By Lisa Lupo
Food authenticity is not a new concept, but it seems to be surging both within the U.S. and on the global front. What’s all the buzz about food authenticity and why has it come to the forefront of the industry? Is it the ultimate solution to food fraud? Or is it simply a way to help assure consumers are getting the product they believe they are buying? To find out more about this emerging movement, QA spoke with four industry experts: Michael Roberts, executive director, UCLA School of Law Resnick Program for Food Law & Policy: John Spink, director, Michigan State University Assistant Professor and Food Fraud Initiative; Karen Everstine, Decernis Senior Manager, Scientific Affairs; and Mitchell Weinberg, International Food authenticity Assurance Organization (IFAAO) founder, president, CEO, and Chairman of the Board.
What is the relationship between food authenticity and food fraud?
Spink: The terms are often used interchangeably, which is confusing. Food authenticity is a state of being. Food authentication testing is a process to evaluate that state of being. Food fraud is the act that creates the problem; it is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product, for economic gain. Food fraud prevention is the process to reduce the chance of food fraud occurring; food fraud mitigation is the process to reduce the impact of an incident after it occurs; and, finally, food authenticity testing is a process to support the food fraud prevention strategy. (See What is ...)
Weinberg: Food fraud is economically motivated adulteration of food. Food authenticity means that the food has not been adulterated, but it is much broader than food fraud. For example, the issue of GMOs touches directly on food authenticity. A natural question that must be asked is whether genetically modified food can be considered authentic. Food authenticity is relevant to marketing and branding, has trade and economic implications, and can mean the difference between whether food is safe or not and whether it is qualitative or not.
Roberts: Food fraud can be very broad —from economically motivated adulteration (EMA) to counterfeiting, sabotage, and false labeling. Food authenticity is a positive way of approaching the problem of food fraud or EMA. It is a process that proves a food or food ingredient is original or genuine and can be verified as such. Food authenticity is a solution that also speaks to value, proving that the food is what it purports to be. Most importantly, food authenticity enables consumers to get what they pay for and increases their overall level of trust of food.
Everstine: Many people talk about food fraud because that is the challenge we are trying to tackle, but the goal is really to ensure food authenticity along with food safety and quality. Food authenticity means that foods and food ingredients are accurately and appropriately represented to the customer (whether that be another food company or the final consumer). This concept of accurate and appropriate representation can apply to the contents of the food as well as the production methods, geographic origin, and other relevant characteristics.
Food authenticity is not a new concept. Why is it now coming to the forefront of the industry?
Everstine: The occurrence of multiple widespread and widely publicized incidents of food fraud over the past decade has increased media attention to issues of food authenticity as well as focus by both the food industry and regulatory agencies.
Roberts: It’s a historic accident that it has taken this long. Food authenticity as a concept in the U.S. was arguably inferred in the meaning of “pure” in the 1906 Pure Food & Drug Act and, as a value, was embedded in the adulteration provisions of Section 402(b) in the 1938 FD&C Act. The Act doesn’t specifically define food fraud or food authenticity, but it does list components we typically subscribe to food fraud. But food authenticity got swallowed up in issues of substitution, such as the margarine/butter wars where margarine was originally presented by the threatened industry as a fraudulent product. Thus, food authenticity as an ethical or legal concept never really developed. What really triggered attention on food authenticity, or at least fraud, was the melamine scandal in China nearly a decade ago, involving pet food and infant formula. But, while EMA did become a subject of regulation, it has continued to escape enforcement because it is not a public health concern. Instead, EMA is seen as a sort of second-tier adulteration problem that generally only gets FDA’s attention if it threatens food safety. If we take off our blinders, we should see food fraud as a crime the type of which we don’t tolerate in other industries.
Today, food authenticity, the absence of food fraud, is aligned with the food movement that emphasizes local, quality, and authenticity. Now, with the enhanced ability to detect food fraud problems and to verify food authenticity, it presents an opportunity in the marketing and branding of food.
Weinberg: Consumers are demanding transparency as to where their food comes from and what is in it. Additionally, food authenticity represents a fresh starting point to address the issue of food integrity. Efforts thus far have ranged from being very effective to ineffective and a new approach will help to assess and streamline what has become highly fragmented and disjointed. As opposed to food fraud, which is seen by the industry as a negative, food authenticity can be positively positioned. If the food industry is able to prove food is authentic, brand value, reputation, and profits can be enhanced.
What is being done today and by whom?
Weinberg: Academic institutions and the Food Authenticity Network (the UK government initiative to help bring together those involved in food authenticity testing) are employing science to prove whether something is authentic. Technology companies are trying to develop technologies to determine authenticity. IFAAO is employing a collaborative multi-disciplinary and multi-stakeholder approach to educate and help institutions like Codex Alimentarius and its member states both define food authenticity and ensure there is a single harmonized approach taken across the globe.
Spink: Food authenticity testing is a form of quality control or specification confirmation. This is a complex food-science concept, so the activities have naturally grown out of food science groups. A criminology forensic chemist would usually focus on different activities but using food authenticity testing would be key for them to confirm a crime has occurred.
Roberts: Because consumers are becoming more aware, they are driving the industry to become more interested. The industry is seeing challenges and lawsuits as to whether their food is authentic, and that is also going a long way to connect branding and marketing with authenticity.
Additionally, it helped when food integrity became a focus of US Pharmacopeia (USP); having such a reputable organization involved increased awareness. But there is a lot of resistance because we don’t really understand the full scope of the problem, and it is rightfully seen as a difficult problem to solve. Even the making of food standards to define what constitutes “authenticity” for food has come to a grinding halt. The honey and olive oil industries have been petitioning FDA for years for a standard, but the agency continues to steer clear of developing this legal tool.
What are the food quality and/or food safety issues of inauthentic food?
Spink: The vast majority of food fraud incidents do not cause a public health threat — but they could. Food fraud is a root cause of food safety incidents. Thus, groups such as GFSI have taken a total quality management approach and focused on reducing the root cause which are vulnerabilities. Thus, food fraud prevention focuses on vulnerabilities first before evaluating and addressing risks.
Everstine: The biggest concern with food fraud is if the substances used will be harmful to human health, such as what happened when melamine was added to milk supplies resulting in illnesses and deaths in babies who consumed infant formula made from that milk. However, beyond that, when we consume foods that have been misrepresented in some way, we are not able to ensure that they were produced with the appropriate food safety controls. We are trusting food safety to people who are intentionally misrepresenting the food they are selling, which is a gamble.
Weinberg: Inauthentic food can be of poor quality and be a safety risk. From a quality perspective, authentic food ingredients may command a higher price. If foods are inauthentic, then they should not command the same price as authentic food.
Can we completely authenticate the provenance of every food and ingredient?
Weinberg: Yes. It will take a harmonized combination of science, technology, intelligence, policies, standards, and laws.
Spink: Theoretically, probably, in most cases. In reality, no. The food itself is so variable… if there is more rain, then some of the profiles can change. Also, there are so many ingredients — let alone molecules — that authentication is complex. Food is not a synthetic chemical that is refined to be 99+% pure. We can continue to find ways to determine certain aspects such as DNA, ionization of water, etc.
But what if water from the San Fernando Valley is used to irrigate crops in Napa Valley? The authenticity testing of the ionization of the water may identify fraud. The wine is labeled and presented as a product of Napa Valley and does not state anything about the water that is used. Authentication is too costly and time consuming. Consumers don’t want to pay $10 for a single regular old apple.
Everstine: We need to be strategic in our approach to ensuring food authenticity. In cases where the provenance or production method adds value to the product, stakeholders along the supply chain will probably want to put in place extra measures to ensure authenticity. But it is certainly not feasible to conduct extensive testing on foods at every point in the supply chain. An effective plan for ensuring food authenticity will focus on those foods and ingredients that are the most vulnerable, use a combination of risk reduction strategies, and ensure resources spent on analytical testing are as targeted as possible.
Roberts: Too often, consumers either don’t know to ask questions about the authenticity of their food, or if they know, they don’t know whom to ask or if that person would even know. The industry, especially smaller companies, often doesn’t know how to authenticate the food back to the source — and the effort to do it would put them at an economic disadvantage.
But to solve a problem, one should start with the lowest hanging fruit which includes honey, olive oil, spices, juices, and seafood. Why not start with products where we know there’s a problem and build from there? Technology is often seen as the panacea for the problem, but I keep reminding folks that while we need technology and testing to combat this problem, effective governance and enforcement are also essential.
How would globally harmonized standards be of benefit?
Weinberg: A globally harmonized standard would level the playing field for countries and stakeholders in the food industry. If everyone is acting in accordance with a single standard, it is easier to regulate the issue of food authenticity. For consumers, food authenticity means that consumers can know where their food is coming from and what is in it, and have comfort in knowing that they are getting what they are paying for.
Spink: Harmonization of terms and management systems will help everyone at least start on the same page. In the past there have been different projects with different scopes of work, and the findings could not be combined. I was at a conference where a European business person said he was working on TACCP and VACCP (threat and vulnerability assessment and critical control point systems). Because these are GFSI concepts that are being more generally adopted, the U.S. colleague knew exactly what they were talking about. Those two people could immediately start talking about the details and sharing best practices. An important part of the international harmonized activity is the shift to prevention — and that of an interdisciplinary and complex focus on the entire problem, not just pieces. For example, the root cause is a human adversary, so the fraud opportunity is based on criminology theory such as situational crime prevention. But long before considering what to do for the “risk treatment,” there is a need to diagnose the problem and include a way to evaluate if the treatments actually help reduce the problem. Additionally, food fraud prevention theory shifts the focus from emergency room reaction to a long-term focus on your total health which includes some preventive measures. (For example, it can be likened to the preventive use of sunscreen vs. applying aloe vera on a sunburn or being treated for resulting melanoma.)
Roberts: In 2017, our UCLA program published a white paper, The Pursuit of Food Authenticity, explaining that a well-developed definition of “authenticity” could be emulated elsewhere and facilitate global harmonization. Next, we need to be able to verify authenticity, so we need to have standards. As I have mentioned, standards making has fallen out of favor; however, perhaps we need to reassess the purpose of standards and our approach in making them.
Everstine: Global standard-ization can be helpful to both industry and consumers by providing a common set of requirements that increases food safety and facilitates trade. For example, GFSI’s business-driven initiative that benchmarks global food safety standards can enable and simplify communication, drive harmonization, and benefit the industry and consumers.
Where is food authenticity going from here? What needs to be addressed?
Roberts: We need to have a verifiable approach to food authenticity, but it also needs to be based on technology and governance.
Technology creates a double-edged sword in that we get better at testing, but cheaters also increase their ability to deceive. As to governance, who will enforce it? Will it be solely FDA? Or also the Department of Justice? The INTERPOL sting in Europe in 2016 resulted from a combination of agencies working together — that’s what it takes.
Unfortunately, this sting was a one-time hit, but it does set an important precedent. Organizations, like the International Food Authenticity Assurance Organization (IFAAO) with which I am involved, need to continue to step up and work the system. IFAAO is working closely with Codex Alimentarius in defining and promoting food authenticity.
Finally, we need the industry to commit to the pursuit of authenticity. In our white paper, we suggest that the industry should adopt the value of authenticity just as it has sustainability. Incorporating authenticity in a real and meaningful way is a chance for the industry to self-regulate and create for themselves a market value.
Spink: I think the next evolution is actually a very slow and steady harmonization of the definition of terms and scope of work. The scope is expanding from reaction and detection to prevention and deterrence. This expanding scope is incorporating criminology to consider the root cause and also business decision sciences for “how much is enough.”
Weinberg: The approaches taken by the food industry to address food fraud are woefully inadequate. The issue should never have been exclusively assigned to food safety and quality people. Those individuals are extremely competent at what they do, but food fraud is a criminal issue and should have been assigned to people accustomed to dealing with criminal conduct. Food fraud occasionally presents food safety issues, but the larger issue is one of economics. Consumers are being cheated every time they purchase consumer ingredients or food that is not genuine. None of the solutions put forward thus far by the food industry have addressed this critical issue.
Everstine: This is a rapidly developing area and the good news is that many organizations are working hard to develop tools and resources to support the food industry in its goal of ensuring food authenticity.
The author is Editor of QA magazine. She can be reached at firstname.lastname@example.org.