Uncovering Product Vulnerability

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Figure 1: The number of EMA incidents in each food product category, by location of origin of adulteration.

The food supply is becoming increasingly globalized and U.S. consumers eat imported foods or ingredients on a daily basis. More than 15 percent of the foods we eat in the U.S. are imported, with as much as 80 percent of seafood products coming from other countries. Many food ingredients, such as spices, are sourced almost exclusively from other countries. The FDA estimates that importation of regulated products next year will be triple that from 2007. Globalization of the food supply increases the length and complexity of supply chains, and arguably increases the opportunity for both foodborne illness and economically-motivated adulteration (EMA). Of the more than 450,000 food and feed facilities registered with FDA, more than 285,000 are foreign facilities. There is a large gap in inspection coverage among foreign facilities and domestic facilities. Between 2001 and 2007, only 1 percent of foreign food firms were inspected by FDA. The agency has proposed a number of programs aimed at addressing the challenges posed by imported food products and ingredients. However, there is still some debate about how to approach the problem of EMA.

Types of EMA

Various groups have defined EMA, or food fraud, including the Global Food Safety Initiative (GFSI), the U.S. Pharmacopeial Convention (USP), and the Grocery Manufacturers Association, or GMA. The bottom line is that EMA involves misrepresentation of the true nature of a food product or ingredient, with the goal of the economic gain of the seller. The National Center for Food Protection and Defense at the University of Minnesota has identified the following eight types of EMA.

Substitution involves complete replacement of a food product or ingredient with an alternate product or ingredient. Examples include fish species fraud or selling olive pomace oil as extra virgin olive oil.

Dilution involves partial replacement of a food product or ingredient with an alternate ingredient. Examples include dilution of honey with sugar syrups and the addition of horse meat to ground beef.

Transshipment or origin masking refers to misrepresentation of the geographic origin of a product to avoid import duties, regulatory oversight, or to benefit from consumer demand. Examples include routing Chinese honey shipments through Vietnam to avoid U.S. import duties and mislabeling imported shrimp as U.S. Gulf coast shrimp.

Artificial enhancement is the addition of unapproved chemical additives to enhance the perceived quality of a product. Examples include the addition of Sudan dyes to chili powder and the addition of melamine to milk.

Mislabeling refers to misrepresentation with respect to harvesting or processing information. Examples include falsification of label information for organic produce, cage-free eggs, kosher foods, halal foods, and date-markings.

Theft and resale refers to situations where a food product has been stolen and re-enters into commerce through unapproved channels. Examples include retail theft of infant formula and cargo thefts.

Counterfeit is fraudulent labeling of a product by an unauthorized party as a brand-name product. Examples include counterfeit infant formula and counterfeit Heinz ketchup bottles.

Intentional distribution of a contaminated product is the intentional sale of a product despite knowledge of foodborne contamination. Examples include the intentional sale of Salmonella-contaminated peanut products and the intentional export of dioxin-contaminated fish.

EMA has occurred in many food products (see Figure 1). EMA incidents typically do not result in consumer illnesses or deaths since the goal of the perpetrators is to not be detected. However, perpetrators do make mistakes and are not always knowledgeable enough about the safety of the adulterants being used. Adulteration of milk supplies in China with the nitrogen-rich chemical melamine is the most recent example of EMA resulting in widespread illnesses and deaths. In 1981, thousands of people in Spain became ill and hundreds died after consuming fraudulent olive oil that was actually industrial-grade rapeseed oil.