of wrong (cheaper) fruit*, 

(b) therefore any frauds that are likely to occur are unlikely to make the concentrate unsafe and

© the quantity of the concentrates in the final product is low enough (perhaps) that there would be minimal impact on the safety and quality of the finished product if the concentrates were fraud-affected.

 

Again, I'm not saying that you don't need to test, and I couldn't guarantee that any SQF auditor would be okay with this, but if the impact of fraud is expected to be low you may be able to justify a lower vulnerability rating, for example by using a likelihood versus severity matrix.  With a lower vulnerability rating for the ingredient you can implement a less rigorous mitigation plan with less frequent testing.

 

Re. mitigations, definitely include a background check on your supplier, as that is a low cost, one-off job.  It involves exploring whether they have been involved in any questionable trading in the past.  And, as other respondents said, definitely don't rely on statements from your supplier that they are doing the right thing. 

 

*Also, be wary of any concentrate for which colour impacts the quality or price of the material, as it would be tempting for a supplier to add undeclared colouring agents, and that WOULD have a potential food safety impact.  Likewise for undeclared flavour compounds, which could impact the truthfulness of any claim you make on your finished product, such as 'natural' or 'no artifical flavours'. 

 

There are a lot of ifs and buts in this post (food fraud is tricky!), but I hope it provides some useful insights,

 

Karen