FOOD SAFETY

TECHNICAL TOOLKIT FOR

ASIA AND THE PACIFIC

Food fraud
Intention, detection
and management 5

Wagyu
 FOOD SAFETY
TECHNICAL TOOLKIT FOR
ASIA AND THE PACIFIC

Food fraud
Intention, detection and
management
5
Food and Agriculture Organization of the United Nations
Bangkok, 2021
FAO. 2021. Food fraud – Intention, detection and management. Food safety technical toolkit for Asia
and the Pacific No. 5. Bangkok.

The designations employed and the presentation of material in this information product do
not imply the expression of any opinion whatsoever on the part of the Food and Agriculture
Organization of the United Nations (FAO) concerning the legal or development status of any
country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or
boundaries. The mention of specific companies or products of manufacturers, whether or not these
have been patented, does not imply that these have been endorsed or recommended by FAO in
preference to others of a similar nature that are not mentioned.

The views expressed in this information product are those of the author(s) and do not necessarily
reflect the views or policies of FAO.

© FAO, 2021

Some rights reserved. This work is made available under the Creative Commons
Attribution-NonCommercial-ShareAlike 3.0 IGO license (CC BY-NC-SA 3.0 IGO;
https://creativecommons.org/licenses/by-nc-sa/3.0/igo).

Under the terms of this license, this work may be copied, redistributed and adapted for non-
commercial purposes, provided that the work is appropriately cited. In any use of this work, there
should be no suggestion that FAO endorses any specific organization, products or services.
The use of the FAO logo is not permitted. If the work is adapted, then it must be licensed under the
same or equivalent Creative Commons license. If a translation of this work is created, it must include
the following disclaimer along with the required citation: “This translation was not created by the
Food and Agriculture Organization of the United Nations (FAO). FAO is not responsible for the
content or accuracy of this translation. The original English edition shall be the authoritative edition.

Any mediation relating to disputes arising under the license shall be conducted in accordance with
the Arbitration Rules of the United Nations Commission on International Trade Law (UNCITRAL)
as at present in force.

Third-party materials. Users wishing to reuse material from this work that is attributed to a third party,
such as tables, figures or images, are responsible for determining whether permission is needed
for that reuse and for obtaining permission from the copyright holder. The risk of claims resulting from
infringement of any third-party-owned component in the work rests solely with the user.

Sales, rights and licensing. FAO information products are available on the FAO website
(www.fao.org/publications) and can be purchased through [email protected].
Requests for commercial use should be submitted via: www.fao.org/contact-us/licence-request.
Queries regarding rights and licensing should be submitted to: [email protected].
Abstract
Food fraud occurs when a food supplier intentionally deceive its
customer about the quality and contents of the foods they are
purchasing. While food fraud is often motivated by profit, some forms
of food fraud can also pose a direct threat to the health of customers
and consumers. Detecting food fraud is a challenge because consumers
alone cannot detect them, and food fraudsters are usually innovative in
the ways they avoid detection. In Asia and the Pacific, the risk of food
fraud is estimated to be high, due to the high demand for premium
quality food combined with an increasingly globalised food supply
chain. This document describes the key aspects of food fraud, and
discusses a set of measures that food safety authorities can take
in order to stop the persistent problem of food fraud. Among these,
legal interventions combined with the use of technological tools
seem to be promising tools in combatting the phenomenon. The
adoption of a definition of food fraud at the national level could support
the identification of targeted actions, and the tools which help the
alignment of national legislations and measures with Codex Alimentarius
food standards support national food safety authorities in addressing
the problem.

Keywords
Food fraud, food safety, food quality, food adulteration, food standards,
food legislation, consumer protection, Codex Alimentarius, Food and
Agriculture Organization of the United Nations (FAO),
Asia and the Pacific.

iii
iv Food fraud Intention, detection and management
Contents

Abstract iii
Keywords iii
Acknowledgements vi

1. Introduction 1
2. Food fraud and food safety 3
2.1. Background 3
2.2. State of the art in Asia and the Pacific 6
2.3. Key legal aspects that determine food fraud 8
2.4. Legal interventions and new technologies
to reduce food fraud 10
2.4.1. Legal interventions 10
2.4.2. Innovative technologies 16
3. Conclusion 21
4. Recommendations for food safety authorities 23
5. Resources 25
5.1. FAO Resources 25
5.2. Other readings 26
5.3. Bibliography 26

v
Acknowledgements
The Food and Agriculture Organization of the United Nations
(FAO) would like to express its appreciation to the many people who
contributed to this document, which is authored by Teemu Viinikainen
under the supervision of Carmen Bullon and prepared and developed
for FAO under the coordination of Masami Takeuchi. Technical and
editorial inputs provided by various FAO colleagues, including Markus
Lipp, Cornelia Boesch, Isabella Apruzzese and Sridhar Dharmapuri are
gratefully acknowledged. Technical editing was done by Kim Des Rochers.

Wagyu

vi
 1 Introduction

Food fraud occurs when customers are deceived about the quality and/
or content of the food they are purchasing, and is often motivated by
an undue advantage for those who are selling the food. A 2016 study
conducted on food fraud in Canada showed that more than
75 percent of respondents reported that they would pay an extra one
to five percent more for zero food fraud certified products; 24 percent
perceived food fraud as a high risk to their health (Statista, 2020).
Economically motivated adulteration of food and food fraud can be a
serious issue for food safety: the case of melamine in milk led to over
300 000 people becoming ill (BCC, 2010), while the toxic olive oil
syndrome resulting from aniline in olive oil led to approximately 300
deaths shortly after the onset of the disease and to a larger number
developed chronic disease (Gelpi, 2002).

Apart from the adverse public health impact, food fraud plays a major
role in negatively impacting consumers’ trust in food industries and
government agencies. Food safety professionals around the world
are dedicated to ensuring that food is safe, but blind spots in food
supply chains can provide opportunities for individuals and business to
conduct food fraud. It is extremely costly to respond to food fraud: it
is estimated that the cost of food fraud for the global food industry is
approximately EUR 30 billion every year (European Commission, 2018).

1
2
 2 Food fraud and
food safety

2.1. Background
Food fraud is commonly described as any suspected intentional action
committed when a food business operator intentionally decides to
deceive customers about the quality and/or content of the food they
are purchasing in order to gain an undue advantage, usually economic,
for themselves. While this is a common description, many others also
exist. Examples of food frauds include adding sugar to honey, selling
regular beef as Wagyu beef, or injecting shrimp with gel to make them
look larger and weigh more (see Box 1).

While these examples of food fraud mostly harm the wallet and trust of
the customer – which alone should call for government action – other
forms of food fraud can pose a direct threat to the health of customers
and consumers; such as adding melamine to infant formula (Hilts and
Pelletier, 2009), lead to powdered turmeric (American Spice Trade
Association, 2013), and dangerous chemicals to milk (The News, 2020).
Finally, the health threat can be indirect, such as when the nutritional
quality of the food is not what is promised because of lower-quality
ingredients, which robs the consumer of the health benefits for which
they paid. As such, food fraud always concerns the quality of food, and
it can be related to either the product (e.g. wood dust in coriander; see
Hindustan Times, 2019) or the process (e.g. selling non-halal products
as halal (Ahmad et al., 2018) without intentionally affecting food safety.
However, food fraud can pose a risk food safety as a secondary effect,
and it can result in the product being harmful to consumers, such as
formaldehyde in fish (Agriculture Times, 2018) and undeclared allergens
added to food products (FAO and WHO, 2017) (see Table 1).

3
 Box 1. Gel-injected shrimp

A growing problem in China

and Viet Nam is the injection
of gel into shrimp to increase
their weight and make them
look more appealing. The health
consequences of such practices
are unknown, but because the
products with which shrimp are
injected are not designed for
food use, they are likely to be
dangerous.

At the national level, widely published food fraud cases can decrease
the trust and confidence of consumers in the country’s food supply,
even in cases where such systems are safe and becoming safer (Barnett
et al., 2016). Successful food fraud can also make it more likely that
fraudsters take further risks with food, thereby placing the safety and
integrity of food supply chains in danger.

Several key challenges make detection and prevention of food fraud

difficult. First, it is not always clear what is meant by food fraud and
where the line between food fraud and marketing lies. This requires a
clear understanding, and potentially a legal definition, of food fraud
that does not slow innovation but which protects the health and trust
of customers and consumers. Second, without specialized instruments
and knowledge, it may be difficult or impossible for consumers to
detect food fraud at supermarkets or market stalls. Unless the product
poses an immediate health hazard, consumers may not necessarily
know, even after consuming the product, that they were victims of
food fraud. This means that the fight against food fraud cannot be left

4
to consumers, but instead must be taken up by governments and the
food industry. Third, food fraudsters actively avoid detection and once
one method of fraud has been discovered, they move on to a different
method, potentially avoiding detection for a long time. This third
problem is made worse by the fact that the kinds of products used to
adulterate food, such as melamine and other chemicals, are not easily
detected through regular food safety and quality tests used by food
safety authorities and law enforcement around the world. This requires
innovation both in preventing and detecting food fraud, such as the
adoption of new technologies and digital innovations on traceability.

Table 1. Types of food fraud

Potential public
health threat
Term Definition Example
that may lead to
illness or death
Adulterate A component Melamine added Fraudulent
of the finished to milk component
product is
fraudulent
Tampering and Legitimate Changed expiry Fraudulent
mislabelling products and information; packaging
packaging fraudulent information
are used in a description
fraudulent way of production
method or origin
Over-run The legitimate Under-reporting Fraudulent
product is of production product is
made in excess distributed
of production outside of
agreements regulated or
controlled supply
chain
Theft Legitimate Stolen products Fraudulent
product is stolen are mixed with product is
and passed off legitimate distributed
as legitimately products outside of
procured regulated or
controlled supply
chain

Food fraud and food safety 5

 Potential public
health threat
Term Definition Example
that may lead to
illness or death
Diversion The sale or Relief food Shortages or
distribution redirected to delays of relief
of legitimate markets where aid food to needy
products outside is not required populations
of intended
markets
Simulation Illegitimate “Knock-offs” of Fraudulent
product is popular foods not product of lesser
designed to produced with quality
look like but not same food safety
exactly copy the guarantees
legitimate product
Counterfeit All aspects of Copies of popular Fraudulent
the fraudulent foods not product
product and produced with
packaging are same food safety
fully replicated guarantees

Adapted from Spink and Moyer, 2011.

2.2. Food fraud in Asia and the Pacific

Asia and Pacfic suffer from a lack of accurate data on food fraud,
but are still considered to be at risk from this practice (Reilly, 2018).
Further, the globalization of food supply, with long, complex and
often difficult-to-trace chains, and the related lack of transparency and
traceability, creates new opportunities for food fraud, and potential
safety and health threats as a result.

A brief overview of some reported food fraud cases from Asia and the
Pacific in the past three years, as found in the European Commission’s
monthly Food Fraud Summary Reports (2020),1 provides a wealth of
examples of “traditional” food fraud – those types of fraud that target
the same products and channels of commerce as has been practiced
for millennia.

1
 hese monthly reports can be found at: https://ec.europa.eu/knowledge4policy/food-fraud-quality/food-
T
fraud-summary-reports_en

6
Table 2. Overview of some reported food fraud cases
from Asia and the Pacific in the past five years

Australia Almost 20 percent of honey Bangladesh National authorities

on the Australian market is adulterated were forced to shut down a synthetic
with substances such as cane sugar fruit juice manufacturing plant
or corn syrup. The rate of adulterated for producing juices that did not
samples went up to 50 percent for contain any fruit but were instead
imports from Asia (Zhou et al., 2018). manufactured using hazardous
chemical substances (Daily Sun, 2018).

Pakistan The country is the world’s China A collaboration between Chinese

fifth largest milk producer, authorities and Italian scientists carried out DNA
commonly confiscate milk adulterated tests on 153 samples from 30 different
with urea and contaminated water brands of roasted Xue Yu (a kind of cod)
(The News, 2019; Daily Times, 2019). fillet and found that 58 percent of the
samples were substituted with other fish
species (Xiong et al., 2017).

Taiwan Province of China The chair of a food processing

company was convicted of mixing low-grade palm oil and
other cheap oils and labelling them as high-grade olive oil.
Beyond the fact that lower-quality oils were used, the blend
also contained artificial colourants that were harmful to
human health (Logan, 2016).

Source: European Commission, 2020.

Food fraud and food safety 7

New challenges with regard to addressing food fraud are related
to the fast growth of e-commerce of food in the Asia-Pacific area.
Countries such as Australia, China, Indonesia, Japan and South Korea
are experiencing a boom in e-commerce in general, and increasingly in
food e-commerce. Three of the top ten online grocery markets in the
world are in Asia, with the majority being in China followed by Japan
and South Korea (Food Industry Asia, 2018).

There are several problems associated with food e-commerce,

particularly between businesses and consumers, which make
e-commerce more vulnerable to food fraud. These result from the fact
that consumers have no face-to-face contact with the traders, no real
opportunity to inspect food items before purchase, and are (typically)
required to pay in advance of delivery. Essentially, consumers must fulfil
their contractual obligations at the beginning of the transaction, while
trusting the trader, who may be in another jurisdiction, to fulfil theirs
at the end (Hunter and Riefa, 2017). Furthermore, even legitimate food
business operators who operate online may not be able to control the
final delivery of the products (Comans, 2019), which are often posted to
the final consumer or delivered via couriers. Due to these vulnerabilities,
a recent investigation using DNA barcoding of fishery products sold
online in China found that 85 percent of the samples identified by DNA
barcoding were mislabelled (Xiong et al. 2016)

2.3. Key legal aspects that determine food fraud

The previous section showcased a variety of examples of food fraud
in Asia and the Pacific. To better identify legal interventions and
new technologies to reduce food fraud, it is important to go beyond
examples and try to better understand what food fraud is. FAO has
been active in this area, and in 2019, it convened an expert meeting
to discuss food fraud.

8
 Figure 3. Elements of food fraud

= FOOD
FRAUD

INTENTION
+ DECEPTION

+ UNDUE
ADVANTAGE

Source: FAO, 2020

From four days of discussion and debate, the expert meeting identified
three elements underlying all cases of food fraud, informed both by
international instruments2 and existing national examples:3

1) intentionality,
2) deception and the motivation of
3) undue advantage (Figure 3).

Intention separates food fraud from mistakes and errors. Deception may
be through any means, such as labels or advertisements, and at any
stage of the supply chain, to mislead a buyer, customer or consumer
as to the integrity or value of the food. Food fraud is different from
other offences because of the presence of an undue advantage,
or unfair advantage, which most often takes the form of economic
gain. Of course, if injury is caused, in particular to human health, or if
death is caused, such effect should attract a penalty that matches or
reflects the level of injury. As such, food fraud could be understood as
the intentional deception of a customer or a consumer for an undue
advantage, economic or not (FAO, 2020).

2
Such as: Codex Alimentarius Commission, Discussion Paper on Food Integrity and Food Authenticity,
CX/FICS 18/24/7, August 2018; BRC Global Standards. 2018. Global Standard Food Safety. Issue 8;
International Featured Standards. 2018. IFS Standards Product Fraud – Guidelines for Implementation;
Global Food Safety Initiative. 2018. Tackling Food Fraud Through Food Safety Management Systems.
3
 uch as: China, Draft Measure to Handle Acts of Food Safety Fraud; EU, EU Food Fraud Network
S
key operative criteria for food fraud; USA, FDA Notice on Public Meeting on Economically Motivated
Adulteration, 74 Fed. Reg. 15,497; British Standards Institution PAS 96: 2017.

Food fraud and food safety 9

What is clear from these elements, is that any act that would be
categorized as food fraud would already most likely be prohibited in
the national legal frameworks of jurisdictions in the Asia-Pacific region.
This should not lead to a sense of security, however, as the rising
number of food fraud cases in the region, and in the world in general,
suggest that a generic approach is not necessarily enough. The question
then is, what would be the legal interventions, as well as potential
technical innovations, needed to reduce food fraud?

2.4. Legal interventions and new technologies

to reduce food fraud
2.4.1. Legal interventions
Even in jurisdictions where food fraud cases are already be prohibited,
it is still valuable for governments to adopt a definition of food fraud.
A well-defined concept of food fraud may bring focus and offer more
targeted solutions to pre-existing prohibitions, as well as highlight the
seriousness of food fraud, which poses risks not only to economies but
also people’s health. Few countries have laws that define food fraud in
all jurisdictions, including those in the Asia-Pacific region.

Preventing food fraud from happening in the first place is safer

and more cost-efficient than trying to detect it after the fact. Legal
frameworks can, and often do, place the primary responsibility to
prevent fraud on food business operators, such as through traceability
requirements and requirements to adhere to good agricultural practices
and good manufacturing practices. One way to improve the private
sector’s capability to prevent food fraud is the adoption of food
fraud vulnerability assessments in both private and public regulatory
frameworks (see Box 2).

10
 Box 2. The Vulnerability Analysis and Critical Control Point
(VACCP) system

Food safety has significantly benefited from the adoption of the

Hazard Analysis and Critical Control Point (HACCP) principles.
Similar gains in the fight against food fraud could be achieved by
the adoption of the Vulnerability Analysis and Critical Control Point
(VACCP) system. Following the VACCP principles, a food business
can develop documented procedures to identify and mitigate the
risks of food fraud in their supply chains. (Reilly, 2018a)

A VACCP system would typically consist of:

• drawing up a list of all ingredients and materials used
in the manufacturing process;
• identifying potential forms of fraud they may be subject to;
• evaluating the risk of fraudulent practices;
• identifying and implementing control measures; and
• recording and reviewing findings.

Adulteration is a well-known form of food fraud, which can pose direct

health risks to consumers. Many of the examples in earlier sections
of this paper – contaminated water in milk, dangerous chemicals in
spices, formaldehyde in fish, melamine in infant powder – pose direct
risks to anyone unlucky enough to have consumed such fraudulent
products. Due to adulteration’s direct health risk, national food safety
frameworks, and occasionally their criminal laws, commonly prohibit or
criminalize this practice. One example comes from Thailand, where the
Food Act (B.E. 2522) Section 27 prohibits adulteration, substitution and
mislabelling, which includes many forms of typical food fraud (see Box 3).

Food fraud and food safety 11

 Box 3. Thailand’s Food Act Section 27

Food of the following descriptions shall be deemed adulterated:

1) F
 ood for which other substances are partly substituted, or in
which valuable substances are wholly or partly removed and
which is sold as or under the name of the genuine food.
2) S ubstances or food produced as substitutes for any food and
distributed as being genuine food.
3) Food that is mixed or prepared in any way to conceal defects or
inferior quality of the food.
4) Foods labelled in order to deceive or try to deceive purchasers
in matters of quality, quantity, usefulness or special nature or
place or country or production.
5) Food not up to the quality or standard prescribed by the
Minister of Public Health, and the quality or standard of that
food deviates from the upper or lower specified limit by
more than thirty percent, or its deviation may be harmful
to the consumer.

One way to provide an objective background against which cases of

suspected food fraud can be measured, is to adopt food standards for
specific products and commodities. To ensure that these standards
reflect international best practices, the use of standards adopted by
the Codex Alimentarius Commission is highly recommended.4 As an
example, if a seller was offering a product labelled “edible sago flour”
in a jurisdiction that has a food standard for it that is compliant with the
Codex Alimentarius Regional Standard for Edible Sago Flour (Asia) CXS
301R-2011, and the offered product did not comply with such standards,
the second element – deception – would be easy to prove.

4
These standards are available online at: http://www.fao.org/fao-who-codexalimentarius/codex-texts/list-
standards/

12
Particularly when combined with food standards, food labelling rules
can be effective in preventing food fraud. Simply put, if the information
required and provided for a food item is true, lawful and clear, there is
no room for food fraud. As with food standards, matching a country’s
labelling requirements with those proposed by the Codex Alimentarius
Commission would ensure the use of international best practices. For
example, in Japan, the Food Labelling Act (Act no. 70 of 2013) creates
standards for food labelling following the fundamental principles of
securing the safety and opportunity of consumers to make autonomous
and rational choices. In South Korea, the Food Sanitation Act (Article
13) creates a prohibition against false and unrealistic labelling and
advertisement of food items, as well as the use of labels or
advertisements that are likely to deceive or mislead consumers.

Outside the scope of food safety legislation, consumer protection

legislation can also offer protection against food fraud. These types
of legislation protect consumers’ right to not be harmed by unsafe
and hazardous goods and services, and to be informed about issues
such as quality, quantity and price and to seek redress against fraud
(Vapnek and Melvin, 2005). India’s Consumer Protection Act of 1986
contains provisions for the protection of consumers against unfair
trade practices, defined as: “trade practices, which, for the purpose
of promoting the sale use or supply of any goods [including food] or
for the provision of any service, adopts any unfair method or unfair or
deceptive practice”.

Examples given in the same article include falsely stating that goods are
of a particular standard, quality, quantity, grade, composition, style or
model; or making false or misleading statements concerning the need
for, or the usefulness of, any goods or services.

Finally, food e-commerce should be subject to the same requirements

as traditional retail market requirements, and could benefit from
specific legal interventions. More careful attention may need to be
paid to aspects such as record-keeping and transparency, traceability
of food, and controls and import formalities. A difficult topic in food
e-commerce is the question of liability of different stakeholders for
cases of food fraud. While the primary responsibility for food fraud is
with the food business operators who committed the act, regulators
may need to decide on the limits of liability for the providers of online

Food fraud and food safety 13

platforms where these foods are traded (see Box 4). Other possible
issues can arise, such as when food offered for sale online is produced
following the food safety standards of the producing country, which
may differ from those of the importing country (see Box 5).

Box 4. Liability in food e-commerce in China

Internet platforms in China are both regulators and regulated

under China’s Food Safety Law. They are obligated to register the
legal names of food retailers admitted to their platform, define
their food safety management responsibilities, and verify that
those who are required to obtain permits have their permits. If
the platform becomes aware of food safety violations, which
could include food fraud, the platform must stop the trader from
continuing irregular activities and report them to the local food
and drug authority. For serious offences, the provider must stop
providing the internet platform services. Failing to comply with
these obligations can lead to fines or closure of operations for the
e-commerce platform.

14
Any of these legal interventions are unlikely to succeed without
efficient control and enforcement. Governments need to be able to
detect the occurrence of food fraud, including through import controls
at their borders. This requires creating a legal basis to control and
inspect food products at various stages of the food chain. Beyond a
legal basis, government officials undertaking food inspections must
have the technical capacity to physically detect when a product is
fraudulent. For this exercise, the technological innovations of the next
section can help.

Box 5. Professional counterfeit hunters

In the early stages of cross-border food e-commerce in China,

a unique mode of private enforcement emerged in the form of
professional counterfeit hunters – groups of private professionals
aiming to intentionally purchase substandard goods to seek
punitive compensations under China’s consumer protection and
food safety laws. These counterfeit hunters intentionally purchase
food items in cross-border e-commerce that they suspect to be
in violation of Chinese food and safety standards. They then file
lawsuits against the online food business operators and platform
service providers, claiming that it is a fraudulent practice for them
to sell those foods. If hunters are successful in the courts (i.e. the
food item did not follow the Chinese standards, whether or not it
followed the domestic standards of the country-of-origin), they
would be rewarded compensations of ten times the value of the
food purchased. (Pinghui, Xiao, pers. comm., 2019; Global Times, 2018).

Food fraud and food safety 15

2.4.2. Innovative technologies
Food fraud is a continuous race between food fraudsters who devise
new ways to defraud their customers, and officials and careful buyers
who try to catch them. Fraudsters hold an unfortunate edge in this race,
as they are free to innovate any possible ways to increase their profit,
with no concern for the well-being of consumers. To deal with this, legal
interventions alone are not enough, and innovative technologies can go
a long way to breach the gap.

Traditionally, access to laboratories has been a requirement to detect

whether some food products have been adulterated and are fraudulent.
This is costly both monetarily and time wise. The recent development
of portable testing devices, through funding from both the private
sector and governments, may reduce both costs. Thanks to recent
developments in miniaturisation technologies, AI-driven machine
learning and general increases in computing power, it is now possible to
build portable devices utilizing infrared, ultraviolet and visible light, or
Surface Enhanced Raman Spectroscopy sensors. Use of such relatively
cheap portable devices would move testing from the laboratory
to the field and enable risk-based sampling. Using a variety of
detection technologies, with different sensory capabilities in changing
combinations, would make food fraudsters’ jobs of finding weaknesses
in any individual method more challenging (Popping, 2019).

The real functionality of the portable devices would be dependent

on the reference database against which they would reference the
results from analysing the samples. To be as effective as possible, and
accessible to officials and private parties alike, such reference databases
could be centrally held by an independent institution or organization.
This naturally carries rather significant costs. Secondly, the quality of
the data, both from authentic products and from adulterated ones, fed
into such reference databases, may be the reason for the database’s
failure or success. With good data, these databases and devices can
create accurate profiles of authentic products, against which samples
can be compared (Popping, 2019). Conversely, low-quality data results
in overall inefficiency of the database.

16
DNA barcoding, which has seen success when used to identify fish
(see Box 6), is a promising and potentially very accurate method
of identifying the species and detecting cases of food fraud by
substitution. For fish identification, DNA barcoding works by using a
short genetic sequence of mitochondrial DNA to identify the fish as
belonging to a particular species. This very useful method can be used
on both raw and cooked products (Reilly, 2018b).

Box 6. DNA barcoding to detect fish fraud in Asia (Reilly, 2018b)

Investigations in Asia using DNA barcoding have reported cases of

mislabeling of fish. In a forensic fish survey conducted in Malaysia in
2016, 16 percent of raw, frozen or commercially processed fish were
found to be mislabeled (Chin Chin et al., 2016). Studies in China
using DNA barcoding have also revealed widespread mislabeling
of fish on the national market (Xiong et al., 2016a, b). A study on
the authenticity of fish maws (dried, salted swim bladders) on
the Chinese market found that 53.2 percent were mislabeled, and
commercial species substituted with low-value species (Wen
et al., 2015). Similarly, an investigation into the authenticity of fish
imported into Taiwan Province of China showed that 70 percent
of samples were mislabeled (Chang et al., 2016).

An Indian survey of the authenticity of fresh and processed fish

from the domestic market also used DNA barcoding (Nagalakshmi
et al., 2016). Its results showed that 22 percent of samples were
mislabeled. Another study used DNA barcoding to identify shark
species from dried fins, confiscated from a vessel fishing illegally
in Australian waters (Holmes, Steinke and Ward, 2009). It found
that the fins were from 27 different shark and ray species, some
belonging to endangered species. A DNA analysis of fish in retail
markets and fish ports in Indonesia utilizing both the CO1 and the
nuclear rhodopsin gene fragment revealed mislabeling of some
species and substitution with endangered species (Abdullah and
Rehbein, 2017).

Food fraud and food safety 17

Figure 4. Simplified steps for DNA barcoding

?
Unknown DNA- Barcode
organism extraction fragment

DNA barcode
C T A A T C

DNA-sequencing

JD

100%

Barcode Identification
database Match species name

18
Another technically advanced method for establishing food authenticity
is the variety of techniques under the umbrella of nuclear techniques,
including the analysis of stable isotopes and trace elements, and
profiling volatile organic compounds. Stable isotope analysis combined
with trace element analysis can be a very accurate way to link a food
product to the environment or location where it was produced and the
agricultural methods that were used during its production.

While this method can be very accurate, it is both costly and requires
a high level of expertise to undertake. As with the simpler portable
devices, the results are only as good as the comparison data available
in reference databases (Kelly et al., 2019). Another robust method that
provides ideal application to detect food frauds is Nuclear Magnetic
Resonance spectroscopy, which can rapidly analyse mixtures at the
molecular level without requiring separation and or purification steps
(Hatzakis, 2018). The fact that a broad spectrum of ingredients can
be tested at once allows for both on-targeted detection and for
quantification of dozens of substances in a few minutes. The result of
the test is a pattern of substances that can be easily compared to other
reference spectrums of authentic foods through automatic methods.
The success of the application of this techniques largely relies on the
availability of sufficiently populated databases (Sobolev, 2019).

Blockchain technology shows early promise in improving traceability

and transparency of food supply chains (see Box 7). Blockchains can
assist in providing an unchangeable record from the creation to the
retail store of a product (FAO and ITU, 2019). As such it could be
efficient in preventing operators in the middle of the supply chain from
changing the description of a food product, such as mislabelling horse
meat as beef, but it would not prevent the first person inputting the
original data into the blockchain from fraudulently defining the product
at the start. Blockchains can also be expensive to operate, and for full
traceability, require the different blockchains of different companies to
work together (Kim and Laskowski, 2017). As such, blockchains do not
offer a silver bullet to combat food fraud and more general issues of
traceability, but when applied carefully and combined with inspections
to verify the quality of original information, can increase
the transparency of supply chains and consumer trust.

Food fraud and food safety 19

 Box 7. What is blockchain?

Distributed ledged technology (DLT) is a decentralized system for

recording transactions with mechanisms for processing, validating
and authorizing transactions that are then recorded
on an unchangeable ledger.
Blockchain is an implementation of DLT. In the simplest terms,
a blockchain consists of a linked chain that stores auditable and
unchangeable data in units called blocks.

20
 3 Conclusions

Food fraud is an age-old problem that has gained more recognition

in the policy agendas in the Asia and Pacific region in recent years
because of highly publicized cases of very serious health repercussions.
Because of rapidly rising living standards, and the related demand
for premium quality food, as well as the explosive growth of food
e-commerce, the region is considered to be at particular risk for food
fraud. This fact requires action from governments to ensure consumers’
trust in the safety and function of their food supply chains.

Two connected avenues for preventing and controlling food fraud

were considered in this paper: legal interventions and technological
innovations. Legal interventions, which should closely match the
individual country context, could benefit from a definition of food fraud
in a statutory instrument. Such a definition could bring clarity and focus
on the fight against food fraud. Other key interventions could include
the use of VACCP principles, creating and updating food standards
and labelling rules compliant with the Codex Alimentarius standards,
and the application of consumer protection legislation to cases of food
fraud, when food safety systems are not more suitable. Importantly,
the rapidly expanding food e-commerce sector requires specific legal
interventions to make it safer, more transparent and reliable, such as
by clearly designating the roles and liabilities of the different operators,
including internet service providers, in the field of online food trade.
These interventions must be accompanied by effective control and
monitoring mechanisms.

21
To assist in catching technologically advanced food fraudsters, this
paper showcased some recent technological innovations. Handheld
portable devices can take testing from the laboratory to the field.
Nuclear techniques, such as stable isotope analysis, while difficult in
terms of cost and high-levels of expertise required, can be very accurate
in detecting various kinds of fraud, including mislabelling of origin and
production process. Both of these require comprehensive reference
databases in order to fully function. DNA barcoding can be very
effective in identifying species substitution, and has seen great success
when used on difficult-to-identify fishes. Finally, blockchain
and other digital traceability solutions, when appropriately applied,
can increase the transparency of food supply chains, thus making
fraud more difficult and increasing consumer trust.

22
 4 Recommendations for
food safety authorities

Below is a set of practical recommendations that national food safety

competent authorities might like to consider:

1 Include the topic of food fraud when discussing emerging

issues regarding food safety. In order to preserve
consumers’ trust and the safety of food supply chains,
governments need to manage food fraud, especially when
it jeopardizes the safety of food.

2 Adopt a definition 3 Review national food

of food fraud at the safety and quality
national level. legislation so that they
are aligned with Codex
Alimentarius, which
provides a solid basis
to counter food fraud.

4 Develop a 5 Keep up to date with

framework to and invest in new
respond to technologies to counter
challenges related food fraudsters.
to food fraud in
e-commerce.

23
24
 5 Resources

5.1. FAO Resources

FAO. 2020. Food for thought on food fraud. Development Law - Issue #1
of 2020. http://www.fao.org/legal/development-law/magazine-1-2020/en/

FAO. 2016. Handbook on food labelling to protect consumers [online].

FAO. Rome. [Cited 7 July 2020]. http://www.fao.org/3/a-i6575e.pdf

FAO & ITU. 2019. E-agriculture in action: Blockchain for agriculture.

Opportunities and challenges. Bangkok. 72 pp.
http://www.fao.org/3/CA2906EN/ca2906en.pdf

FAO & WHO. 2020. Codex Alimentarius standards and related texts – In:
Codex Alimentarius International food standards [online]. [Cited 7 July
2020]. http://www.fao.org/fao-who-codexalimentarius/codex-texts/en/

FAO & WHO. 2018. Committee on Food Import and Export

Inspection and Certification Systems. Twenty-Fourth Session.
Discussion Paper on “Food Integrity and Food Authenticity”, CX/FICS
18/24/7. http://www.fao.org/fao-who-codexalimentarius/sh-proxy/
en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%25
2Fcodex%252FMeetings%252FCX-733-24%252FWorking%2BDocuments
%252Ffc24_07e.pdf

25
FAO & WHO. 2017. Codex Committee on Food Import and Export
Inspection and Certification Systems. Twenty-third Session. Discussion
Paper on “Food Integrity and Food Authenticity”, Prepared by
Iran with assistance from Canada and the Netherlands. CX/FICS
17/23/5. http://www.fao.org/fao-who-codexalimentarius/sh-proxy/
en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%25
2Fcodex%252FMeetings%252FCX-733-23%252FWD%252Ffc23_05e.pdf

5.2. Other readings

China: Draft Measure to Handle Acts of Food Safety Fraud.
Available at: https://members.wto.org/crnattachments/2017/TBT/
CHN/17_1809_00_x.pdf

India: Consumer Protection Act, 1986 (No. 68 of 1986).

Japan: Food Labeling Act No. 70 of June 28, 2013

Korea: Food Sanitation Act (Consolidated version of Act No. 9432

of 2009 as amended last by Act No. 15277 of 19 December 2017)
Thailand: Food Act (B.E. 2522)

5.3. Bibliography
Abdullah, A. & Rehbein, H. 2017. DNA barcoding for the species
identification of commercially important fishery products in Indonesian
markets. International Journal of Food Science and Technology,
52:266–274.

Agriculture Times. 2018. India unveils rapid detection kits for

adulterants in fresh fish. In: Agriculture News [online]. Mumbai.
[Cited on 30 January 2018]. https://agritimes.co.in/headline-details.
php?head=K65lrLIoi8quqrSM8mQsyIvKWjUoCQxoBAA=

26
American Spice Trade Association. 2013. The American Spice Trade
Association’s statement on lead in turmeric. In: American Spice Trade
Association [online]. Washington, D.C. [Cited on 28 October 2013].
https://www.astaspice.org/the-american-spice-trade-associations-
statement-on-lead-in-turmeric/

Ahmad, A.N., Abidin, U.F.U.Z., Othman, M. & Rahman, R.A. 2018.

Overview of the halal food control system in Malaysia. Food Control, 90.
(also available at: https://doi.org/10.1016/j.foodcont.2018.02.035).

Baker, N. 2016. Stomach-churning video shows tiger prawns being

injected with jelly to make them look fresh before they hit the
supermarkets. In: The Sun [online]. London. [Cited on 5 October 2013].
https://www.thesun.co.uk/news/1914483/stomach-churning-video-
shows-tiger-prawns-being-injected-with-jelly-to-make-them-look-fresh-
before-they-hit-the-supermarkets/

Barnett, J., Begen, F., Howes, S., Regan, A., McConnon, A., Marcu, A.,
Rowntree, S. & Verbeke, W. 2016. Consumers’ confidence, reflections
and response strategies following the horsemeat incident. Food Control,
59:721–730.

BCC. 2010. China dairy products found tainted with melamine.

In: BCC [online]. [Cited on 5 October 2020].
https://www.bbc.com/news/10565838#:~:text=The%20use%20of%20
melamine%20in,Minhe%20Country%2C%20in%20neighbouring%20
Qinghai.

BRC Global Standards. 2018. Global Standard Food Safety. Issue 8;

International Featured Standards. Available at: http://www.medagri.org/
docs/group/108/free_locked_BRC%20Food%20Standard%208%20
Web_English.pdf

British Standards Institution. 2017. PAS 96:2017 Guide to protecting

and defending food and drink from deliberate attack. Fourth edition.
Available at: https://www.food.gov.uk/sites/default/files/media/
document/pas962017_0.pdf

Chang, C.-H., Lin, H.-Y., Ren, Q., Lin, Y.-S. & Shao, K.-T. 2016. DNA
barcode identification of fish products in Taiwan: Government-
commissioned authentication cases. Food Control, 66:38–43. (also
available at: https://doi.org/10.1016/j.foodcont.2016.01.034).

Resources 27
Chin Chin, T., Adibah, A.B., Danial Hariz, Z.A. & Siti Azizah, M.N.
2016. Detection of mislabelled seafood products in Malaysia by
DNA barcoding: Improving transparency in food market. Food
Control, 64:247–256. (also available at: https://doi.org/10.1016/j.
foodcont.2015.11.042#).

Comans, C. 2019. eCommerce of Food – International Conference

on Trends and Official Control. Online Food Fraud. PowerPoint
presented in Berlin. Available at: https://www.bvl.bund.de/SharedDocs/
Downloads/10_Veranstaltungen/eCommerce2019/PPT/Comans_PPT.
pdf?__blob=publicationFile&v=1

Daily Sun. 2018. Food adulteration goes unchecked. In: Daily Sun
[online]. London. [Cited on 2 October 2018]. https://www.daily-sun.com/
printversion/details/340099/2018/10/02/Food-adulteration

Daily Times. 2019. PFA disposes of 40,000 litres of adulterated milk.

In: Daily Times [online] [Cited on 15 January 2018]. Lahore.
https://dailytimes.com.pk/181350/pfa-disposes-40000-litres-
adulterated-milk/

European Commission. 2020. Monthly Food Fraud Summary Reports.

In: European Commission [online]. Brussels. https://ec.europa.eu/
knowledge4policy/food-fraud-quality/food-fraud-summary-reports_en

European Commission. 2020b. Food fraud: What does it mean? In:

European Commission [online]. Brussels.
https://ec.europa.eu/food/safety/food-fraud/what-does-it-mean_en

European Commission. 2018. The EU Food Fraud Network and the

System for Administrative Assistance - Food Fraud. Annual report 2018.
[online]. [Cited 7 October 2020]. https://ec.europa.eu/food/sites/food/
files/safety/docs/ff_ffn_annual-report_2018.pdf

FDA. 2009. Economically motivated adulteration; public meeting;

request for comment. Docket No. FDA-2009-N-0166. 74 Fed. Reg.
15,497. https://www.govinfo.gov/content/pkg/FR-2009-04-06/pdf/E9-
7843.pdf

Food Industry Asia. 2018. Food e-commerce across Asia. Risks

and opportunities. https://foodindustry.asia/documentdownload.
axd?documentresourceid=30715

28
Gelpi. 2002. The Spanish toxic oil syndrome 20 years after its onset:
a multidisciplinary review of scientific knowledge. Environ Health
Perspect. 110(5): 457–464. https://doi:10.1289/ehp.110-1240833

Global Food Safety Initiative. 2018. Tackling food fraud through

food safety management systems. https://mygfsi.com/wp-content/
uploads/2019/09/Food-Fraud-GFSI-Technical-Document.pdf

Global Times. 2018. Government attitude toward businesses that make

living suing counterfeiters change. In: Global Times [online]. [Cited on
22 November 2018]. http://www.globaltimes.cn/content/1128554.shtml

Hilts, C. & Pelletier, L. 2009. Background paper on occurrence of

melamine in foods and feed. Prepared for the WHO Expert Meeting
on Toxicological and Health Aspects of Melamine and Cyanuric Acid.
WHO. Geneva. https://www.who.int/foodsafety/fs_management/
melamine_3.pdf

Hindustan Times. 2019. After synthetic milk, Madhya Pradesh busts

adulterated spice racket. In: Hindustan Times [online]. https://www.
hindustantimes.com/india-news/after-synthetic-milk-madhya-pradesh-
busts-adulterated-spice-racket/story-eS6g8QF3mokDN3VbNF241O.html

Holmes, B.H., Steinke, D. & Ward, R.D. 2009. Identification of shark and
ray fins using DNA barcoding. Fisheries Research, 95(2):280–288.
(also available at: https://doi.org/10.1016/j.fishres.2008.09.036).

Hunter, J. & Riefa, C. 2017. The challenge of protecting EU consumers

in global online markets. In: The European Consumer Organisation and
the Federation of German Consumer Organisations.
https://www.vzbv.de/sites/default/files/downloads/2017/11/08/17-11-08_
brochure-vzbv-beuc-lr3.pdf

IFS. 2018. IFS standards product fraud – Guidelines for implementation.

Berlin. https://www.kin.de/wp-content/uploads/2018/05/FoodFraud-
Guide_1805.pdf

Kelly, S., Abrahim, A., Islam, M., Maestroni, B., Mihailova, A. &
Cannavan, A. 2019. Presentation on “The activities of the FAO/IAEA
Joint Division’s (AGE/NAFA) Food and Environmental Protection
Laboratory (FEPL)”. FAO Food Fraud Workshop, November 2019.

Resources 29
Kim, H.M., Laskowski, M. 2017. A Perspective on Blockchain Smart
Contracts: Reducing Uncertainty and Complexity in Value Exchange.
26th International Conference on Computer Communication and
Networks (ICCCN), Vancouver, BC, 2017, pp. 1–6,
https://doi:10.1109/ICCCN.2017.8038512

Logan, W. 2016. Taiwanese businessman sentenced to four years in

prison for olive oil fraud. In: Olive Oil Times [online]. Rhode Island, USA.
[Cited on 30 March 2016]. https://www.oliveoiltimes.com/business/asia/
taiwanese-businessman-sentenced-to-four-years-in-prison-for-olive-oil-
fraud/51023

Nagalakshmi, K., Annam, P.-K., Venkateshwarlu, G., Pathakota, G.-B. &

Lakra, W.S. 2016. Mislabeling in Indian seafood: An investigation using
DNA barcoding. Food Control, 59:196–200. (also available at:
https://doi.org/10.1016/j.foodcont.2015.05.018).

Pavlovic, A. 2019. The 5 biggest food frauds ever pulled off. In: Qualsys
[online]. [Cited 17 September 2020]. https://quality.eqms.co.uk/blog/
the-5-biggest-food-frauds-ever-pulled-off

Popping, Bert. 2019. Necessary technical and infrastructure capacities.

Detection methods for adulterants – developments, challenges and
needs. Paper presented at the FAO Expert Workshop on Food Fraud,
November 2019.

Reilly, Alan. 2018a. Food fraud – understanding the impact of food

fraud in Asia. In: Food Industry Asia [online]. https://foodindustry.asia/
documentdownload.axd?documentresourceid=30310

Reilly, Alan. 2018b. Overview of food fraud in the fisheries sector. FAO
Fisheries and Aquaculture Circular No. 1165. FAIM/C1165 (En). Rome, FAO.
21 pp. (also available at: http://www.fao.org/3/i8791en/I8791EN.pdf).

Spink, J. & Moyer, D. 2011. Defining the public health threat of food fraud.
R. Concise Reviews in Food Science, 76(9):157–163. (also available at:
https://onlinelibrary.wiley.com/doi/pdf/10.1111/j.1750-3841.2011.02417.x).

30
Statista. 2020a. Amount consumers are willing to pay extra
for zero food fraud certified products in Canada as of October 2016.
In: Statista [online]. [Cited 17 September 2020].
https://www.statista.com/statistics/713665/consumer-willing-to-pay-for-
zero-food-fraud-certification-label-canada/

Statista. 2020b. Level of risk regarding food fraud perceived by

consumers in Canada as of October 2016. In: Statista [online].
[Cited 17 September 2020]. https://www.statista.com/statistics/713717/
consumer-risk-perception-regarding-food-fraud-canada/

The News. 2019. 4,915 litre tainted milk disposed of. In: The News
[online]. [Cited 14 January 2019]. https://www.thenews.com.pk/
print/418656-4-915-litre-tainted-milk-disposed-of

The News. 2020. 22 food points sealed, 15,500 litre milk discarded. In:
The News [online]. [Cited 4 March 2020]. https://www.thenews.com.pk/
print/623579-22-food-points-sealed-14-500-litre-milk-discarded

Vapnek, J. & Sprei, M. 2005. Perspective and guidelines on food

legislation, with a new model food law. FAO Legislative Study 87.
268 pp. FAO. Rome.

Wen, J., Zeng, L., Sun, Y., Chen, D., Xu, Y., Luo, P., Zhao, Z., Yu, Z. & Fan, S.
2015. Authentication and traceability of fish maw products from the
market using DNA sequencing. Food Control, 55: 185–189.
(also available at: https://doi.org/10.1016/j.foodcont.2015.02.033).

Xiong, X., Guardone, L., Cornax, M.J., Tinacci, L., Guidi, A., Gianfaldoni,
D. & Armani, A. 2016a. DNA barcoding reveals substitution of
sablefish (Anoplopoma fimbria) with Patagonian and Antarctic
toothfish (Dissostichus eleginoides and Dissostichus mawsoni) in
online market in China: How mislabeling opens door to IUU fishing.
Food Control, 70:380–391. (also available at: https://doi.org/10.1016/j.
foodcont.2016.06.010).

Resources 31
Xiong, X., Guardone, L., Giusti, A., Castigliego, L., Gianfaldoni, D., Guidi,
A. & Andrea, A. 2016b. DNA barcoding reveals chaotic labeling and
misrepresentation of cod (Xue) products sold on the Chinese market.
Food Control, 60:519–532. (also available at: https://doi.org/10.1016/j.
foodcont.2015.08.028).

Xiong, X., Yao, L., Ying, X., Lu, X., Guardone, L., Armani, A., Guidi, A. &
Xiong, X. 2017. Multiple fish species identified from China's roasted Xue
Yu fillet products using DNA and mini-DNA barcoding: Implications on
human health and marine sustainability. Science Direct Volume 88:123–
130. (also available at: https://www.sciencedirect.com/science/article/
abs/pii/S095671351730614X).

Zhou, X., Taylor, M.P., Salouros, H. & Prasad, S. 2018. Authenticity and
geographic origin of global honeys determined using carbon isotope
ratios and trace elements. Scientific Report, 8, 14639. (also available at:
https://doi.org/10.1038/s41598-018-32764-w).

32
Food fraud
Intention, detection and
management
5

CB2863EN/1/03.21

FAO Regional Office for Asia and the Pacific

[email protected]
fao.org/asiapacific

Food and Agriculture Organization of the United Nations

Bangkok, Thailand

36 Food fraud Intention, detection and management