Future Threats on Food Fraud:

Early Detection and Mitigation Efforts

ROY SPARRINGA
Disampaikan pada Forum Komunikasi Pencegahan Kejahatan Obat dan Makanan.
“Sinergisitas Holistik Multiperspektif dalam Upaya Cegah Tangkal Kejahatan Obat dan Makanan”.
Badan Pengawas Obat dan Makanan. Surabaya, 24-25 Juli 2024

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Future Threats on Food Fraud:
Early Detection and Mitigation Efforts

1 Food safety system changes

2 Intentional actions
3 Food fraud
4 Detection and mitigation
5 Closing remarks

AGENDA

2
 Current position and activity Roy Sparringa
• Chair of the Indonesia Food Safety Professionals Association (APKEPI).
• Chair of Governing Board of Food Safety and Quality Assurance - Professional Certification
• Member of the Indonesian Codex National Committee.
• Member of the Environmental Health Expert Committee, Ministry of Health, Indonesia
• Member of National Biosafety Commission for Genetically Modified Products, Indonesia
• Member of the Advisory Board of the Association of Indonesian Food Technology Experts
(PATPI), and the Association of Indonesian Pharmaceutical Companies (GPFI).
• Guest Lecturer at several universities.
• Food safety consultant (WHO, FAO & UNIDO, 2006-2017) and WHO temporary adviser on
Traditional Food Markets in the Asia Pacific Region (2021, 2022, 2023).
• Scientific Panel Member, International Life Sciences Institute (ILSI) – SEA.
Past career • Research and scholarship reviewer in several ministries/institutions.
• Chairman of Indonesia Food and Drug Authority / BPOM
(2013 – 2016). Education
ROY SPARRINGA
• Deputy Chairman for Food Safety and Hazardous • Ph.D. in Food Microbiology, Department of
Substance Control, BPOM (2010-2013) Food Science & Technology, University of
• Assistant to Deputy Minister for Medical and Health Reading, UK (1999)
Sciences, Ministry of Research and Technology (2007-2010) • M.App.Sc in Food Microbiology, University of
• Deputy Director of Food Safety Surveillance and Extension, New South Wales, Sydney, Australia (1994)
BPOM (2001-2007) • BS / Ir Food Science & Technology, Brawijaya
• Researcher / engineer - BPPT (1986-2017) University (1985).
• Principal Engineer - BPPT (2017)
©RoySparringa 3
 Future Threats on Food Frauds:
Early Detection and Mitigation Efforts

Food safety system changes

• The drivers of the food safety system changes
• Milestones of HACCP and Food Safety Management System
• The direction of food control policy?
4
 EU Food Safety System
DRIVERS First harmonization program (1968-1969)
RASFF (1979)
• Single market Food safety reformed in EU and in most
EU member states
• Food crises in 1980s-1990s Consumer protection
- Madcow (BSE)
- Dioxin Integrated approach to food safety from farm
to table (White Paper on Food Safety; 2000)
Food crises created a window of opportunity
for the development of a more internally
• Risk regulations
integrated food safety policy
• Self-regulation by the industry
• Integrated food safety system

EFSA (2002)
RASFF strengthened General European Food Law (2002)

Stronger food safety system in EU 5

 China Food Safety System

• Food Scandals: e.g. melamine and watermelons

RIV ERS
D • Lost confidence in the domestic supply chains
affecting the global supply
• Global trade

• China’s Food Safety Law (2005) gave stronger roles of CFDA (China Food and Drug Administration
and ACSIQ (General Administration of Quality Supervision, Inspection and Quarantine).
• Centralized regulation by the CFDA of the entire food supply chain.
• Stricter regulation of key food industry sectors, such as infant formula and other dairy, health
foods, foods for special medical purposes [FSMP].
• A self-regulating industry and increased post-market supervision by authorities.
• Refinement and optimization of China’s national food safety standards.
• Improvement in the quality and safety of edible agricultural products circulating in the food
supply.
• Establishment of China National Center for Food Safety Risk Assessment (CFSA) in 2011.
6
 US Food Safety System
ERS
DRIV • Public health concerns: Foodborne illness (48 million / 1 in 6
Americans get sick each year), immune-compromised individuals
more susceptible, life-long chronic diseases.
• Globalization (15% of US food supply is imported)
• Food supply more high-technology and complex
• Shifting demographics
• Vulnerability of the food system

Food Safety Modernization Act (FSMA) 2011

7 Major FSMA Rules: Preventive controls for human food, produce safety
standards, foreign supplier verification program, preventive control (animal food),
third party accreditation, sanitary transport, and intentional adulteration.
7
Milestones of HACCP from the introduction to development of HACCP and
HACCP based food safety management system (Adapted from Margaret et al 2018)

2020 2024

Food Safety
Culture

Food Defense
(Food fraud &
bioterrorism)
FSSC 22000
(2009) HARPC provisions of the
FDA FSMA (2015) 8
UNINTENTIONAL INTENTIONAL

The food safety management system includes prevention of hazards, threats and
vulnerabilities (FSSC 22000 Version 5) 9
The COVID-19
pandemic in
accelerating the
digitalization in
several food-
related areas

Food Fraud?

Hasson et al. (2023)

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 Global changes in food safety system
DRIVERS CHANGES TRENDS OUTCOMES
• Food scandal and food • Food regulatory system • Consumption changes • Food safety and
fraud • Regional and global • Integrated food safety system quality
• Public health protection agreement nationally and regionally • Public health
• Harmonization of food safety • Free trade
• Market integration • Equivalence and mutual
and quality standard • Food security
• Global trade and open recognition in trade • Implementation of SPS and TBT
agreement • Diverse and
market • Cost effectiveness for food pleasurable foods
• Global environmental • Food security policy quality, safety, food defense, • Safe, healthy and
changes • Innovation in pre and supervision, sanctions,
sustainable food
• Resource constraints post-harvest technology adopting operation in multiple
system
• Emerging issues • Biosecurity policy jurisdiction.
• Safe, healthy and sustainable • National / regional
• Climate changes • Food fraud and food protection
food
• Science and technology defense policy
• Traceability and control over
• Pandemics (e.g. Covid19) • Digital transformation Do we
the supply chains.
• Digitized supply chain • Global supply chain address these
• Application of Big Data and AI
• Geopolitics in food safety issues?
• National and or / regional
interests 11
Cell-Based Food?
FAO & WHO (2023)

• Due to extreme weather, geopolitical shifts, supply

chain disruptions, and resource scarcities, they affect
the availability of safe food for people (CCEXEC Sub-
committee on New Food Sources and Production
Systems, Nov-Dec 2022)
• More than 100 start-ups developing various cell-based
FAO (2024) food products including meat, fish, poultry, dairy, and
FAO (2023) eggs (FAO, 2023) 12
 Future Threats on Food Fraud:
Early Detection and Mitigation Efforts

Intentional actions
• Intentional actions?
• Introduction to Food Defense, Food Fraud and Food Crime
• Do we address the issues?
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 Food Protection Risk Matrix

MOTIVATION
Food Quality Food Fraud Gain: Economic

Food Safety Food Defense Harm: Public health,

economic or terror

Unintentional Intentional
ACTION

Robson et al. (2020)

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Differences between food fraud and food defense (Constable, 2021)

Food Fraud Food Defense

Motivated by a desire for economic Motivated by a desire to cause harm to
gain. consumers and/or food businesses
Does not always involve direct Usually involves direct adulteration of
adulteration of food. food.

Activities are intended to go Intended to be detected by victims

undetected

Affected foods sometimes (but not Affected foods always pose a direct
always) pose a direct health risk to health risk to consumers
consumers
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 Food crime can involve
Scopes of Food Integrity (Robson et al.,2020) food fraud, food
Food Integrity* defense, food quality
and food safety

*Food integrity is a concept that encompasses the disciplines of food safety & quality, food
fraud prevention and food defence (Constable, 2021) 16
Definition: “Food crime is serious fraud and related criminality within food supply chains”
(NFCU & SFCIU, 2020 in Wilkes 2021, FSA, 2024).

FOOD CRIME TECHNIQUES

• Theft: the dishonest appropriation of food, drink, or feed products from their lawful owner with
an intention to benefit economically from their subsequent use or sale
• Illegal Processing: the slaughter, preparation, or processing of products of animal origin outside
of the relevant regulatory framework.
• Waste Diversion: the unauthorised diversion of food, drink or feed intended for disposal back
into relevant supply chain.
• Adulteration: reducing the quality of a food product through the inclusion of a foreign
substance, with the intention either to make production costs lower, or apparent quality higher
• Substitution: the replacing of a food product or ingredient with another substance of a similar
but inferior kind.
• Misrepresentation: the marketing or labelling of a product so as to inaccurately portray its
quality, safety, benefit, origin, or freshness
• Document Fraud: the use of false or misappropriated documents to sell, market or otherwise
vouch for a fraudulent or substandard product.
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Bioterrorism Act and Food Safety Modernization Act
9/11 2001

Bioterrorism Act 2002

The Food and Drug Administration

Amendments Act of 2007 (FDAAA); 2009
Section 417, The reportable food
registry

FSMA 2012
Food Safety Modernization Act
Food Defense
@RAS 18
Bioterrorism Act

@RAS 19
 Bioterrorism Act

@RAS 20
Impact on the food industry
 Food Safety Modernization Act
• Enabling FDA to focus more on preventing food • Prevention controls
safety problems rather than relying primarily on for food facilities
reacting to problems. • Authority to
• Providing FDA with new enforcement authorities prevent intentional
designed to achieve higher rates of compliance contamination
with prevention and risk-based food safety
standards and to better respond to and contain
problems.
• Focus of the FSMA provides the FDA mandates
on prevention, inspection and compliance,
response, imports, and enhanced partnerships

@RAS 21
 Public health implication, consumer confidence, and tremendous economic losses

• In 1989, millions of tons of fruit from Chile became suspect when a

call was made to the U.S. Embassy in Santiago reporting that
Chilean grapes had been intentionally poisoned with cyanide.
• The FDA banned the import of Chilean fruit and warned people not
to eat grapes or Chilean fruit after investigators found traces of
cyanide in two seedless red grapes shipped from Chile to
Philadelphia.
• The incident cost Chile $300 million in lost revenue.

• Loss of consumer confidence

• Economic stress for the Chilean fresh fruit industry
• Expenses for the United States to conduct and implement
investigations, import bans, and enforcement.
FDA (2017) • Retail loss of revenue due to recalls of fruit.
@RAS 22
 Global Importance of Food Defense

SIZE AND COMPLEXITY

- More opportunities for vulnerability

INTERCONNECTEDNESS
- Consequences will spread through the system

Making the system impervious is impossible

@RAS
Food Protection and Defense Institute (2016) 23
20 Juli 2016
Indonesia should begin to control the
strategic issues of:
ü Sabotage (Food Defense)
ü Terrorist (Food Defense)
ü Economically motivated adulteration
(Food Fraud)

Sparringa (2016)

@RAS 24
Examples of food fraud in Asia Pacific (EU, 2020 in FAO, 2021)
FOOD
Australia.
Almost 20 % of honey is China
adulterated with substances such DNA tests on 153 samples from 30
as cane sugar or corn syrup. Up to different brands of roasted Xue Yu (a
50 % for imports from Asia kind of cod) fillet and found that 58
percent of the samples were
Bangladesh substituted with other fish species
National authorities were forced to
shut down a synthetic fruit juice Taiwan
manufacturing plant for producing Mixing low-grade palm oil and other cheap oils and
juices that did not contain any fruit labelling them as high-grade olive oil. Beyond the fact
and consisted of hazardous that lower-quality oils were used, the blend also
chemical substances contained artificial colourants that were harmful to
Pakistan human health (a case of a food processing company)
As the world's fifth largest milk
producer, authorities regularly
Indonesia?
confiscate milk adulterated with
urea and contaminated water 25
 The Role of Laboratories in
National Food Safety Risk Assessment

Food fraud
• Types of food fraud
• Definition of food fraud
• Cases reported and the impacts

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 Definition?
• So far no international definition relating to ‘‘food fraud”.
• Definition of food fraud varies from government perspective, academic
literature, economically motivated adulteration, food authenticity, food
integrity, and /or food crime (Robson et al, 2020).
• There is no definition of Food fraud in Indonesia. So far the Codex has not
yet established a definition of food fraud.
• Food fraud is usually described as an intentional act and is committed
when a food business person intentionally deceives customers about the
quality and/or content of food in order to gain undue advantage, usually
of an economic interest (FAO, 2021).
• Examples of food fraud:
ü adding sugar to honey,
ü selling meat regular beef as wagyu beef, or
Food fraud is the illegal ü injecting gel into shrimp to make them look bigger and heavier.
(intentional) deception for • Food fraud has emerged as a serious food safety risk as one of the biggest
economic gain using food concerns for the food industry and government regulators (Spink, 2019).
(Moyer et al. 2017). • The impact of food fraud robs consumers' wallets, damages public trust /
confidence, and threatens the public health. The government should take
an action. (FAO, 2021). 27
A growing problem in some countries in Asia Pacific

• Injecting shrimp with gel to

make them look larger,
weigher, and more appealing.
• Not food safety practice, use
of “un-known gel” and they
are likely to be dangerous.

FAO (2021)

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What are fraudulent
practices in Indonesia
apart from “Daging
Sapi Gelonggongan?”

https://www.detik.com/jatim/berita/
d-6898159/rph-surabaya-temukan-
500-kg-daging-sapi-diduga-
gelonggongan Accessed 4 July 2024
29
 Type Definition Examples General Type

Type,
Definition,
and Examples
(FSSC 22000, 2019)

30
 Type Definition Examples General Type
Type,
Definition,
and Examples
(FSSC 22000, 2019)

31
Hierarchy of terms and definitions (CEN, 2019 in Robson et al. 2020)

The European Committee for Standardization (CEN) 32

Deliberate act types leading to food misrepresentation

Poping et al. 2022

33
Fraud report frequency by supply chain node and fraud type observed at each node (Lawrence et al. 2022) 34
 Top 20 species of seafood as fraud cases based on
reporting frequency
(01 January 2010 – 31 December 2020)

Lawrence et al. 2022) 35

The economic
impact of
food fraud
risks
Butler et al. (2021)

Freepik
36
 Challenges in E-Commerce Food Fraud
§ Not knowing exactly where the product is coming from

§ Not knowing how the product was handled or mishandled, such as a

continuous cold chain or other contaminants.

§ Not being able to sample or assess products before purchase.

§ Lack of clarity on when the product—and legal responsibility—transfer to the

end user, whether the courier in contract with the end user or the seller?

§ Lack of supply chain and handling transparency across the different delivery
options. It may order from one e-retailer, and the delivery may be conducted
by multiple companies.

Spink (2019)
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Range of possible food inauthenticity events: The likelihood and impact

Popping et al. (2022)

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 Future Threats on Food Fraud:
Early Detection and Mitigation Efforts

Detection and mitigation

• Vulnerability assessment and fraud mitigation in Food Industry
• Authoritative activities countering food fraud
• Early detection and mitigation in Indonesia?
39
One of the ways to combat food
fraud is by Food Authentication

This review article discusses

about food inauthenticity
including:

• Authority activities
• Guidance for food operators
• Mitigation tools

Popping et al (2022)
40
 Global Activities for Food Fraud Detection, Prevention and Mitigation
European Commission
North America
• DG SANTE • USA (FDA, FSIS, TTB, USDA, NIST SRM)
• The European Anti-Fraud Office (OLAF) • Canada (CFIA)
• Food Fraud Network
• Europol (through Opson Initiatives)
Africa
• EC science agency Joint Research Center (JRC).
• The Rapid Alerts for Safety of Food and Feed (RASFF)
• Uganda
Mitigation
• The Administrative Assistance and Cooperation System for
Food Fraud (AAC-FF) Latin America Prevention
• DG Joint Research Centre established the Knowledge Centre • Argentina
for Food Fraud and Quality (KC-Food) • Chile Detection
• DG AGRI and DG MARE
Asia
• FAIM project (Research on food authenticity issues and
• China
methodologies)
• India (FSSAI)
European Member States and the United Kingdom • Malaysia (JAKIM)
• Germany • France • Japan (Consumer Agency Affairs, MAFF?)
• The Netherlands • Italy
• Denmark • The United Kingdom Indonesia:
• ILSI: Food BPOM, MoA,
Food Standards Agency (FSA), DEFRA,
Authenticity Task MoMF, NFA?
Force Food Authenticity Network (FAN). Popping et al (2022) 41
 January 2024

The ACN composing

RASFF, AAC and FFN)
established Mar 2021
• RASFF - food/feed
safety-related
notifications.
• AAC - non compliance
notifications without
public health risk
involved.
• Agri-FF - non compliance
notifications with
suspicion of fraud.
https://food.ec.europa.eu/document/download/c235fad7-df80-4b80-9989-
dfda920d0463_en?filename=acn_report_2023_overview.pdf Accessed 14 July 2024
 Record tampering: 34
May 2024
Product tampering: 37
Other non-compliance (implicit claim violations): 210

Source of detection:
ü Border control: 125
ü Market control: 101
ü Consumer complaint: 24
ü Company’s own check: 15
ü Whistleblower info: 9
ü Media monitoring: 5
ü Food poisoning: 2

https://food.ec.europa.eu/document/download/1e5bac5c-e9d1-438a-9e85-
35ad711d0164_en?filename=ff_ffn_monthly-report_202405.pdf Accessed 16 July 2024 43
https://www.foodauthenticity.global/tools-guides-reports Accessed 14 July 2024
44
 Guidance on Food Fraud in Food Industry
Ingredient authenticity Control
1. Establishing the required specification of the ingredient within the commercial relationship with the
supplier, including defining an appropriate source.
2. Managing an authenticity process to ensure that required specification is met an on going basis
3. Generating information to facilitate the authenticity by analytical data and audit information

45
General process for managing authenticity Popping et al (2022)
 USP (2016)
Picture: ScienceSoft

Contributing factors for vulnerability assessment

ü Supply chain
ü Audit strategy
ü Supplier relationship
ü History of supplier regulatory, quality or safety issues
ü Susceptibility of QA methods and specs
ü Testing frequency
ü Geopolitical considerations
ü Fraud history
ü Economic anomalies
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Food Fraud Mitigation Guidance Framework for Industry
• Economic vulnerability (how economically • Relationship with supplier (e.g. long relationship or spot-
attractive is fraud) buying)
• Detectability (e.g. how easy to detect, routine • Certification through an independent sector specific
screening present) control system for fraud and authenticity
• Access to raw materials, packaging materials and • Complexity of the supply chain (e.g. length, origins and
finished products in the supply chain where the product is substantially changed /processed)

Mitigation depending on potential ü Information and data

fraud types such as known fraud, management
fraud vulnerabilities identified or
unknown / unexpected
ü Analytical testing
ü Risk management
activities

MITIGATION
Source: USP (2016), FSSC 22000 (2019) 47
Priority food fraud management framework

Popping et al (2022) 48
Global media as an early warning tool for food fraud; an assessment of MedISys-FF

• The system has collected articles

discussing potential food fraud risks due
to the COVID-19 crisis.
• The MedISys-FF tool utilizes a list of 531
food fraud related keywords carefully
selected based on the existing scientific
literature and other previously available
food fraud databases (e.g. RASFF, EMA),
• They were validated by experts and then
translated into 8 different languages. The
performance of these keywords in
filtering out media articles specifically
about food fraud, assessed, and iterative
improvements until a stable level of 80%
relevant articles was reached.
• The MedISys-FF is a very useful tool to
detect early trends in food fraud
(Marvin et al, 2022)
49
 CED: Common Entry Doc
HC: Health Certificate

Frequency of food fraud type being reported in the dataset (2015–2020)

50
Overview of products mentioned in food fraud
articles published world-wide (2015–2020).
Products reported more than 2% of 5022 products

• Meat and meat products (other than poultry): 1392 (27.7%)

• Milk and milk products: 526 (10.5%)
• Cereal and bakery products: 416 (8.3%)
• Fish and fish products: 389 (7.7%)
• Poultry meat and poultry meat products: 384 (7.6%)
• Fruits and vegetables: 293 (5.8%)
• Fats and Oils: 224 (4.5%)
• Alcohol beverages: 198 (3.9%)
• Confectionery: 198 (3.9%)
• Non alcoholic beverages :183 (3.6%)
• Honey and royal jelly: 111 (2.2%
• Herbs and spices: 99 (2%)

(Marvin et al, 2022) 51

Global frequency of food fraud in fruit and vegetable by continent 2015-2020 (Marvin et al, 2022)
52
 Early warning tools and systems for
emerging issues in food safety (FAO, 2023)
• Modern warning systems fed by numerous, real-time
and diverse data, and enhanced by advancements in
artificial intelligence (AI) and machine learning (ML)
techniques, are capable of food safety early warning
and analysis
• Promote exploration of the application of Big Data and AI
in food safety-including food fraud early warning
systems and emerging risk identification processes.
• Provide an overview of available food safety early
warning tools and consider prospects and innovative
solutions for addressing gaps to their implementation in
low- and middle- income countries (LMICs).

FAO. 2023. Early warning tools and systems for emerging issues in food safety
https://openknowledge.fao.org/server/api/core/bitstreams/ced6b5e9-3ccd-
4591-84a6-09f1c12ba429/content. Accessed 18 July 2024
53
 Different time horizons for retrospective,
early warning and horizon-scanning/
foresight systems, and input into the risk
analysis process

FAO (2023) 54
 Future Threats on Food Fraud:
Early Detection and Mitigation Efforts

Closing remarks
Conclusion and Recommendation

55
 Closing Remarks
• Food frauds have been widely reported and may have negative implications for
food safety, public trust and be economically detrimental to consumers. However,
food authorities' responses still vary in addressing these important issues.
• There is no international agreement on defining food fraud. However, there are
many definitions of food fraud from government perspective, academic literature,
economically motivated adulteration, food authenticity, food integrity, and/or food
crime. However, in principle, food fraud is illegal and intentional deception of food
for economic gain.
• Encourage business operators to self detect, prevent and mitigate food fraud, and
the government to facilitate it, especially to the SMEs.
ü Business practices by increasing transparency
ü Conduct vulnerability assessment and fraud mitigation.
ü Developing supply chain procurement protocols that increase supplier
visibility
ü Increase the penalties associated with food fraud, such as supplier delisting or
potential prosecution.
ü Develop long term relationships with compliant suppliers.
ü Develop awareness training within the organization
56
 Closing Remarks
• Indonesia does not seem to have a stepwise, measurable approach to fighting food fraud:
ü Establish a definition of food fraud
ü Review existing food safety and quality legislation that provides a solid basis to counter
food fraud.
ü Develop a framework to respond the challenges of food frauds according to the food /
food ingredient priority scale that are often misrepresented, tampered, counterfeited, or
adulterated in the food supply chain, including in legal/ illegal food trade via e-commerce.
ü Use data and information from global networks in fighting food fraud, and develop
national and international network collaboration, and identify the challenges and its
contribution factors.
ü Involve business operators, academics and the communities to combat food fraud.
ü Utilize new technology to counter food fraudsters in detection, prevention and
mitigation, and future threats.
• Let’s start with food crime! Food crime can be defined as serious fraud and related
criminality in food supply chains.
• Utilize global data to prevent and deter the imported food products, assess food fraud in
Indonesia from the global trends, develop the national early warning system by assessing
the vulnerability and the impact and its mitigation.
57
Which area of food crime will you detect, prevent and mitigate?

The area of food fraud which is in

the food crime category, an
intentional act that has a
negative impact on health (food
safety), the economy, and /or
even terrorism (food defense)
which has a large and
widespread impact

Scopes of Food Integrity (Robson et al.,2020)

58
 What are the challenges of controlling of free school meal programs?

ü Food Safety
ü Food Quality /
nutrition
ü Food Fraud
ü Food Defense
ü Food Crime

Illustration by Nur Luqman Shalahuddin

59
What are the food control challenges for VVIP?

ü Food Defense

Do we address this issue?

Freepik
60
Roy Sparringa

0817 0337 4386

[email protected] Asosiasi Profesi Keamanan PanganIndonesia

@apkepi_official www.apkepi.or.id https://jmkp.or.id

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