The latest official assessment warns that criminals remain active in UK supply chains. Experts believe Brexit and covid will only increase the risk to businesses. Nick Hughes reports.
Why are we talking about this now? The Food Standards Agency (FSA) and Food Standards Scotland (FSS) recently published their latest assessment of the threat to the UK from food crime, which the agencies define as “serious fraud and criminality within food supply chains”.
Should we be worried? Well, the good news is that the FSA’s national food crime unit and Scottish food crime and incidents unit (SFCIU), set up in the wake of the 2014 Elliott Review into the integrity and assurance of food supply networks, jointly believe there is minimal evidence that organised crime groups are active in the UK food sector. This is in contrast to certain overseas countries: in Italy so-called agromafia groups are known to play a key role in the food industry; while in Mexico increasing global demand for avocados has seen rising interest in food production by crime cartels.
So what should we be worried about? The cost of food crime is notoriously difficult to quantify, however the Centre for Counter Fraud Studies at the University of Portsmouth has estimated the possible annual losses to the UK at £11.97bn. The Food Crime Strategic Assessment (FCSA) doesn’t put its own figure on the cost but it does conclude that, rather than criminal activity not being an issue in the UK, food crime is mostly committed by people with an existing role in the food and drink economy, be they traders, suppliers or sellers of food to the end consumer.
What kind of thing are we talking about? The most common crimes involve substitution, adulteration and misrepresentation of food products and there is evidence in the FCSA that these are still reasonably commonplace.
Substitution involves replacing a food product or ingredient with another substance of a similar but inferior kind. Fish is a classic example: sampling of takeaways during the FCSA’s reporting period found instances of high value species such as cod being substituted with lower value species like pangasius, coley and whiting.
What’s the difference between that and adulteration? Adulteration is where the quality of the food is reduced by the inclusion of another, usually lower-value, substance with the intention of making production costs lower or the perceived quality higher. The horsemeat scandal of 2013 remains the highest profile case of adulteration in this country but other products such as olive oil, honey and herbs and spices are more common targets for criminals. The Institute for Global Food Security recently found that over 25% of sage samples tested were adulterated, with the sage often bulked out with non-food materials such as olive leaves.
And misrepresentation? This is where information provided to the buyer falsely conveys a higher value to the product; for instance labelling a food as organic when it has been produced conventionally, or falsely using an EU protected designation such as Parma ham or Prosecco for a product produced outside of these regions. An important one for the foodservice sector is misrepresentation of durability dates whereby meat, for example, is given a longer use-by date than it should have. In 2018, meat supplier Russell Hume fell into administration after a recall of meat products related to processes around use-by dates caused a number of foodservice customers, including JD Wetherspoon and Jamie’s Italian, to terminate supply contracts.
Are there any other risks specific to the foodservice sector? The FCSA cites the rise of online aggregator platforms as an emerging avenue for misrepresentation where ready-to-eat food is being delivered directly to consumers from so-called “dark” kitchens. Throughout 2019, cases have been reported of food sold through these platforms coming from an unregistered food business operator (FBO) or misrepresented as being from a higher quality establishment.
Any other emerging risks we should be aware of? Social media is increasingly seen as a “wild west” for food with precious little traceability. Much of the food sold on platforms like Facebook and eBay is produced in residential kitchens by people who have not registered as food businesses and therefore food hygiene checks are unlikely to have been carried out. The risk of allergens not being properly labelled is a key concern over food sold via these platforms.
Has covid-19 increased the risk of food crime? The assessment was drafted before the pandemic hit but in a short piece of additional commentary the FCSA notes that the “imbalance of supply, demand and controls appeared to provide the perfect environment for those seeking to commit food crime”. However, evidence of criminal exploitation has so far been limited, the FCSA notes. This may not be the case for long. Professor Chris Elliott, director of the Institute for Global Food Security and author of the eponymous government review, predicted in a recent New Food magazine article that “2021’s assessment will tell a different story”.
And what about Brexit? The FCSA says there is no evidence to suggest that the UK will be at more risk from food crime as a result of leaving the EU. But “our new status does remain a factor for active consideration and situational awareness”. Specifically it points to the Irish land and sea border as an area for “particular vigilance”. More broadly, it notes that “regardless of the outcome of the current UK/EU trade talks, the food landscape will almost certainly change in some way and with it potential new opportunities for food crime”.
Professor Elliott is more forthright in his view. “Personally, I can see Brexit causing some issues, both in terms of reduced intelligence coming from our European neighbours and also lower (if any) scrutiny checks on goods entering mainland Europe for transhipment to the UK,” he wrote. “For those that believe our hard-pressed border inspection forces can deal with the massive ramping up of inspection, I suggest they think again.”
Why should businesses be concerned about food crime? In the most serious cases, selling fraudulent food can present a severe food safety risk where, for instance, allergens are used to adulterate products and then not declared on the label. More commonly, the risks are reputational but can still be devastating to a business as Russell Hume discovered to its cost.
So what can foodservice businesses and their suppliers do to protect themselves? The advice remains much the same as when Professor Elliott published his seminal review. Developing trusted relationships with a small number of suppliers is important; some businesses have already signalled their intention to shorten supply chains in response to the challenges posed by Brexit and covid-19. Regular horizon scanning for future risks is another key prevention strategy with large fluctuations in commodity prices providing an early warning signal that a food or ingredient could be susceptible to fraud. Targeted testing and sampling is also important, with the FCSA noting that future scientific developments in food authenticity testing are likely to increase the capability to detect fraud across a wide range of food types. Businesses can also join collaborative networks where information and intelligence is shared. Major supply chain players such as 2 Sisters Food Group, Brakes, Booker and Compass Group are part of the Food Industry Intelligence Network established in the wake of the horsemeat sandal.
Finally, businesses – and their buyers in particular – need to use common sense. If a deal looks too good to be true, it probably is.