Chris Elliott on Food Fraud & The Elliott Report

I attended the Highfield Fighting Food Fraud Conference on 17th September, where Professor Elliott was speaking so I thought I would share with you what I learned at the presentation…

Professor Chris Elliott was contracted by the government to write a report, to provide learnings from the horse meat scandal.

Chris was an amazing speaker and his presentations (he did two, I’m just sharing one of them here with you) were really insightful. He really brought it home for me, how important the work that we are doing to tackle food fraud is and that ultimately we’re dealing with criminals.  All these small steps that we are taking, to make us more aware and to protect our businesses and the consumer are so important.

There’s a link at the bottom of this post if you would like a copy of the Elliott Report and I’ve also put together a free Food Fraud & Food Crime Fact Sheet for you, which provides you with lots of really useful information about previous issues that you can use in your own vulnerability assessments.  To get your free fact sheet, just click below to be directed to our sign up page.

Elliott Report

What is the difference between food fraud and food crime?

There is no legal definition for food fraud or food crime, however below is Chris’ interpretation.

A food fraud is an act carried out by fraudsters for financial gain, where the food or food packaging is subject to substitution, dilution or misrepresentation (where it’s labelled as something that it’s not, like a brand name). Food fraud is normally a random act, which is borne out of a particular situation and possibly not meant to be deceptive.  For example, a manufacturer may have a lack of raw materials to fulfil an order and so, they may substitute an ingredient to get the order out.

Note – Chris talks about packaging too, whereas BRC only talks about food raw materials, so this would lead you to believe packaging would not be included.

A food fraud becomes a food crime, when it is no longer just a random act but is organised by a group, with the intention of being deceptive or to injure.

What are the main types of food fraud or food crime?

Substitution: where part or all of the food with a lower value substitute. Such as replacing beef with horse, or other oils in olive oil. Or a recent example when ground nut shells were added to spices.

Addition: adding a component to increase the value of the overall product.  One of the most well known issues of this kind is when milk in China had melamine added, as melamine when tested looks like protein, meaning a higher protein content milk has a higher value. Another example would be the Sudan dye issues when the colour was added to spices to improve their colour, meaning they had a higher value.

False claims: this where products are labelled with fraudulent claims that increase their value, such as organic, welfare friendly, fair trade and provenance claims such as country of origin.

 Interesting fact – twice as much organic food is purchased in the U.K as there is produced!

Did you also that for a compositional product to be labelled with the Fairtrade logo, the pack must only contain 20% Fairtrade product. Not fraud, but I’m not sure that the normal consumer would understand why that was ok, and may think that it was a little misleading….

What are the risks?

The risks to business are extensive, loosing consumer trust can have a massive impact on brand damage and subsequent financial losses. The Findus brand was hugely affected by the horse meat scandal, so much so you can no longer buy any meat Findus products at all anymore.

The risks to the consumer are even more so and include a feeling of being cheated, as they haven’t got what they paid for, direct food safety health risks  and also long term health risks if they are exposed to something that is toxic over a period of time or due to lack of nutritional content (the issue in China where rice was diluted with plastic which looked like rice).

What actually happened in the horse meat scandal?

The story broke in 2013, when a Tesco beef burger was found to contain 29% horse meat.

It is thought that Tesco had agreed supply of Irish beef through a European company. Allegedly the EU company due to pressure sourced the beef from Poland, which was sent to Ireland.

Both parties believed the other was at fault, nobody really knows, because the beef didn’t go directly from Poland to Ireland but actually went through lots of other places in between. So the ‘swap’ is untraceable.

At the same time Findus contracted a French company to supply them with beef.  This company then subcontracted to another, which was then subcontracted again and so on. The last subcontractor was a man in Cyprus who never actually saw the meat, but acted as an agent using a mobile phone.

29 people over 4 member states were arrested, but no one really knows how long it had been going on.

The driver (or the pressure that caused it) is thought to be the economic downturn in Europe, which meant people who owned horses no longer could afford them. This provided an opportunity for organised criminals who realised that they could purchase horses for just a few Euros each. In addition, many horses went missing.

Just taking the Tesco and Findus cases as an example, both criminal networks were working independently, with no cross over between them.

How vulnerable is the UK?

The industry is worth over 100 billion pounds. Chris said, “it’s on a massive scale and incredibly complicated.”  It employs over 37 million people and is far from being self sufficient as it imports 40% of the food manufactured.

The Elliott Report – what are the 8 pillars of food integrity?

Chris proposed 8 pillars in the Elliott Report, which are 8 areas for improvement to protect the UK from future food crime.  You can get your copy of the Elliott Report here – The Elliot Report July 2014.

These are:

  1. Consumer first
  2. Zero tolerance
  3. Intelligence gathering
  4. Laboratory tests
  5. Audit
  6. Government support
  7. Leadership
  8. Crisis management

I’ll go through each one, as Chris explained them to us.

1. Consumer first

UK consumers have lost trust in the UK supply chain.
A survey showed that 3 months after the horse meat scandal, consumer trust was at its lowest ever – lower than following the PSE or CJD link, even though horse meat didn’t cause any harm.
The first pillar of the Elliott Report is that food safety and food crime has to be the priority over everything else.

2. Zero tolerance

A zero tolerance policy has to be adopted.
Chris compared this to crime in the USA, when New York used to be the most dangerous city in the US.
When the new Mayor took over she introduced a zero tolerance policy. By doing this she managed to change the mind set of what was acceptable and within 5 years the crime rate was reduced so that it was no longer number 1.
Chris said “Any cheating be it small or trivial must no longer be acceptable.”

3.  Intelligence gathering

Information is key.  When Chris was carrying out the research for the report, the FSA had a hotline to receive this type of information.  In 2012 the FSA received 85 tip offs. Compare this to the Netherlands where their information gathering system received 120,000 tip offs in 2012. We need this type of system in the UK, where the information is then collated and analysed to produce between 5 and 10 investigations.

4.  Laboratory tests

In the UK we used to have a good public analyst system, which was originally set up due to instances of food fraud.  Due to cut backs in local authorities, the number of laboratories is much reduced, meaning there is much less surveillance.  Chris wants the labs that are left to come together and work more collaboratively, in order for them to survive.

5.  Audit

During Chris’ research the number of audits on manufacturers was the number one complaint.  But none of these audits were looking for food fraud. Chris recommended that audits should be moved from announced, to unannounced.  At the time this was met with a lot of negative feedback, but since then Asda have moved to unannounced, Tesco’s already work to unannounced and now M&S have also become unannounced too. There are also plans to develop a BRC food fraud module.

6. Government support

At the time of writing the Elliott Report, there was no one government department that was responsible for food fraud.  Therefore, Chris recommended that the government bring their departments together to talk about the UK supply chain, as no one department can do it on their own.

7. Leadership

The government need to provide leadership in this area, so Chris recommended that a Food Crime Unit be set up.
Today, we now have a Food Crime Unit. Andy Morling has been appointed Head of Food Crime and has 25 years experience in organised crime, as he used to work for the National Crime Agency.

8. Crisis management

When the horse meat scandal struck, because no one person or department was responsible, no one knew who should deal with it.
This is why it took 3 months before the police were even involved and hence why there have been zero prosecutions in this country.  Therefore, to be able to tackle the future issues more effectively they must have a plan in place. They must know who is in charge and what needs to be done.

A year on from the Elliott Report being published, Chris is pleased with progress but feels there is still much to be done. He feels industry must manage the supply chain and government really need to convey to the consumer that they come first.

He said “Keep your eye on the ball, because we might not be so lucky next time.”

Also, don’t forget to get your copy of our FREE Food Fraud and Food Crime Fact Sheet, which provides you with lots of really useful information about previous issues that you can use in your own vulnerability assessments. Click the button below:

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