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BRCGS 9 clause 5.4.3 - Vulnerability Assessment

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SAEED AFZAL

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Posted 13 February 2025 - 08:42 AM

Hi,

Can anyone explain the BRC-9 clause 5.4.3 "economic factors which make adulteration or substitution more attractive" in vulnerability assessment. Thanks 


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GMO

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Posted 13 February 2025 - 09:23 AM

Think about things which bring value to an ingredient or product and how they could be substituted or adulterated to increase the value or reduce the input cost.

 

So, for example:

  • The sudan dye issues in chilli and paprika (adulteration).  There was a higher value placed on more "red" chilli powders and paprikas meaning that adding the dye increased the value of the ingredient.
  • Manuka honey (substitution).  The claim / origin statement of "manuka" is a premium product in the eyes of consumers and production volumes are low, substitution with another honey or sugar solution will reduce the input costs while the high sales price remains the same.
  • Similarly, another substitution "extra virgin olive oil" is at a premium price because it's more expensive to produce.  Substitution with cheaper olive oils not from the first press or other oils reduces the input cost.
  • Same kind of substitution case with the horse meat scandal.  Horse meat is cheaper than beef so substitution of part of that ingredient meant the input costs were lower.
  • Fake brands, again substitution.  There have been various cases of alcohol particularly which were claimed to be a brand but actually faked completely.  Again this is to have lower input costs but sell at the same price as the major brand.
  • Adulteration of milk.  This was a famous Chinese case where melamine was added to milk as it "tricked" the incoming milk testing devices to make it look like it was higher in protein and, so, higher prices.

 

I'll have a ponder if I can think of any more.  Generally though there is also another economic argument why fraud is so attractive in food, the penalties are tiny.  


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