John Points's Posts (579)

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There is already a “failure to prevent fraud” offence in the UK Economic Crime and Corporate Transparency Act 2023 (ECCTA).  If a senior manager commits an offence then the company/organisations also commits the offence in the eyes of the law.  A “senior manager” can be anyone who’s role gave them the authority and autonomy to act in the illicit way they did; it is not limited to particular job titles in the organogram or hierarchical seniority.  However, there is a “due diligence” defence for the company if they have a strong anti-fraud compliance programme in place. 

If food fraud prosecutions are brought under the UK Crime and Policing Act enacted last month, however, there are important differences

  • It applies to companies of any size (unlike the ECCTA which is limited to larger companies)
  • There is no “due diligence” defence
  • It includes offences conducted outside the UK

Although there is no “due diligence” defence, evidence of a strong compliance programme is still essential as this will inform the decision of whether it is in the public interest to prosecute.  Other mitigation advice echoes best practice in food fraud defence but with a more internal focus.  Companies should assess their internal vulnerabilities in terms of who in the organisation has the authority, autonomy, motivation and opportunity to commit fraud “on behalf of” the company.

Taken from an article by Osborne Clarke LLP – read the full article here.

Photo by Bermix Studio on Unsplash

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The Authenticity Methodology Working Group (AMWG) evaluates scientific research developed within the UK Department of Agriculture, Food & Rural Affairs’ Food Authenticity Research Programme, ensuring methods developed are robust and advising on the wider application of methods.

31198692658?profile=RESIZE_400xThis webpage  provides a summary of the group’s work in 2025. All have been previously reported on FAN but the annual summary is a useful collation with links to individual project reports.  They include advice on research projects:

  • Bottled water sampling: 3rd country spring water vs bottled drinking water
  • Offal detection and speciation in meat products
  • British heritage sheep meat traceability system:
  • Honey NMR database
  • New testing methodology for honey authentication
  • Methods for oil authentication

It also includes the committee’s consultation response to proposed research on measuring folic acid in flour and authenticating alternative proteins.

You can find the annua summary here.

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31198406284?profile=RESIZE_400xIn this study (open access), three insect species approved for human consumption in the European Union (Acheta domesticus, Locusta migratoria, Tenebrio molitor), along with six additional species with potential for legitimate or fraudulent use in the food industry (Blaptica dubia, Gryllus assimilis, Hermetia illucens, Schistocerca gregaria, Schelfordella tartara, Zophobas morio), were analysed using liquid chromatography – trapped ion mobility spectrometry – time-of-flight mass spectrometry. Reference samples were obtained directly from breeders and were cooked.

The authors identified characteristic amino acid sequences for each species and genus, enabling taxonomic differentiation. Depending on the insect species, 30–684 characteristic markers and 30–651 species-specific markers were identified.

As a proof of concept, the marker panel was subsequently applied to the screening of 60 commercial insect-based food products to verify their declared species composition. Insect species were successfully identified in all analysed products, including samples containing as little as 7% (w/w) of declared insect ingredient.

The authors conclude that the proposed method is promising as a rapid, accurate, and reliable screening tool for the authentication of edible insect species in food matrices.

Photo by Srihari Reddy Arumalla on Unsplash

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31197762492?profile=RESIZE_400xThis study (open access) set out to assess the use of portable Near Infra-Red (NIR) spectroscopy as a screening tool for spice authentication, with subsequent confirmation by FT-IR  The authors recommend pre-defined decision points, meaning that samples for laboratory confirmatory testing could be selected based on the results of widespread screening tests rather than based (as present) on fraud risk-ranking or audit findings.

The authors tested the approach using market surveys of oregano and cinnamon.  Of 39 oregano samples, 7 screened suspect by NIR, 1 of which subsequently confirmed as non-compliant by FT-IR.  Of 27 cinnamon samples, 17 screened suspect by NIR, or which 12 confirmed non-compliant by FT-IR.  There were no non-compliant samples that that failed to be flagged as suspect by the NIR screen.

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The latest EU Agri-Food Suspicions report, for April 2026, has been published here.  FAN produce a rolling 3-month graphic to visualise the relative prevalence and trends in the main issues.    31195336096?profile=RESIZE_710xI always read through the full report to pick out any subjective impressions not reflected in a numerical analysis.  This month there seemed to be a return to more "traditional" forms of fraud - meat quality or substitution in kebabs, sausages, salami and pate, or substitution of expensive nut ingredients (pistachio in baklava) with cheaper (peanut) - a clear allergy risk.  There is too little data to prove a causal link to general economic pressures but this is certainly one hypothesis.  Bulking up the weight of frozen seafood with excessive glaze and water always features highly.

The EU AgriFood Suspicions reports are only one information source, presenting one approach to estimating fraud frequency.  There are many other approaches, each looking at different data for different purposes.  An overview can be found on FAN's "Incident Trends" page.

 Our interpretation of the Agrifood suspicion reports is subjective. In order to show consistent trends we have excluded cases which appear to be unauthorised sale but with no intent to mislead consumers (e.g. unapproved food additives, novel foods which are declared on pack), we have excluded unauthorised health claims on supplements, and we have excluded residues and contaminants above legal limits.  We have grouped the remaining incidents into crude categories.  Our analysis is intended only to give a high-level overview

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31195155886?profile=RESIZE_400xThis study (purchase required, GBP£29.95) set out to improve the confidence in discriminatory models between Arabica and Rustica ground coffee.

The researchers pooled Arabica (n = 41) and Robusta (n = 21) samples from different origins and prepared in-house “calibration” mixtures.

They compared alternative approaches for processing data obtained by nontargeted ultra-high-performance liquid chromatography coupled to high-resolution tandem mass spectrometry analysis of in-house control Arabica/Robusta mixtures

They report that the most accurate results were obtained by targeted extraction of a set of five ions corresponding to kahweol palmitate, kahweol linoleate, 16-O-methylcafestol palmitate, 16-O-methylcafestol linoleate, and 16-O-methylcafestol stearate. Tthe first two compounds were identified as markers of Arabica and the latter three of Robusta using multivariate statistical models constructed in the first phase of the study on an authentic coffee sample set. This compared favourably with the most common approach currently used by laboratories of classification based on 16-O-methylcafestol quantification.  Using this latter approach, more than 60% of the in-house control coffee mixtures did not meet the preset accuracy criteria.

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31194795488?profile=RESIZE_400xIn this study (purchase required, USD$31.50) the researchers propose a combination of three galloylated flavonol glucosides, quercetin-(galloyl)-glucoside, myricetin-(galloyl)-glucoside, and kaempferol-(galloyl)-glucoside, as origin-specific geographical markers for Ceylon black teas

They identified these markers by untargeted analysis of reference samples of various tea types.  They used quantitative UHPLC-DAD-Q-TOF-MS-based color-oriented metabolomics to systematically characterize the critical compounds associated with the bright-red infusion colour of Ceylon black tea and to further identify potential geographical markers for its authentication.

They report that five representative grades of Ceylon black tea differed in leaf appearance, but all produced bright-red infusions. Ceylon black teas  undergo a relatively low degree of enzymatic oxidation, resulting in higher catechin contents and lower levels of theaflavins, thearubigins, and theabrownins. Untargeted colour-oriented metabolomics with orthogonal partial least squares regression analysis screened and identified 85 key low-molecular-weight compounds associated with infusion colour, some of which were further screened for geographical markers in Ceylon black tea, resulting in the three main candidate markers.

Their discriminatory performance was verified in an independent set of newly purchased black tea samples by targeted quantification using UHPLC-QQQ-MS/MS, followed by principal component analysis, which enabled clear separation of Ceylon black teas from black teas of other origins.

Photo by Jocelyn Morales on Unsplash

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31188879052?profile=RESIZE_400xThis study (IAFP membership or purchase required) investigated whether there are environmental (i.e. non-adulterations) explanations for foreign tuna DNA in canned tuna.  It was prompted by reports that DNA of undeclared tuna species had been found in cans labeled as skipjack. Only one species of tuna is allowed in a can sold in the European Union if the muscle structure of the tuna is visible.

Previous reports had identified environmental DNA (eDNA) from various Thunnus and other species in the ocean and on the tuna catcher vessels and further tracked to the first stage of raw tuna processing in tuna canning (thawing).

The authors built on this work to further investigate if eDNA can be found in other parts of the cannery supply chain during tuna processing in the stages after thawing.

They collected 99 samples from raw/frozen and unfrozen tuna, precooked tuna, and retorted (heat preserved) tuna.  A total of 225 DNA analyses were performed on these samples using Polymerase Chain Reaction (PCR) methods and Sanger sequencing, real-time PCR and NGS-SBS.

They report that DNA fragments from other tuna species are present during tuna harvesting and processing operations. They suggest that eDNA from various Thunnus and other species could be found at multiple levels of the cannery processing chain.

They conclude that their results highlights the drawbacks of using traditional DNA barcoding for the purpose of detecting fraud or mislabeling with retorted canned tuna. They present  mitigation measures for solving the problem of multiple species of muscle meat in tuna products during the canning process.

Photo by Dillon Lobo on Unsplash

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Traditional PCR methods for detecting species adulteration in buffalo milk are both highly sensitive and non-quantitative, and therefore cannot distinguish incidental trace-level contamination from intentional fraudulent adulteration at commercially relevant concentrations.

To address these limitations, researchers in this study (USD $24.95 purchase required)  developed a point-of-use quantitative, and amplification-free detection platform that directly correlates signal intensity with the degree of adulteration. Their approach utilizes the strand displacement activity of Bst DNA polymerase to enable target-probe hybridization without target amplification, in conjunction with a colloidal gold lateral flow strip (LFS) for visual readout and portable quantification. Two single-stranded DNA probes were designed, a gold nanoparticle-conjugated reporter probe and a biotin-labeled capture probe, to specifically hybridize with the buffalo mtDNA D-loop region. Bst DNA polymerase facilitates this process by unwinding the double-stranded mtDNA via strand displacement. Crucially, by omitting dNTPs from the reaction, all amplification is prevented. They report that this design eliminates the risk of aerosol contamination from amplification. Following hybridization, the mixture is applied to a lateral flow strip. The complexes migrate by capillary action, and biotin-streptavidin binding at the test line captures them to form a visible red band.

They report that, when using a portable reader, the colorimetric signal exhibits a strong linear correlation with the fraction of buffalo milk in adulterated samples, with a detection limit of 10% (v/v).

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31188212256?profile=RESIZE_400xChina is the largest market for Atlantic salmon (Salmo salar) in Asia.

This study (open access) tested the species of 186 “Atlantic Salmon” samples sold at the marketplace and online throughout China.  The researchers used a combination of PCR (using a using a fragment of the mitochondrial 16S ribosomal RNA gene, an adaptor primer, and a 6-nucleotide multiplexing tag) and Next Generation Sequencing.

They report that only 53.76% of these samples were genuinely Atlantic salmon (S. salar).   33.33% were rainbow trout (Oncorhynchus mykiss), 3.23% were coho salmon (Oncorhynchus kisutch), 1.61% were chum salmon (Oncorhynchus keta), and 8.06% were pink salmon (Oncorhynchus gorbuscha).. The mislabeling rate of salmon products purchased from online platforms was significantly higher than that from traditional offline stores. There were no significant differences in mislabeling rates among different product categories (fillets/steaks, sushi, and canned processed.

Photo by Fadya Azhary on Unsplash

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The Food Standards Agency has published the results of its 2025 testing programme.

31188073063?profile=RESIZE_400xThey conclude that most of the food tested was safe and authentic, but the survey did reveal some labelling and authenticity failures in Dubai-style chocolate and goat meat products.   The programme targets areas of known or potential risk. Between July and December 2025, 845 products were sampled from national supermarkets, independent retailers and online sellers.  

Dubai-style chocolate 

Only one of the 45 samples of Dubai-style chocolate passed every test and labelling requirement, a finding that prompted the FSA to issue consumer warnings before Christmas 2025.  

Labelling issues were found in 42 of the 45 samples. These included incorrect or missing use-by and best-before dates, allergens not clearly highlighted, ingredients not listed in the correct order and lack of UK importer details. 

Goat meat 

Of the 40 goat meat samples tested, 20 contained only sheep. Another sample contained a mix of sheep and goat meat, and a further sample was found to be wholly deer.    

Slush-ice drinks 

The survey uncovered on-going issues with a small number of slush ice drinks, particularly around glycerol levels and use of glycerol warning posters in shops. 

The programme was delivered in partnership by the three Local Authority Official Food and Feed Laboratories (OLs) and two private OLs in England and Wales. 

A permenant link to the report has been added to FAN's searchable Research database.

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The Mexico Ministry of Health (COFEPRIS) have published a non-regulatory guide to the classification of food supplements.

31188049075?profile=RESIZE_400xA food supplement must satisfy each of four separate legal requirements in order to be marketed, otherwise it must fall into a different regulatory catetory.

  • The General Health Law, which states that supplements must be based on herbs, plant extracts or traditional foods, aimed at complementing the diet, and free of restricted ingredients.
  • The Regulation on the Sanitary Control of Products and Services, which incorporates criteria on composition, exclusion of substances with pharmacological action and, especially, strict rules on labelling, prohibiting therapeutic indications or misleading information.  The guide prohibits the marketing of substances with a pharmacological or therapeutic action as food supplements.
  • The Decree determining additives and adjuvants in food, beverages and food supplements, their use and sanitary provisions, published in the Official Gazette of the Federation (DOF) on December 15, 1999, and its amendments published on September 5, 2013 and May 16, 2016, and the Decree determining the prohibited or permitted plants for teas, infusions and edible vegetable oils, published in the DOF on December 15, 1999, which delimit the substances that can be used and the specific conditions applicable, including labeling requirements in the case of certain ingredients.

This guide establishes the possibility of using the Herbal Pharmacopoeia of the United Mexican States as a reference in the development of food supplements, since it lists plants and their derivatives that can cause unwanted effects, have interactions with other plants and medications,or can be toxic or allergenic.

This aligns Mexico’s marketing approval regulation more closely with that of Europe, but is a reminder that manufacturers and sellers (particularly online sellers) of supplements and botanicals must be highly cognisant of the specific regulations in each country of sale.

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31188048290?profile=RESIZE_400xThis paper (open access) is an example of the growing trend of “data fusion” from multiple techniques to aid authenticity classification.  Contributing techniques can be extremely simple.  In this case the researchers including Differential Scanning Calorimetry (DSC), which is a routine way to measure the melting point of a solid (or the crystallisation point of an oil).  They combined DSC with GC-MS profiling of fatty acid methyl esters (FAMEs) to detect adulteration of walnut oil.

The researchers prepared cold-pressed walnut oils in an normal manufacturing setting, in compliance with the Romania legal specification constraints.  They produced binary mixtures adulterated with sunflower oil between 5 – 50 %.

They report that, as the proportion of adulterant oil increased, thermal parameters changed progressively. Samples with 40% and 50% sunflower oil exhibited low crystallisation enthalpy values, reflecting the dominant thermal characteristics of sunflower oil at higher substitution levels. Chemometric analysis demonstrated strong discrimination between authentic and adulterated oils, with support vector machine models achieving complete classification under the conditions of this study.

Photo by Pranjall Kumar on Unsplash

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31187911495?profile=RESIZE_400xThis paper (open access) draws on previous cost of crime frameworks to develop a model specifically for food fraud in the UK. The novel features of the model are its use of ‘crime scheme’ as the unit of analysis and the introduction of ‘market cost’, the impact of illicit supplies on the legitimate market. The analysis estimates that the annual economic cost of food fraud in the UK is between £ 0.4 billion and £ 2 billion.

The conclusion of this analysis is that the UK food industry suffers a low rate of fraud relative to other industry sectors.  The authors argue that collective action by the food industry has created an overlapping framework of quality controls that squeezes out fraudulent products and creates a significant barrier to entry for unethical businesses and rogue traders.

This estimate chimes with a previous estimate by the Food Standards Agency.  These, and other estimates of the global cost of fraud, can be found on the "Cost of Food Crime" tab on our Food Crime page.

Photo by Jp Valery on Unsplash

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Food Standards Scotland (FSS) are recruiting a Chief Scientific Advisor.  The details of this prestigious, senior, independent role can be found here

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This three day per week role is envisaged as a 2 to 5 year secondment.

FSS’s CSA is an outward facing role, with responsibility for representing FSS’s use of science and evidence to key stakeholders, the media and public, including during incidents. It will promote and champion the work of FSS’s scientists; supporting learning and development and driving engagement across the wider scientific community and the food industry, to maintain and strengthen FSS’s reputation as a highly regarded science and evidence-based organisation.

The closing date for applications  is 14 July.

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JRC Food Fraud Incidents Report - April 2026

The Joint Research Centre of the European Commission has published its latest collation of food fraud incidents.  Your can find the report here.  These are drawn from global media reports, so give a different perspective to the monthly EC "Agri-food suspicions" (which are drawn from regulatory reports).

The JRC reports are used to populate a searchable application, which can be used to visualise trends by food commodity or by country of origin.

Links to these EC resources, plus other tools and resources that draw trends from food fraud incidents, are included on FAN's new Incident Trends Hub.

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We are pleased to launch a new webpage that provides navigation to some of the many tools and reports (both open-access and commercial software) that collate reported food fraud incidents and suspicions, draw trends, insights, and make future predictions.

Most of these tools were already signposted on FAN but we hope that the new hub explains some of the differences (all tools collect data in different ways, for different purposes, and give different insight) and makes it easier for you to navigate.  The hub also includes our own reports and summaries and those provided by our Partners for the benefit of FAN members; you must be logged on as a member to access this section.

You can access the new hub here.  We hope you find it useful.  Please let us kinow your feedback (you can e-mail, or leave a comment on this blog) and let us know any other tools you know of that should be included.

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This monthly highlights report has been produced for FAN members by one of our Partner organisations, iComplai.

31184551252?profile=RESIZE_400xThe report is an AI-generated prioritised digest.  It is blended from online regulatory and media reports of food fraud incidents and suspicions, giving a summary of each selected issue and suggested mitigation steps.

iComplai are one of a number of commercial providers of digital horizon scanning tools, many of whom are signposted on FAN on our new Incident Trends hub.  We do not endorse any specific company.  We are grateful to iComplai for providing this free digest which we hope you find useful.

If you know of a tool which would be beneficial to signpost to our membership, or if you are interested in becoming a FAN Partner, then please get in touch.

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31182495263?profile=RESIZE_400xThe UK government announced this week that they will be implementing national regulations to protect against deforestation.

The regulations will mirror the EUDR requirements in terms of the scope of foods and feed included and the requirement for companies to verify that their supply chains for these commodities do not contribute to deforestation.  There is no timescale announced yet for GB implementation; consultation will start shortly.  In the interim period Northern Ireland will implement the EUDR, under the Windsor Framework Agreement to maintain frictionless trade, phasing in from December 2026.

Anti-deforestation regulations will provide a significant new incentive for falsification of certification and traceability documentation, increasing the risk of origin fraud according to most risk-ranking models.

You can read the UK Government press release here.

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31180561471?profile=RESIZE_400xIn this paper (open access) the authors propose a chemometric workflow for verifying rice varieties.

Authentic rice varieties were sourced from Ente Nazionale Risi, a public economic body supervised by the Italian Ministry of Agriculture, Food Sovereignty and Forestry, These comprised 36 Italian plus varieties from Sri Lanka, Malaysia, Bangladesh, Philippines, Indonesia, Taiwan, Australia, Brazil, India, and Louisiana.  They were characterised by their amylase (“high”, “low” and “waxy”) and by their grain morphology (“Round”, “Medium”, and 3 variations of “Long”).

The researchers built classification models based on both Near Infra-Red Hyperspectral Imaging (NIR-HSI) and on morphological classification.  They found that NIR-HSI alone gave relatively poor classification but they recommend it as a quick, cheap screening tool, with follow-up where required using a morphological classification model.  They propose a morphogram tool to visualise the results.  They report that this workflow gave good results, and recommend it as a routine approach that can be applied at any point where rice is traded..

Photo by Łukasz Rawa on Unsplash

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