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Fighting food fraud in natural colors, flavors

Rainbow cupcakes lined up in an arch

KANSAS CITY, MO — Reformulating products using natural colors and flavors opens up new opportunities for bakers. It can also expose them to a higher risk of ingredient fraud, which is on the rise.

Food fraud is the act of deliberately substituting, diluting, mislabeling or misrepresenting an ingredient in an effort to reduce costs or increase profits. It tends to occur most often with high-cost, high-variability ingredients such as vanilla, olive oil, honey and cocoa, as well as with higher-risk ingredients such as cinnamon, spices, nuts, colors, flavors and specialty grains. It’s often driven by commodity price volatility or margin pressure.

“Vanilla may be extended with synthetic vanillin, honey may be diluted with cheaper syrups, cinnamon may be substituted with lower-cost cassia,” said Kevin Kenny, founder of Invenimus Training Institute, which provides food safety training to the global food, product and packaging industries. “Natural color claims may not match the actual ingredient source.”

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Food fraud enforcement resources

Because food fraud sits at the intersection of food safety, food quality, consumer protection, customs enforcement and criminal fraud, consistent regulation is difficult.

“It is a cross-functional effort,” said Sara Jane Bellocchi, strategic accounts manager with TraceGains. “Procurement influences supplier selection and reactivity to price pressure. R&D typically manages the ingredient substitution process. Operations is responsible for receiving ingredients and following procedures for quality and safety.”

In the US, the problem is addressed via the Federal Food, Drug and Cosmetic Act’s adulteration and misbranding provisions and FSMA Intentional Adulteration rules. Enforcement can involve the FDA, USDA, US Customs and Border Protection, state agencies, and, in serious cases, the US Department of Justice.

Global Food Safety Initiative (GFSI)-recognized schemes such as Safe Quality Food, Brand Reputation Compliance Global Standards, and Food Safety System Certification 22000 now require food fraud vulnerability assessments and mitigation plans. The Codex Alimentarius Commission sets standards globally, and the European Food Safety Authority and EU Food Fraud Network coordinate enforcement. In Canada, the Canadian Food Inspection Agency enforces the Safe Food for Canadians Regulations, and the Food and Drugs Act for labeling and adulteration.

“Regulations are strong on paper, but enforcement is often reactive and resource-limited,” said Freeman Libby, senior advisor at The Acheson Group, a global food safety consulting firm. “Fraud tends to be uncovered after economic or safety damage occurs, but most investigations result from consumer complaints.”

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Identifying food fraud in natural colors and flavors

Many food fraud risks originate upstream in the supply chain, before ingredients ever reach the manufacturer. Natural colors and flavors are often harder to verify than synthetic or commodity alternatives because they come from agricultural sources that vary by crop, region, season, weather, harvest conditions and processing method. Synthetic detection methods can be costly.

“Synthetic alternatives are usually more chemically consistent, less expensive and easier to standardize analytically,” Kenny said. “Natural ingredients often require more sophisticated verification tools — such as isotope ratio analysis, chromatography, spectroscopy, DNA testing or fingerprinting — against known authentic reference materials. The goal isn’t to test everything. The goal is to understand where fraud would be most profitable, easiest to hide and hardest to detect.”

Once natural colors and flavors are extracted, blended, concentrated, deodorized or standardized, they can become much harder to verify their origin. Additional documentation related to country-of-origin verification, processing methods, extraction solvents used, organic status, sustainability claims, allergen controls and compliance with natural definitions is required.

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“These requirements become especially important when the ingredient supports a natural, organic, plant-based, sustainably sourced, single-origin or no artificial colors claim,” Kenny said. “Companies need documentation not only for food safety but also for claim substantiation.”

He offered eight best practices for bakers when it comes to auditing ingredient supplier claims:

  • Conduct supplier risk assessments and vulnerability analyses
  • Perform unannounced, on-site supplier audits; verify chain-of-custody
  • Use analytical authenticity testing
  • Periodically verify the COA with an independent or buyer-directed testing service
  • Carefully monitor price increases and market disruptions to minimize food fraud risk
  • Use approved supplier programs with periodic requalification to build reliable, longer-term vendor relationships
  • Understand that if the price for a competitive ingredient or product seems too good to be true, it probably is

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