Food Crime

FOOD CRIME
STRATEGIC ASSESSMENT 2020
This document is produced by the

NATIONAL FOOD National Food Crime Unit (NFCU) and
CRIME UNIT the Scottish Food Crime and Incidents
Unit (SFCIU).
Table of Contents
Probability and Uncertainty............................................................................................... 2
Foreword........................................................................................................................... 3
1. Executive Summary....................................................................................................... 6
2. Introduction .................................................................................................................10
2.1 Purpose and structure .......................................................................................................... 10
2.2 Information sources and limitations .................................................................................... 11
3. Current Environment .................................................................................................... 12
4. Food Crime and Serious Organised Crime .....................................................................19

4.1 Overview ................................................................................................................................ 19
4.2 Exploitation of the food system.......................................................................................... 20
4.3 Food criminals and serious organised criminals................................................................ 21
5. Threat Assessment ..................................................................................................... 23

5.1 Overview ............................................................................................................................... 23
5.2 Theft .......................................................................................................................................25
5.3 Unlawful Processing ............................................................................................................ 29
5.4 Waste Diversion.................................................................................................................... 32
5.5 Adulteration and Substitution............................................................................................. 33
5.6 Misrepresentation ................................................................................................................ 43
5.7 Document Fraud ...................................................................................................................52
6. The Future of Food Crime ............................................................................................ 55
7. Next Steps ................................................................................................................... 59
Appendix A – List of Contributors .....................................................................................61
1
Probability and Uncertainty
the Professional Head of Intelligence Assessment (PHIA))1 has been used to ensure
ranges considered when such language is used:
1
The Professional Head of Intelligence Assessment is based within the Joint Intelligence
Organisation
2
Foreword
It is four years since the National Food Crime Unit and Scottish Food Crime and Incidents Unit
from food crime.
operational activity, demonstrating our continued focus on this complex area of criminality.
This includes strong consideration of the value of food crime prevention; many of the
The UK is a safe food environment. However we do recognise the potential for changes within
the food and drink sector to similarly alter the landscape of criminal opportunities in this area,
and the assessment articulates some points of required vigilance. There is no evidence to
suggest that the UK will be at more risk from food crime as a result of leaving the EU, however
our new status does remain a factor for active consideration and situational awareness.
relationships which we establish and maintain with partners in the regulatory environment,
law enforcement and also within the private and third sectors. We’re pleased to be able to
draw on intelligence, data and insight from these partners in this assessment.
There are areas of consistency between our baseline document and this latest assessment of the
threat. These include areas of clear harm to consumers, such as the toxic chemical
groups, despite evidence of the activity of such groups in and around the food and drink sector.
We use this document to drive our own work to tackle the food crime threat, and to support
how we prioritise themes within this landscape and develop strategies to tackle them.
further mitigate associated risks and harms, with the support of our partners.
As our assessment concludes, a continued focus on the tangible threat which food crime
Darren Davies Ron McNaughton

Head of Food Crime Head of Food Crime and Incidents
National Food Crime Unit, Scottish Food Crime and Incidents Unit,
Food Standards Agency
3
FOOD CRIME STRATEGIC ASSESSMENT 2020 • • • OFFICIAL
Since this assessment was drafted, the Covid-19 pandemic has spread across the
exception.
In the UK and Europe, ‘lockdown’ and social-distancing caused the temporary closure of
much of the food service, or ‘out-of-home’, sector1,2. Consumers switched to shopping
closer to home, or via online platforms and delivery services3. Uncertainty led to changes
in consumer behaviour, with stockpiling of some products such as dry pasta and frozen
vegetables further straining retail supply routes largely operating on a ‘just-in-time’
basis4. After the initial shock, the retail sector was largely able to adapt to cope with this
increased demand and purchasing behaviour has since returned to normal levels5.
due to gaps in accreditation or assurance scheme membership, as well as means to

produce retail size packs6. Lockdown measures led to temporary reductions, or cessation,
of some audits and inspections, and the introduction of remote audits7 to ensure
businesses are handling and producing safe and authentic food. This imbalance of supply,
demand and controls appeared to provide the perfect environment for those seeking to
commit food crime, but evidence of criminal exploitation has been limited.
The impacts of Covid-19 go beyond the food service sector. Online sales have been
estimated to account for between 11.5 to 13% of the groceries market, almost double its
share for the same period in 20198. Sales of vegetable and recipe boxes have increased9
as have purchases via social media platforms for some groups10. We discuss some of the
risks associated with the purchase of food online, including challenges around regulation
and reduced traceability, later in the assessment.
1
Lockdown in the UK was announced on 23rd March 2020. Restaurants, bars and cafes
closed on 20th March.
2
Around 80% of Accommodation And Food Service Activities Businesses were closed
temporarily during the lockdown period until the beginning of May (Business Impact of
Covid-19 Survey (BICS)
3
Covid-19 Consumer Tracker Waves 1 and 2, Food Standards Agency (FSA), June 2020.
4
COVID-19 and food supply
2020.
5
The National Food Strategy - Part One, July 2020.
6
Maintaining Post-Covid-19 Capacity in Hospitality and Food Service Supply Chain
Businesses - 'The Squeezed Middle', Food and Drink Industry Roundtable, June 2020.
7
Coronavirus: Red Tractor completes 6,300 remote assessments, FarmingUK, July 2020.
8
The Power List 2020: online shopping, The Grocer, June 2020.
9
Veg Box sales increase by 111% in six weeks as a result of Covid-19, Food Foundation,
May 2020.
10
Covid-19 Consumer Tracker Waves 1 and 2, Food Standards Agency (FSA), June 2020.
4
The pandemic has also led to an increase in food insecurity for many11, with the number of
emergency food parcels distributed by food banks up 177% in May 2020 compared to May
2019.12 An increase in demand for cheaper food products, as disposable income is reduced
for many, is likely to create opportunities for food crime. The increasing importance of
price in purchasing decisions, perhaps at the expense of quality and traceability, may
Since the easing of lockdown restrictions13, most of the food service sector has been able
to reopen14. However, estimates suggest that it could take up to a year for the food service
sector to return to pre-Covid levels15, even with government support for the sector16.
remain. This, in combination with the impact of the economic downturn and increasing
unemployment17 on consumer purchasing patterns, is likely to produce an environment
requiring continued awareness in some areas. We remain vigilant to the opportunities this
environment could present to food criminals and recognise the need for the capacity and
capability to take timely action.
At time of writing, a second wave of Covid-19 infections remains plausible. It is likely
seen and experienced previously due to seasonality factors and a changing social and
economic landscape. The Units will continue to monitor the impact of any disruption
11
2020.
12
Independent Food Bank Emergency Food Parcel Distribution in the UK, Independent
Food Aid Network (IFAN), July 2020.
13
Pubs, restaurants and accommodation sites have been able to reopen in England from
4th July 2020.
14
Nearly 80% of Accommodation And Food Service Activities Businesses were trading in
(Business Impact of Covid-19 Survey (BICS)
National Statistics (ONS), May 2020).
15
2020.
16
Eat Out to Help Out launches today, Gov.UK, August 2020.
17
Boris Johnson warns 'long, long way to go' for UK economy, BBC News, August 2020.
5
1. Executive Summary
1.1.1 This assessment looks to describe the threat to the UK and its interests, from food
crime – serious fraud and related criminality within food supply chains.18
1.1.2 It is a complex sector of criminality, with many detailed technical aspects and a
broad variety of methodologies at play within it. Consequently, maintaining a current
continuous process.
1.1.3 There are noted disparities between the current shape of the regulatory framework
surrounding food and drink, and the broader landscape of how consumers and
businesses source food and ingredients. These can make the task of ensuring that
1.1.4 It is acknowledged that matters of fraud, in broader terms, do not always fall within
the priority thresholds of other law enforcement bodies.
1.1.5 Within the food crime landscape, we note threats which stem from the actions of
criminals working within the bounds of the United Kingdom, alongside others which
arise from the illicit actions of producers, processors, suppliers or traders operating
overseas is less important, for example with non-perishable products sold online and
shipped directly to the consumer.
1.1.6 Our collective response needs to acknowledge this duality within the food crime
the safety and authenticity of the food we eat in the UK. The ways in which industry
1.1.7 Another area of variance between domestic and overseas food crime is the degree to
which the involvement of more traditional organised crime groups (moving into the
food crime is committed by those with an existing role in the food and drink economy,
and the access to markets which this provides is clearly an asset to those criminals.
1.1.8 This assessment does recognise that criminality takes place in and around the
food sector without directly impacting on the safety or authenticity of food, but
nonetheless resulting in harm to communities, to vulnerable people and to the UK’s
broader interests.
18
gain; conducted by group of people in pursuit of common purpose; or involving the use of
violence.
6
1.1.9 The key themes within this threat assessment show some continuity with those
one another is something which has changed, and which we better understand.
1.1.10 Most food crime relates to two broad classes of activity – either the repurposing
of materials holding little or no value in the food chain as edible and marketable, or
the sale of passable food, drink or feed as a product with greater volume or more
desirable attributes.
1.1.11 When we consider the volume and variety of reporting, we note areas of clear focus,
with the various stages of the meat and poultry sectors featuring prominently,
stages of production and scales of enterprise, and the risk within these sectors, and
others, will not be consistent across all phases and scales of supply.
1.1.12 In other areas, it is the severity of the harm resulting from the criminality which draws
attention. The clearest example of this is the toxic chemical 2,4-dinitrophenol (DNP),
which continues to cause fatalities of UK consumers following its sale as an illegal
fat-burner. This demands a continued operational response from the Units as well as
cross-government approach is taken to tackle the sale and supply of this substance
for human consumption.
1.1.13 There are areas which we recognise as key features within the threat landscape, but
of the internet and e-commerce in food crime (both now and in the future), and how
communities.
1.1.14 As we look ahead to the end of the transition period we note the requirement for
continued vigilance around the changes to the dynamics within the food and drink
economy, and the shifts this may generate in the presence, absence and scale of the
windows of opportunity for food criminals.
1.1.15 The Units will use this assessment to develop their priorities for the coming period,
and to develop and deliver strategies to counter the most harmful threats, and to
garner more intelligence where we have gaps in our coverage.
1.1.16 In tackling food crime there are three key lines of defence for ensuring that food is
both safe and authentic. There are roles to play for food businesses, for the regulatory
and law enforcement community and for consumers in shopping thoughtfully and
raising concerns where they hold them.
1.1.17 We will ensure continued engagement with partners and remain committed to playing
mitigate the risks to consumers everywhere from those who fraudulently introduce
unsafe or inauthentic food into our communities.
7
Threat assessment – highlights

The below commodities and themes are likely or highly likely to continue to manifest in food
Product types
Commodity or theme Assessment summary

Several points of risks within the red meat sector ranging
from livestock theft and the entry of meat from stolen or
illicitly slaughtered animals into food chains, to adulteration,
Red meat
industry sampling data points to very low levels of anomalies
Criminality relating to the marketing of substances unsafe for

Dangerous
non-foods therapeutic properties for various conditions) is high harm,
Illegal harvesting continues around the UK coastline,

followed by misrepresentation of product provenance to
The high harm but low prevalence issue of spirit drinks

adulterated with industrial alcohols is noted, alongside
Alcohol
less harmful but detrimental issues of counterfeit and
assessed as at high risk of food fraud owing to their nature or

products
Fish non-compliance than local authority checks; the application

of illicit treatments to tuna is also of note although the scale
Eggs
8
Cross cutting themes and techniques
Commodity or theme Assessment summary
Meeting demand
well as domestic practices such as illegal slaughter, can
facilitate the provision of food products popular with various
communities
Misuse of premium status labels, including designated origin

Misrepresentation
of premium
status or
provenance
The entry into the food chain of products which should not
be there is at its most notable with animal by-products (ABP),
Diversion of
waste products
but enter secondary sales routes, despite having been
Routes via which the internet enables the provision of

fraudulent and/or unsafe food to consumers (as well as items
E-commerce which may facilitate food crime) include social media sites,
other online marketplaces, standalone trading sites and the
A noted modus operandi which leaves suppliers out of pocket

European
Distribution
Fraud
9
2. Introduction
2.1 Purpose and structure

2.1.1 The Food Crime Strategic Assessment 2020 (FCSA) outlines the current understanding
of the scale and nature of the food crime threat to the UK, highlighting any gaps in that
understanding. It will inform strategic priorities for our forward response to food crime.
2.1.2 This is a joint assessment produced by the Scottish Food Crime and Incidents Unit
(SFCIU) within Food Standards Scotland (FSS), and the Food Standards Agency’s
National Food Crime Unit (NFCU), collectively referred to in this product as the Units.
2.1.3
criminality within food supply chains”. This also encompasses drink and animal feed.
2.1.4 This iteration of the FCSA continues to build upon our understanding of the nature
2014-15. This assessment covers a principal reporting period from 1 September

2018 to 31 August 2019, although reporting from outside this period is used where it
provides additional context.
2.1.5 The purpose of this document is to:
(1) highlight themes and trends in food crime;
(2) demonstrate changes in our understanding of the UK food crime threat;
(3) enable the prioritisation of the most harmful issues within the UK’s response to
food crime;
(4)
2.1.6 The 2020 assessment will not form an exhaustive review of the response to food
crime by regulators and law enforcement. This is an intelligence assessment,
designed to provide a high-level understanding of the threat from food crime to the
UK and its interests.
2.1.7 This assessment seeks to understand how particular techniques are applied across
supply chain, as opposed to within silos of product types, or sectors of the food and
drink economy.
2.1.8 The current environmental factors that impact on food crime are also assessed,
and the relationship between food crime and serious organised crime is considered.
are observed within food crime, across a range of commodities. Finally, the future of
food crime is evaluated.
10
2.2 Information sources and limitations

2.2.1
an increasingly enhanced understanding of food crime and its complexities. This has
enabled the development of a detailed and wide-ranging picture of the threat landscape.
2.2.2 The assessment draws upon information and intelligence routinely received from a range
of sources. These include local authorities, regulatory and law enforcement bodies,
those working within the food and drink sectors, and information provided to the Units by
members of the public. This includes the incorporation of intelligence supplied discreetly
Units.
2.2.3 To supplement our baseline data, intelligence requirements were shared with key
partners. Debriefs were held with a range of subject matter experts.
2.2.4 It is important to highlight that there has been an increase in returns from local authorities
tackling food crime.

2.2.5 Intelligence collection by the Units has been augmented by FSA colleagues in Wales and
Northern Ireland who have provided relevant insight on the food systems in these nations.
2.2.6 This assessment also draws upon datasets such as the UK Food Surveillance System
(UKFSS) and Scottish Food Sampling Database (SFSD), other sampling results, and
the data made available to the Units by the Food Industry Intelligence Network (FIIN).
Collectively these provide a richer (if still partial) picture of what we can learn from
sampling and authenticity checks performed by public and private sector alike.
2.2.7 Whilst the UKFSS dataset provides the most comprehensive summary of local authority
sampling in England, Wales and Northern Ireland available, it is important to note that not
in these three nations.

2.2.8 Better deployment of horizon scanning tools, including bespoke tools developed by the
FSA Strategic Surveillance team and the FSS Horizon Scanning Group, has increased
the quality of our rolling intelligence collection. This has been alongside increased use of
consumer insight reporting, and dedicated engagement with industry and the academic
community.
Operation OPSON
One annual feature of the Units’ proactive work is their participation (with the
invaluable support of partners) in Operation OPSON. This is an internationally
co-ordinated focus on substandard or counterfeit food and drink, led jointly by
Interpol and Europol.
In recent years, the annual activity has involved intelligence led collaboration
and co-ordination, working across the UK and with European partners, to target
agreed commodities due to the threats posed to consumers and businesses.
11
3. Current Environment
3.1.1 Food crime is an issue which cuts across food authenticity and safety. As is the case
3.1.2
assessment of the food crime threat, in terms of how they may create opportunities
Regulatory Framework
3.1.3 The regulatory and enforcement landscape for food is complex and interwoven.
responsibility depending on the nature of a given issue. Front line regulatory controls,
face competing priorities and resourcing constraints.

3.1.4 Most of the issues raised in response to our local authority intelligence requirement
relate to areas which consume a large amount of time and resources and can prevent
The key issues include online sales of food products, food businesses operating
from domestic kitchens or storage units without registration, and an increase in
unregistered businesses.
3.1.5
and standards published in June 2019.19
3.1.6 A key concern from local authority feedback was the increased diversity of food
businesses and products noted by some local authorities, and the challenges that this
presents. Concerns in this area include an increasing variety in food supplements and
communities, and concerns around the legality of imported food products sold in
such businesses.
3.1.7 The increasing resourcing issues experienced by many local authorities were raised
both in their responses and in the NAO report. These have led to a reduction both
gathered at local level, impairing the overall UK intelligence picture with regards to
non-compliance and food crime.
19
Ensuring food safety and standards
12
3.2.8 The combination of tightened resources, and an increasing number of complex issues
to deal with, may make it harder for authorities to prioritise identifying and tackling
food crime. This is particularly the case where fraud investigations are concerned,
not be feasible, or represent the best outlet for public funds in a local context.
3.1.9 Elsewhere within the investigatory landscape, the challenges for UK police forces
20
which makes the requirement
more critical.
Consumer Trends and Attitudes

3.1.10
3.1.11 In 2018-19, there were a reported 6,456 hospital admissions due to a food allergy
in England alone,21 with six deaths recorded in England and Wales in 2018.22 This
represents a 9% increase in hospital admissions compared to 2017-18. It is estimated
23
In November 2019, 12% of
respondents surveyed for the FSA's Public Attitudes Tracker reported having a food
allergy or intolerance.
3.1.12 From a food crime perspective, this area requires vigilance rather than currently
within both FSA and FSS which is looking to understand the root cause of food
allergy incidents in greater detail, as well as working with some local authorities to
understand the prevalence of food allergy issues in their areas.
3.1.13 A key food trend of 2019 was the continued rise of products containing cannabidiol
of CBD products can fall to one of several government bodies, depending on both the
product, and the presence of tetrahydrocannabinol (THC).24
3.1.14
of a move to compliance, in February 2020 the FSA set a deadline of the end of March
2021 for validated applications. Only products linked to a validated application can
remain on the market after this deadline, with no new products allowed without
20
Fraud victims 'failed' as criminals 'operate with impunity', BBC News, January 2020
21
, for 2013-14 to 2018-2019, NHS
22
Deaths registered in England and Wales 2018
23
Food Allergy and Intolerance Programme, Food Standards Agency (FSA), March 2017
24
13
prior authorisation. Precautionary health advice around CBD consumption was also
issued25.
3.1.15 It is a realistic possibility that this market expansion has led to misrepresentation
or
that contain THC and are therefore highly likely to contravene the Misuse of Drugs
Act 1971. It is a realistic possibility that the period until the removal of unvalidated
products from the market
3.1.16 In addition to the increase in CBD products, there has also been an increase in the
variety of food supplement and ‘health’ products on the market. A number of these
new products contain unauthorised novel foods, such as selective androgen receptor
modulators (SARMs) and dimethylhexanamine (DMHA), or unapproved food additives.
products in this area.

3.1.17 Such products can present challenges to regulators due to the complexity of the legal
status of, and enforcement framework around, the ingredients (within or between
novel foods legislation, pharmaceutical regulation and rules around permitted health
claims). It can be hard to demonstrate the presence of deception, but it is likely that
3.1.18
consumption, both in terms of the type of food and how it is prepared.
3.1.19
A rise is noted in reports of food crime and suspicious activity in the red meat and
poultry sectors in the run up to some major festivals in the UK, during which a
form part of the observance or tradition. Demand linked to these events may be met
partially or more comprehensively by the entry of illicit product onto the market.
3.1.20 The impact of other religious and cultural festivals on food crime reporting is not yet
fully understood, but further work is ongoing to assess this area. This ties in with
broader intelligence gaps around practices linked to foods primarily consumed within
25
Food Standards Agency sets deadline for the CBD industry and provides safety advice to
consumers, Food Standards Agency (FSA), February 2020
14
3.1.21 Whilst we have developed an awareness of some aspects of the production and sale
of smokies26 and bushmeat,27 less is known about the true scale of the market for
3.1.22 Some of these products are imported illegally through the postal system, in personal
baggage, or undeclared within large, mixed consignments. This can include products
3.1.23
3.1.24
personal imports.
3.1.25
constitute a food crime. We are working partners at points of entry to better

understand this issue and the potential risk.
26
The meat of sheep or goats, which are slaughtered then burnt, without being properly
butchered.
27
15
African Swine Fever

The dangers of illegally imported food products have been highlighted as
African Swine Fever (ASF) has spread through global pig populations. Whilst the
likelihood of infected product entering the animal feed chain in the UK is low, the
potential impact of the disease – agriculturally and economically – makes ASF a
key issue to governments worldwide.
Testing of illegally imported food products seized at points of entry in Northern
products.28
In October 2019, a joint Defra and UK Border Force operation targeting illegal
imports of meat products in passenger baggage at Heathrow Airport seized
460kg of meat, including 145kg of pork product, over a six-day period.29 It is
not known whether any of this product was infected with ASF but the volume
highlights personal baggage as a vector for importation.
In December 2019, several tonnes of Chinese meat, including pork, concealed in a
EU via Rotterdam).30
Chinese dumplings seized in the Philippines in early 2020 were found to contain
ASF DNA, suggesting either that waste product from culled animals has been
infected are being used in food production.31
3.1.26
poorer households. Such households may spend a greater proportion of their income
on food, and focus not on food authenticity, but on feeding themselves and their
household.
3.1.27 32
This
apparent increase in the number of households requiring assistance may provide an
opportunity for fraudsters to exploit by marketing waste, or poor quality ingredients,
as cheap but viable food.
28
DAERA reminds holidaymakers - don't risk it, leave it behind, Department of Agriculture,
29
, Gov.UK, October 2019
30
Italian authorities seize nearly 10 tons of infected Chinese pork, Deutsche Welle (DW),
January 2020
31
Seized pork dumplings from China test positive for African swine fever, CNN, January 2020
32
Independent Food Bank Emergency Food Parcel Distribution in the UK, Independent Food
Aid Network (IFAN), 2020
16
3.1.28 Fraud can also impact upon those who support needier parts of our societies.
supplied to a number of charities, was adulterated with substances including soya,

33
3.1.29
consumers pursuing health-conscious, environmentally aware or ethical lifestyles.
3.1.30 This has seen a rise in the number of UK consumers choosing animal-free, locally
sourced or ethically produced food and drink. Such products can be vulnerable to food
consumers are willing to pay a marked-up price based on a level of trust placed in
food should make sure it is safe, honest and ethically approved, and noted upward
trends in consumer concern about animal welfare and pesticide use. Nearly three
quarters of consumers declared themselves to be conscious of the wider impact of
the food choices they make.34
3.1.31 Many products developed to target this increasing market contain expensive or
unfamiliar ingredients which make them vulnerable to the commonly observed food
crime techniques of substitution and adulteration. This risk may increase when raw
worldwide.
Impact of Technology
3.1.32 A continuing trend is the willingness of UK consumers to buy food online, and the
increased ease of purchase and availability of food sold through online channels.
In 2019, 32% of internet users in the UK purchased food online, compared to 19%
across the EU.35
3.1.33 Online marketplaces have made the internet sale of food easier, enabling vendors
globally to trade without having to set up a physical shopfront. However they present
challenges to current methodologies for food controls and enforcement. It is often
and thereby to identify who is responsible for administering controls.
33
Fat, skin, soy... everything except meat in these steaks delivered to associations, Courrier
picard, June 2019
34
FSA Public Attitudes Tracker, Wave 19 Report, Food Standards Agency (FSA), February 2020
35
Internet purchases by individuals, Eurostat, 2019
17
Figure 1: Intersections between food and crime and e-commerce
3.1.34 The rise of online aggregator platforms has meant more ready-to-eat food being
delivered directly to consumers from informal or non-restaurant-based kitchens.
Throughout 2019, cases have been reported of food sold through these platforms
coming from an unregistered food business operator (FBO) or being mispresented as
being from a higher quality establishment. This highlights the potential to register a
food business on a platform without the proper scrutiny applied.
3.1.35 Social media is also increasingly used to sell food – used in a similar manner to
online marketplaces, but with less auditability or traceability. Social media enables
for speciality goods. Food produced in residential kitchens is sold through these
platforms. It is hard for consumers to reassure themselves that products are safe,
authentic and hygienically prepared; this is an area which has been subject to media
scrutiny. The FSA has emphasised the responsibilities of social media companies
towards consumers making food purchases via their platforms.36
3.1.36 It is also possible to buy food on the dark web37 – primarily dangerous or borderline
food supplements and other illicit food commodities. Operational activity has
3.1.37 Online routes for purchase also exist for materials such as antibiotics and animal
microchips – articles which may be used in illicit practices such as re-identifying
livestock or the illicit administration of antibiotics to poultry.
3.1.38 The challenges presented by the growth in online sales of food are recognised by
the Units. Work led by both the FSA and FSS, in co-ordination with other government
partners, is key to tackling this issue, and the Units will continue to support this work,
particularly where there are opportunities to reduce the threat and impact of food crime.
36
Facebook: Home food businesses concern FSA watchdog, BBC News, February 2020
37
The dark web is a part of the internet which sits separately to that accessible via
conventional browsing activity. It requires specialist (but broadly available) software,
18
4. Food Crime and Serious
Organised Crime
4.1 Overview
4.1.1
impact only on the safety of food), breaches of food standards regulations not
resulting from fraud, or serious organised criminals making use of food or food
Figure 2:
4.1.2 Although there are exceptions, most food crime is carried out by groups who have
backgrounds in the food industry. These food crime groups will often exploit a wholly
or partly legitimate food business as a vehicle to sell illicit, unsafe, or inauthentic food
products.
4.1.3
Organised Crime Groups (OCGs) being involved in food crime taking place in the UK, or
migrating their activity into this sector.
4.1.4 This is not to say that food crimes are not frequently organised, serious in scale and
harm, and linked to the interaction of several individuals or entities, or that those
responsible should not be categorised as OCGs. Furthermore, this does not indicate
that criminally active food businesses do not, on occasion, extend their activity into
other areas.
19
4.1.5 We assess it as unlikely that many food criminals make a proactive choice to switch
from acting as a compliant food business operator, to being a fully illegitimate one.
It is more plausible that a decline in the probity of a business’s practices takes place
over time, with some FBOs perhaps only temporarily engaging in criminality due to
4.1.6 It is certainly the case that some FBOs are engaged in food crime, but that this only
forms part of their business, with at least some of their activity remaining legitimate.
4.2 Exploitation of the food system

4.2.1 We assess that there are three primary ways in which traditional OCGs make use
of food to conduct criminal activity; money laundering, smuggling, and as an
environment for labour exploitation.
4.2.2 Crime groups are known to trade in food commodities to launder money.38 It is unlikely
the food industry will always be exploited for money laundering as it is, in places, cash
based, whilst also at points featuring long, international supply chains.
4.2.3
Exact methodologies have been varied, perhaps to avoid detection.

4.2.4 The use of food as a cover for smuggling has
been noted frequently in 2019 and more recently,
with a variety of food types being employed.39 It is
assessed as highly unlikely that this meat, or any
food used as part of a concealment, entered the
food chain once the drugs had been retrieved.
leading to an increased risk of detection and the

endangerment of the substantial criminal proceeds
loads are abandoned (for example in a cold store), or in better condition, there is a
greater possibility that the material will enter the food chain.
4.2.5
38
Trade based money laundering is the process using multiple, complex, international trades to
understand the original origin of the proceeds of crime. The National Crime Agency’s National
Strategic Assessment of Serious and Organised Crime 2020 judged that trade based money
laundering remains a key threat.
39
Fowl play: four jailed for importing hundreds of kilos of cocaine in frozen chicken, National
Crime Agency (NCA), May 2020
20
4.2.6 The Gangmasters & Labour Abuse Authority have reported an increase in reports of
oysters, mussels and winkles, with reporting suggesting potential links between
gangmasters and Asian restaurants.40 Partnership working, including joint days of
4.3 Food criminals and serious organised criminals

4.3.1 It remains our assessment that in-depth knowledge of, and access to, established and
at least partially legitimate production, storage, distribution facilities or marketplaces
is necessary to conduct most food crimes. It has been our hypothesis that this is
more important than knowledge of criminal techniques in more general terms, or
broader experience of connections within organised crime fraternities; this inference
remains largely sound.
4.3.2 For some parts of the industry, however, barriers to entry into the food sector may be
less substantial. Examples of this include products which are less perishable or can be
easily distributed into informal or low-scale retail chains, such as alcohol. Avenues for
online sales (whether overtly or via the dark web) also open opportunities for criminal
order supply of food supplements of varying degrees of legality and safety.

4.3.3 The most attractive food target for more broadly active criminals who are not already
rooted in the food industry may indeed be alcohol; especially spirits. If a crime group
can distil or buy a product such as vodka at minimal cost, avoid paying the proper
taxes and sell the product at the going market rate or a competitive price slightly
duty evasion are also considered).

4.3.4 It is almost certain that illicit spirits are being sold through independent retailers to
customers primarily concerned with the cost of the product, rather than authenticity.
Vodka is a regular subject of intelligence and can be subject to concern due to safety
issues if improperly produced, for example through the incorporation of industrial
alcohols.
4.3.5 As with the food and drink sector, criminality is moving increasingly online. According
to the National Crime Agency, there has been ongoing growth in criminal trade on
dark web platforms, although the pace has slowed over the past year.41
4.3.6 Whilst action can readily be taken against websites selling inauthentic or dangerous
substances on the surface internet, dangerous non-foods are also observed
commodities.
40
, Gangmasters and Labour Abuse Authority (GLAA), 2019
41
National Strategic Assessment of Serious and Organised Crime, National Crime Agency
(NCA), 2019
21
4.3.7 Though dangerous non-foods – unsafe products which are sold in a manner explicitly
or implicitly indicating suitability for consumption – have led to the deaths of a number
of UK consumers, they are not clearly within the remit or priorities of law enforcement
partners whose specialist capabilities extend to those operating on the dark web.
4.3.8 There is a realistic possibility that the growth of the dark web will lead to more food
items being sold in online environments where control bodies have limited ability to
4.3.9 It is assessed that the domestic food sector is far less exposed to serious organised
are known to play a role in the Italian food industry and have sought to exploit this
worldwide demand for avocadoes has seen rising interest in food production by
crime cartels in Mexico. The impact in the UK is more likely to be observed in product
availability or authenticity than through similar groups becoming entrenched within
the domestic sector.
4.3.10 It is noted that the UK border within the island of Ireland is an existing locus for
commodity-based activity involving organised criminals, including food. The Irish
land and sea borders will be an area of vigilance as the UK transitions into a future
economic relationship with the European Union and into a period where Northern
22
5. Threat Assessment
5.1 Overview
5.1.1
crime of document fraud, shown below:
Figure 3: The seven types of food crime
5.1.2 Using this framework, we look to understand and assess risk posed by food crime.
5.1.3
are the crime techniques which are present across the broadest selection of product
types and consequently feature most frequently within our intelligence, particularly
misrepresentation.
5.1.4 Theft and associated activities usually sit towards the beginning of the food
crime supply chain – and can also include waste diversion where a product
has been entrusted to a company for purposes of disposal but is then sold on.
They are a common precursor to unlawful processing. As well as leading to the
misrepresentation of quality, waste diversion can also drive unauthorised altering
5.1.5 Substitution and adulteration,
while the product is in the control of an intermediate owner or processor, or in the

retail or catering establishment which will ultimately deliver the product to the
consumer.
23
5.1.6 Misrepresentation
food business operator, enabling a substandard product to be passed onto an
unsuspecting party. This, ultimately, is what cloaks the invisible shortcomings of a
product from the casual eye of a consumer. As nearly all food crime will require an
element of misrepresentation it is unsurprising this is the aspect of food crime on
which the Units hold the most intelligence.
5.1.7
from food crime. A knowing consumer may rationalise buying illicit product if it, or its
result of the price.
Figure 4: Process diagram of food crime types
5.1.8
applications of the techniques discussed, as well as suggesting where the risk within
each area is assessed to be the most profound.
5.1.9 This chapter is not an exhaustive list of all matters currently known to the Units.
landscape.
24
5.1.10 While food crime techniques are useful for identifying and codifying activity, we note it
is rare that a food crime involves just one of the techniques.
5.2 Theft
5.2.1 Acquisitive crime within the food industry is focused largely on the theft of protein
5.2.2 Illicitly obtained food, including that produced from stolen animals, may present
processed or transported in line with food safety and hygiene requirements, or
period before entering the food chain (for example livestock treated with certain
veterinary medicines).
5.2.3
the product, it is almost certain that other food crime methodologies, principally
unlawful processing and document fraud, are employed alongside the theft. This may
legitimate supply chains.
5.2.4 Livestock theft

increasing degree of organisation in their practices. The rural insurer, NFU Mutual,
estimates that between 2017 and 2019, there was a 20% uplift in acquisitive crimes
within the UK livestock sector, with an estimated cost of £3 million in 2019.42
5.2.5 It is likely that there is an underreporting of livestock theft to the relevant authorities.
It is possible that cattle reported as ‘missing’ are not always recorded as a crime and
42
A challenging time for the countryside, Rural Crime Report 2020, NFU Mutual, 2020
25
5.2.6 The onward sale or processing of stolen livestock into the food chain, and whether
this is done through legitimate, or clandestine routes, is not fully understood. Recently
Case Study: Operation STOCK

Between February 2019 and August 2019, a multi-agency taskforce, led
by Northamptonshire Police, investigated the slaughter and butchery
of over 150 lambs and sheep, along with the theft of a further 250+
sheep and lambs in the same region.43 In October 2019, three men were
charged in connection with this activity and appeared in court to face
charges of conspiracy to steal. All later pleaded guilty and received
custodial sentences in March 2020.
Whilst the theft of livestock is a police matter, the butchery and
subsequent sale of meat into the food chain is not, and presents food
safety concerns due to the way the meat has been processed and
handled. Additional concerns were raised around potential veterinary
medicine residues in meat from some of the animals stolen, which may
pose a public health risk if consumed.
5.2.7 We assess that poaching
5.2.8 The in coastal regions across the UK continues to

feature prominently in reporting, with cockles, Manila clams, razor clams, and oysters
reported as the most commonly targeted species.
5.2.9
unlawful harvesting taking place in the South West, South East, and North West of
England, North East Wales, and around the Scottish and Northern Irish coasts.
5.2.10 Methods of harvest reported include both hand gathering, and harvesting from
boats, including the use of yield maximising methodologies such as dredging or
44
It is a realistic possibility that some of this activity is linked to
labour abuse by organised crime groups. Varying levels of scale and organisation are
reported.
5.2.11
consumer health, but our regulatory partners are active in detecting and disrupting
this activity.
43
Operation Stock, Northamptonshire Police, 2020
44
launched, in respect of the harvesting of razor clams.
26
5.2.12 The Units’ understanding of the variety of avenues through which illegally harvested
5.2.13 There are three common routes to market: sale to commercial processors; direct
communities.
5.2.14 It is likely that onward transfer routes may vary depending on the cultural heritage
of those co-ordinating the harvesting activity, and a realistic possibility that the area
where the activity is taking place (and its local demography) has some bearing on this.
5.2.15 Co-ordinated multi-agency activity, supported by the NFCU, at a number of locations
around the English and Welsh coastlines, and similar activity in Scotland by SFCIU has
5.2.16
dramatically changing the properties of the seabed, as well as depleting targeted
population stocks, which can be slow to recover. It is a realistic possibility that
harvesting to other coastal regions.

5.2.17 Whilst it is likely that poaching of wild game continues to be an issue, limited
reporting has been received on this matter.
5.2.18 Reporting received focuses mainly on the poaching of deer. The most likely route for
poached venison to enter the food chain is assessed to be via direct door-to-door
sales to businesses such as restaurants, pubs and butchers. It is unknown whether
sales of illegally poached venison are always local to the poaching location, or
5.2.19 A current intelligence gap is the extent to which the trade of poached game is enabled
by any vulnerability to fraud perpetrated through the misuse, or deliberate false
completion, of the required documents which verify the carcass condition and kill date.
5.2.20 In more direct acts of theft, food products are often targeted for theft during
distribution, with at least £5.5m worth of food stolen from vehicles in the UK between
January and September 2019.45 In 2019, alcohol was reported as the food product most
frequently targeted in theft from distribution vehicles. It is highly likely that criminals
target alcohol as it is a high value and non-perishable commodity, which does not
5.2.21 Identity theft is a continued issue within food crime. The fraudulent use of a
orders with overseas suppliers, is commonly referred to as European Distribution

Fraud (EDF). Legitimate food businesses are approached to supply quantities of
product, believing that the genuine company placed the order. The goods are diverted
while in transit, and never paid for.
45
Transportation Assets Protection Authority (TAPA)
27
5.2.22 It is almost certain that food stolen through EDF is placed into the food chain by
employing other food crime techniques, including misrepresentation and document
fraud.
5.2.23 It is also a realistic possibility that stolen food is not handled, stored or transported
appropriately, and therefore may pose a food safety risk. This risk will vary
through which it is distributed.

5.2.24 to equip the law enforcement
46
community with a full understanding of the prevalence of this issue. The onward
movement of product into the food chain constitutes a food crime due to the absence
of proper traceability.
5.2.25
or nature of EDF in the UK is currently unknown. It has not been possible to obtain
a thorough dataset regarding the scale and extent of this problem but we are
developing partnerships to enhance this.
5.2.26
usually impersonate a well-known UK supplier or manufacture to lend legitimacy to

their order, and may exploit overseas suppliers who, as non-native English speakers,
5.2.27 Equipping food businesses with the capacity to recognise and prevent attempted frauds
of this nature is an important area of focus for food crime prevention activity.
46
Action Fraud is the UK’s national reporting centre for fraud and cybercrime. The service is run
28
5.3 Unlawful Processing
5.3.1 In the context of food crime, unlawful processing can include the use of unapproved
techniques or processes, or the production of food outside of an approved
establishment.
5.3.2
5.3.3 Incidences of unlawful processing have been observed within the red meat, poultry,
as misrepresentation of quality or date, and document fraud, will be necessary to

place the food onto the market unless being sold to those who are fully aware of the
true origin of the food and accept this, owing perhaps to it being very keenly priced.
5.3.4 Whilst it is almost certain that the red meat and poultry sectors share common
vulnerabilities in aspects of food crime such as misrepresentation of date and origin,
limited reporting has been received in relation to unlawful processing within the
poultry sector.
5.3.5
as slaughter of poultry at anything other than industrial scale is commercially
challenging.
5.3.6 Intelligence around unlawful processing falls largely within the following categories:
Illegal slaughter: The slaughter of animals in an unapproved slaughterhouse or by an
unapproved slaughterman.
Unapproved establishment: Use of premises which are not registered or approved by
Unapproved activity: Carrying out an activity within approved premises, for which the
5.3.7 Where unlawful processing occurs within approved premises, it is likely to be found in
conjunction with other regulatory non-compliances. This has been observed in both
small and large-scale establishments.
29
Approved Premises
European Commission Regulation (EC) 853/2004 and (EC) 852/2004 details the
requirements an establishment needs to achieve for approval. The process of
approval is contained in Regulation (EU) 2017/625.
process described in (EU) 2017/625, which are intended to ascertain a Food

Business Operator’s compliance with the requirements of Regulations (EC)
852/2004, 853/2004 and other aspects of food law, including animal welfare and
animal by-products.
5.3.8 Whilst the majority of unlawful processing is carried out by entities who have never
sought to comply with the necessary legal requirements, there are some instances
where FBOs who previously operated legally begin unlawful processing (when
approval to operate is removed from the business, but they continue to trade).
food chain owing to the absence of proper controls.

5.3.9
the risks posed by non-compliant meat establishments. Continued operation may
here.
5.3.10 Within the reporting period, vulnerabilities within the current approval mechanisms
for meat establishments have been exploited by those attempting to evade scrutiny,
through the creation of phoenix companies. This allows FBOs whose approval has
been revoked to set up a new business and apply for approval under a new identity or
5.3.11 In parts of the UK it is almost certain that a number of approved establishments are
illicitly slaughtering out of hours at times of peak consumer demand, particularly
around major religious and cultural festivals. It should be noted that this is not broadly
noted in intelligence relating to Scottish establishments, and also that many abattoirs
do legally operate outside of usual hours during these periods, with the necessary
5.3.12 Illegal slaughter has been a recurring theme in reporting received by the Units, most
risk to the consumer.

5.3.13 A similarly heightened level of risk is observed in relation to the illegal processing of
quantities on UK coastlines, close to known harvesting areas, in unhygienic

conditions.
30
5.3.14 It is likely that this activity is driven by the greater ease of transport of shucked
5.3.15
of operating outside of approval, or by increasing throughput and sales. In some
instances it may be to meet consumer need when their preferred product cannot be
produced legally in the UK.
5.3.16 ‘Smokies’
methods of production and transportation.

5.3.17 It is highly likely that their production is facilitated through the theft and illegal
slaughter of sheep.
5.3.18 In 2017, the intelligence picture suggested that the production of smokies was
concentrated in Wales, with carcasses transported to London for sale. Intelligence
received during this reporting period suggests that production of smokies has now
with no single nexus of production. This practice has also come to the attention of
Irish food safety authorities.
5.3.19
has taken place, and there is no intelligence to suggest a fundamental change in
the communities buying smokies. Limited intelligence indicates farmers knowingly
supplying animals for the production of smokies, although this does not appear to be
widespread.
Case study: Smokies prosecutions

In September 2019, the Proceeds of Crime Act (POCA) hearing of a Welsh
‘smokie’ producer, heard that he had made in excess of £100,000 from
the production and sale of ‘smokies’. He was ordered to pay £30,000
towards the costs of his prosecution – this is in addition to an eight-
month prison sentence suspended for two years given in 2017.
Though it is possible that the 2017 arrest and prosecution of this individual
from Wales to areas of the UK, alternative production established. A group

of three men who were discovered producing 'smokies' in Pembrokeshire
in January 2019 received suspended custodial sentences in September
2020.
5.3.20 Within the UK egg sector, reporting has detailed unlawful processing of eggs, namely
sold as Class A, and must be broken and pasteurised. The scale of this practice is not
fully understood. Egg marketing inspection is a responsibility of the Animal and Plant
Health Agency (APHA).
31
5.3.21 Welfare concerns such as the overstocking of poultry sheds have also been noted
within activities preceding the misuse of free range labelling.
5.3.22 Reporting in relation to unlawful processing within the animal feed sector has focused
on the production of raw pet food in unregistered or unapproved establishments.
It is likely that pet food produced in unapproved establishments is not subjected to
appropriate temperature and hygiene controls, posing a health risk to both pets and
their owners.
5.4 Waste Diversion
5.4.1 Waste diversion is the redirection of waste product considered high risk for human
that have failed relevant quality tests or standards.

5.4.2 The level of reporting in this area remains limited, although it is likely to be much
higher than current reporting suggests. Any activity taking place is likely to pose a
serious risk to either public or animal health due to the nature of the products being
repurposed.
5.4.3
permitted purposes and approved routes for disposal. It remains lucrative, however,
to misdirect waste back into the food or feed chain, particularly as many businesses
would otherwise have to pay to correctly dispose of this material.
5.4.4 In the most serious instances, improper use of animal by-products could result in the
spread of transmissible animal diseases such as Bovine Spongiform Encephalopathy
(BSE). Catering waste containing meat, if diverted into animal feed, could spread
diseases such as African Swine Fever (ASF) and Foot and Mouth Disease.
Animal By-Products (ABP)

ABP consists of animal carcasses, parts of animals or animal derived products
categories of risk from 3 to 1, which determine the level of processing required for
the product.
Most category 3 ABP can be used for either raw or processed pet food, whilst
categories 1 and 2 are classed high risk, for disposal via an approved ABP
processing facility.
32
5.4.5
to dispose of but means there is a realistic possibility that product which should be
incinerated could be misdirected into animal feed. This is a potential animal health
contain elements of TSE47 diseases.

5.4.6 Illegal slaughter and unlawful processing also pose waste diversion risks as there is
suggest that this is a particular issue with poached game.

5.4.7
quality product and may be paying a price consistent with the genuine product. Such
activity can result in extensive reputational and brand damage to the business whose
products have been diverted, even if any safety risk is minimal or absent.
5.5 Adulteration and Substitution
5.5.1 Adulteration and substitution can be very similar. Regardless of the ambiguity
between the two crime types, they can both represent a clear, intentional act of fraud,
and are addressed as such from a food crime perspective.
5.5.2 We continue to observe three principal activities in this area. Instances of their
application vary in volume, severity and harm.
5.5.3 Such techniques elevate risk by introducing food into the food chain, which in some
instances can, cause physical, or emotional harm, through the introduction of
undeclared allergens, or meat species which may compromise religious or ethical
observances. The customer is misled into buying food which is not what the labelling
suggests it is.
47
Transmissible Spongiform Encephalopathies (TSE) are a group of degenerative diseases
Encephalopathy (BSE) is in this group.
33
Figure 5: Adulteration and Substitution
Quantitative Adulteration
5.5.4 Commodities which are known to have been impacted by quantitative adulteration
are produced, and in some cases packed, overseas. However this does not mean that
there is no impact on UK consumers and on businesses who use these ingredients in
their own production.
5.5.5 Both substitution and adulteration are commonly observed crime techniques with
regards to red meat products, particularly processed and composite products.
5.5.6 Whilst meat products subject to substitution or adulteration tend not to pose any
elevated safety risk, they may compromise the religious observances of some
consumers, particularly where pork or beef is used as the replacement meat.
5.5.7 Available industry data makes clear the extent of commercial vigilance in this area
of authenticity tests on red meat products showed signs of possible adulteration with
other species.48
5.5.8 Results from local authority and centrally funded sampling around red meat and
meat products identify more non-compliances, but this testing activity will have been
targeted, focussing on testing foods which have traditionally been non-compliant, or
businesses (or categories of business) with histories of non-compliance.
48
7 out of 30,437 samples tested for speciation within this dataset.
34
5.5.9 Lamb features as a commonly replaced species but is also regularly sampled – likely
due in both cases to the comparatively high retail price of the meat. Beef is a regularly
indicated the undeclared presence of horse meat.

5.5.10
kebabs and sausages. The appearance and composition of such products make it
challenging for consumers to identify fraud. It is almost certain this vulnerability will
continue to be exploited in the UK although this is very much a known area of risk for
regulatory partners.
5.5.11
and connective tissues common adulterants in these products.
Case Study: Horse Meat

In April 2019, four men were found guilty of falsely labelling horsemeat
as beef. These convictions stem from perhaps the most famous case of
red meat adulteration, the 2013 European-wide ‘horse meat scandal’.
The actions of this criminal group, and others, resulted in millions of
beef dishes being pulled from supermarket shelves across the UK, after
it was discovered that they contained horsemeat despite being labelled
as beef. The horsemeat was largely sourced from Romania and traded
across the EU.
The former director of the meat processing company was sentenced to
industry for two years.

Since 2013, four other individuals have been convicted of criminal
activity related to the scandal, by courts in the UK and Spain.
5.5.12 olive oil include the addition of other vegetable,

nut or seed oils, as well as adding substances such as chlorophyll, or beta-carotene
to low quality oil, to obtain a colour and consistency similar to extra-virgin olive
oil. Authenticity issues relating to olive oil are a recurrent theme within food crime
coverage globally and this will be a matter around which major industry partners are
aware and vigilant.
5.5.13 There are agreed levels of annual sampling to monitor and enforce olive oil
compliance. Sampling conducted by the Rural Payments Agency between January
compliance against the EU composition and labelling regulations for olive oil.49 These
failures are not a conclusive indicator of fraudulent activity but this is one potential
cause of the compliance failures, alongside unintentional non-compliances and poor
storage or transportation.
49
Regulation (EEC) 2568/91; Regulation (EU) 29/2012; Regulation (EU) 1308/2013.
35
5.5.14 Very little intelligence has been noted which suggests that non-compliant olive oil
on the UK market has been produced fraudulently. However, in September 2018,
an investigation carried out by the Spanish Nature Protection Service (SEPRONA)
50
Whilst there is no indication that the UK importer
was complicit in this activity, this case shows that UK businesses, and therefore
consumers are not immune to food crime committed elsewhere within the global
market.
5.5.15 It is highly likely that any adulteration of olive oil, occurs during the production
stage, and a realistic possibility that those distributing the product later in the chain,
particularly within legitimate supply routes, are unaware of the true nature of the
product they are handling.
5.5.16 It is also a realistic possibility that continued pressures on European olive production,
including the spread of the plant disease Xylella fastidiosa, will lead to an increase in
adulterated olive oil production by those wishing to exploit price increases and supply
the overall level of fraudulent product on the market increases the potential exposure
of UK consumers.
Case Study – Operation ORO GIALLO

In May 2019, a joint operation by Europol, the Italian NAS Carabinieri, and
the Tribunal of Darmstadt in Germany, led to 20 arrests. 150,000 litres of
fraudulent olive oil was seized.51
chlorophyll, beta-carotene and soya oil to give it the appearance of
German market, largely to restaurant owners. The group is estimated
5.5.17 During the reporting period, we have observed an increase in reporting related to the
adulteration of vodka with industrial chemicals, including methanol and isopropyl
alcohol. Reporting has also highlighted instances where branded vodka has been
substituted with a lower priced vodka and marketed as the legitimate brand.
5.5.18 It is currently unknown whether this increase in reporting is attributed to more
adulterated product being in circulation, or heightened awareness and detection.
50
, ABC News,
October 2018
51
150,000 litres of fake extra vigin olive oil seized from 'well-oiled' gang, Europol, May 2019
36
5.5.19
naturally, at a low level, in most alcoholic beverages, however illicit drinks
manufactured from industrial chemicals, will contain much higher levels of methanol.
These beverages can cause blindness, and even death, depending on their exact
methanol content.52
5.5.20
the harm from this issue is far more apparent overseas. Spates of fatalities from
adulterated alcohol consumption have been reported in Indonesia, the Dominican
Republic and Malaysia.
5.5.21 Within a modest dataset referencing sampled vodka products, a very small number
revealed the presence of industrial alcohols. This demonstrates a continued
requirement for vigilance but these results from targeted activity should not be taken
as representative of broader levels of non-compliance. Other samples from the
53
5.5.22 It is assessed as highly likely that vodka is more susceptible to adulteration than
other spirits, due to the relative ease with which illicit clear spirit can be made using
industrial chemicals, compared to other spirit drinks.
5.5.23
to a change in the supply and demand dynamics of the alcohol market. It is not yet
possible to comment on whether this has had any impact on the supply of counterfeit
alcohol.
5.5.24 Honey is a product which is often recognised in food crime commentary as being
vulnerable to fraud. A vast array of honey products are available to the consumer,
from competitively-priced blended honeys to those which attract a premium price
Zealand).
5.5.25
produced and sold around the world, analysis can be challenging. A number of
of evidence approach for determining the addition of sugars in honey, including

traceability checks, when assessing honey authenticity.
5.5.26 The volume of blended product required for the honey market and the availability of
plausible adulterants such as sugar syrup, in addition to the price premium associated
with higher value honey products, mean that it is a realistic possibility that adulterated
or misrepresented honey is present within world honey supplies. Its presence within
products available to UK consumers cannot be completely discounted.
52
, Paine and Davan, 2001
53
Under the Spirit Drinks Regulations 2008, vodka must have a minimum alcohol content of
37.5%.
37
5.5.27 Sampling carried out in 2018 and 2019 in countries including Canada54, Australia55 and
the UK, by competent authorities and private entities, has explored the authenticity
of some honey products, with possible concerns relating to adulteration with sugar
syrup, declared quality, and declared origin. These themes are also apparent in UK
are small and following investigation, the majority of anomalies were not assessed
to indicate an authenticity issue. Following review of data relating to the UK by
competent authorities, and noting the weight of evidence approach, no followup
action was required.
5.5.28 Testing methods for honey authenticity have attracted a variety of viewpoints
and discussion from across the commercial, analytical and regulatory spheres.
Reservations include the lack of comprehensive, reliable, open reference libraries to
be used alongside some analytical methods. This and other issues were the subject
of a workshop in the UK between scientists, industry and regulators in autumn 201956
and several strands of onward activity are planned as a result of the workshop.
Consideration of methods is also noted in the responses of the Canadian and
Australian authorities to their sampling data.
5.5.29 Other examples of quantitative adulteration observed in the reporting period are in
the herb and spice
herbs. The majority of reporting relating to this sector relates to activities taking place
retailers in the south of England.

This information was referred to the Spanish authorities, who
subsequently uncovered a clandestine factory who were mixing other
5 57
5.5.30 An industry sampling dataset covering analyses conducted between October 2018
levels of adulteration with extraneous plant material. A further six samples tested
54
Enhanced honey authenticity surveillance (2018 to 2019), Canadian Food Inspection Agency
(CFIA), 2019
55
Honey investigation concludes due to testing uncertainty, Australian Competition and
Consumer Commission (ACCC), November 2018
56
Honey Authenticity Seminar (2019) Report, Gov.UK, April 2020
57
, Food Manufacture, August
2019
38
positive for the adulteration of frozen garlic puree with water, most likely to bulk up
the frozen product.
5.5.31 These possible non-compliances represented just 0.75% of all herb and spice
samples tested for authenticity issues within this industry dataset.58
5.5.32 It is highly likely that preventative measures put in place by the majority of UK herb
and spice importers have been successful in reducing the risk to the UK market.
If these products are present in the UK, it is likely they entered the UK as personal
imports or were sold through smaller convenience retailers with lower-scale supply
chains.
5.5.33 A 2019, European Commission-led control plan explored herb and spice authenticity.
The results from this plan will be useful comparison to domestic data once they are
published later in 2020.
5.5.34
adulteration of basmati rice with other varieties. It is likely that this will remain an
issue due to recent changes to regulations relating to permitted pesticide residue
vigilance will be maintained.

5.5.35 In 2019, sampling carried out on products sold in the UK and labelled as containing
found that some contained up to 30% cows’ milk, a more broadly
regarded as a specialist product, commanding a higher price.

5.5.36 It is likely that adulteration of this nature is occurring in other cheese and dairy
products made from milk other than cows’ milk. Broader evidence of this, however, is
not held, but sampling by Bulgarian authorities under Operation OPSON IX did identify
dairy products adulterated with starch.
5.5.37 nut powders,
particularly the addition of peanut powder to almond powder. A number of deaths
have occurred in the UK as a result of the undeclared use of peanut powder in
takeaway meals, and whilst not all were a result of fraudulent adulteration, these
deaths highlight the high level of risk that can be associated with food crime,
particularly where food allergens are involved.
5.5.38 Available sampling data for the reporting period does not indicate a high frequency
of nut powder adulteration and a very low level of intelligence has been received
in relation to this. It is a realistic possibility that this is in part due to the increased
awareness of the profound consequences of such activity.
5.5.39 Recent recalls of pesto sauces linked to peanut contamination in the cashew nut
content of the product demonstrate the continued relevance of this theme within
international supply chains, as well in more localised food service.
58
11 of 1476 tests of herb and spice samples noted within this dataset.
39
5.5.40 During the reporting period, targeted action to uncover potential fraudulent practices
in ground labelled as 100% Arabica was carried out by 14 European countries,
5
5.5.41 Under 3% of the 400+ samples showed adulteration, but we assess that continued
vigilance is necessary in this area; it is almost certain that the scale of this practice
Qualitative Adulteration
5.5.42 Qualitative adulteration aims to improve the appearance of a product, in order to
imply a higher quality and secure a more favourable price. This has been observed in a
range of products, including tuna, and palm oil.
5.5.43 Fraudulent activity across the global tuna supply chain remains an ongoing concern,
although the execution of this practice has not been noted in the UK.
5.5.44 The practice involves the illegal treatment of canning grade tuna to appear to be fresh
grade product. Common methodologies have included the injection of beetroot juice
colouration associated with fresh tuna, masking the brown colouration which occurs
over time.
5.5.45
5.5.46 These practices present health risks, masking the build-up of histamines in the product
which can lead to scombroidosis, with symptoms similar to an allergic reaction.
5.5.47 Under Operation OPSON VII in early 2018, a number of European countries, including
the UK, participated in co-ordinated activity looking at the production and distribution
presence of adulterated product in some areas of the UK market, but no adulteration

activity taking place.
5.5.48
and have since been used to strengthen supply chains, and target enforcement
activity across the EU. The European Commission have taken steps to tighten
regulations around the levels of additives, such as antioxidants, permitted for use in
food.
40
Case Study: Operation ATUNALI

In August 2018, a Spanish-led operation in collaboration with Europol,
the European Commission, and EU Member States, led to the seizure of
45 tonnes of illegally treated tuna.
vegetable extracts containing high levels of nitrites. This had masked
adequate freezing capability to catch fresh tuna.
5.5.49 Activity by law enforcement bodies has disrupted criminality in this area. However,
some criminal groups involved in this activity have changed their adulteration
monoxide.
5.5.50 It is likely that there is still adulterated tuna on the EU market, either through continued
fraudulent processing within the EU, or through the importation of adulterated product
from third countries, and a realistic possibility that illegally treated tuna is present in the
UK market, however the scale of this is currently unknown.
5.5.51 Even where some form of treatment is acknowledged on product labelling, for
not communicated to later consumers, for example when prepared in a food service
environment.
5.5.52
In November 2018 Italian authorities seized six tonnes of cod along with large
5.5.53 Red palm oil

continuing issue within the reporting period, with adulterated product imported from
5.5.54 Red palm oil is naturally red, due to the high beta carotene content. Low grade palm
oil adulterated with Sudan dyes has the same desirable red colour, even after cooking.
5.5.55 Small quantities of such product have been imported by private individuals in the
UK, but it is unknown whether these were intended for personal use or onward
adulterated product.
41
Substitution
5.5.56 Substitution is the wholesale replacement of one product or ingredient for another.
Determining whether a replacement is partial (adulteration) or entire (substitution)
can be challenging, particularly in composite or processed products.
5.5.57 These two crime techniques often seem to occur on a sliding scale, and in some
5.5.58
under Operation OPSON VIII, performed in Northern Ireland, found that two of 27
cod samples procured from takeaways were of the incorrect species. More broadly,
haddock was noted as a common replacement species but a variety of substitutions
have been noted, including pangasius, coley and whiting.
5.5.59 Industry sampling data shows lower levels of substitution than local authority
sampling, which is likely indicative of the types of products and establishments
targeted for sampling in each dataset.
5.5.60 Supply issues within the vanilla sector have been noted as a concern but have not
5.5.61 Global shortages have caused the price of vanilla to soar during this reporting period.
In early 2018, vanilla prices reached £463 a kilo, declining to £397 in June 2018.59 This
5
some artisan ice cream producers announced that they were ceasing production of
vanilla ice cream until such time as the price decreased.
5.5.62 Despite this, substitution of natural vanilla with synthetic vanillin within the UK market
has not featured within intelligence held by the Units during the reporting period.
5.5.63 Similarly, vulnerabilities in the butter and cream sectors, owing to supply issues,
have been noted in market commentary but have not manifested in reported non-
compliances.
5.5.64 One high street bakery chain did publicly declare that they had replaced butter
60
and an
margarine as German butter. Consequently, this remains a sensible area for vigilance
in relation to future supply and demand factors.
59
Vanilla price rise proves chilling for ice-cream makers, BBC News, May 2018
60
, The Guardian, June
2019
42
5.6 Misrepresentation
5.6.1 Misrepresentation within the food chain can largely be categorised into four main
Figure 5: Examples of the main types of misrepresentation
5.6.2
as having intangible but desirable qualities, such as ethical status, or high animal
welfare.
5.6.3 Misrepresentation occurs most commonly where there is little ability on the part
of the customer to identify whether a statement or claim made on the packing of a
product, or as a marketing claim relating to that product, is genuine and accurate.
5.6.4 It is almost certain that where an act of misrepresentation is carried out, there will
be an act of document fraud associated with it, whether associated with product
labelling or with documents used to support authenticity claims. This document fraud
is used to legitimise the misrepresented product and disguise the fraudulent activity.
43
Misrepresentation of Quality
5.6.5 Misrepresentation of quality occurs across many sectors of the food industry.
Products are particularly vulnerable where the misrepresentation is hard to detect.
qualities of a product, a lack of reliable testing methods to verify them, or marked

similarities with a genuine product.
5.6.6
overseas. Global supply chains, however, mean that these issues may still be present
in products on sale to UK consumers,
5.6.7 Products featuring prominently in reporting relating to misrepresentation of quality
elsewhere.
5.6.8
are particularly vulnerable to misrepresentation of quality.

5.6.9 The premium status of these products is typically indicated through the use of an
additional descriptor or logo on the packaging. Examples of premium status include
schemes.
5.6.10 The price mark-up associated with these product characteristics, or alternatively the
market access which they enable, makes such characteristics particularly vulnerable
to misrepresented lower quality products purporting to bear this status.
5.6.11 Organic agriculture aims to produce food and feed using only natural substances
taken place overseas.

5.6.12 The scale on which fraudulent organic products enter the UK market is not known,
held relating to UK-based organic production, or fraudulent sales of organic product
44
Organic farmers, processors, distributors and retailers must be registered,
that the relevant standards are maintained throughout the supply chain. There
5
approved by the European Commission to certify products produced in, or
imported into, the EU.61
5.6.13 As part of Operation OPSON VIII, EU member states focused on identifying fraudulent
organic products being produced, sold or imported into the EU market. This included
some organic shipments relating to the UK.
5.6.14 Successful operational outcomes around organic products have included:
● an Italian-Serbian investigation into an OCG selling juice, jam, and canned foods
labelled as organic, made from decomposed apples.62
● the seizure in Spain of 470 tonnes of vegetables marketed as organic, but which
had been sourced from suppliers who only farmed conventionally.63 This resulted in
● also in Spain, authorities uncovered the fraudulent sale of conventional eggs as

organic, resulting in the seizure of over 45,000 eggs, and six arrests.
Case Study – Organic Fraud – USA

In August 2019, a group of farmers in the US were convicted of
fraudulently selling conventional maize and soybean as organic animal
feed. It is estimated that the group made more than $120 million from
the scheme, and that their produce accounted for up to 7% of organic
corn, and 8% of organic soybeans grown in the US in 2016.
The product was sold to organic livestock farmers, meaning that the
resultant meat, dairy and egg products did not conform to the organic
consumers will have unwittingly paid a premium for product which did
not meet their expectations of quality.
61
Approved UK organic control bodies
62
Eurojust helps reveal fake organic food fraud, EUROJUST, July 2019
63
The Civil Guard seizes 300 tons and 39,000 litres of counterfeit food and drinks, Guardia
Civil, June 2019
45
5.6.15 Due to the international nature of the organic sector, it can be complex to verify the
This is compounded by challenges with verifying the organic status of a product
trail to verify status.

5.6.16 European Union quality schemes protect a range of specialist regional, or traditional
products produced within EU Member States. The majority of these protections are
linked to geographic origin, or method of production.
5.6.17 The prioritisation of the misrepresentation of Protected Designation of Origin (PDO)
products as an issue may vary between countries depending on the number of
products they have registered, and the economic importance of these products.
Within the UK, over 40% of PDO and Protected Geographic Indication (PGI) products
originate from Wales, Scotland and Northern Ireland.
5.6.18 It is likely that some products are being fraudulently marketed as holding such a status,
given the higher price and market share they can command compared to similar
products. This has been noted with regards to Italian sparkling wine and ham products.
5.6.19 Prosecco holds PDO status within the EU and is recognised under the domestic Italian
designation of controlled origin (DOC) and designation of controlled origin guaranteed
(DOCG) schemes.
5.6.20
(originating from areas outside of the Prosecco region, including some produced
outside Italy) and also the marketing, as Prosecco, of sparkling wine ‘on tap’ or from
a keg at a number of businesses across the UK. Wine sold in this manner cannot be
marketed as Prosecco.
5.6.21 It is likely that its popularity makes Prosecco more vulnerable to fraudulent activity of
this nature than other sparkling wine products.
5.6.22 Under Operation OPSON IX in 2019-20, 210 tonnes of cheese were seized which did
not meet the conditions of the protected geographic designation it was to be labelled
with64.
5.6.23 Information has been received regarding several instances of the incorrect
advertisement of protected designation Parma ham by UK sellers during this period.
5.6.24 Within the UK, there are a number of recognised quality assurance schemes for
meat, dairy, eggs and animal feed. These schemes are industry led, and promote high
animal welfare and production standards.
5.6.25 Producers who wish to be recognised under these schemes must pay a members fee,
and are subject to regular audits to ensure that they meet required standards.
64
OPSON IX press release, Europol
46
5.6.26 Consumers may use the labelling from these schemes to identify British origin
products and assign a higher quality to products which bear these markers. It is
attractiveness for fraudsters.

5.6.27 The level of fraudulently labelled product claiming to be produced within the
standards of assurance schemes is not known, however this has featured within
reporting to the Units. The Units continue to enhance relationships with the bodies
regulators.
5.6.28 The misrepresentation of quality of
period, predominantly in relation to illegal harvests. This is closely linked to the
creation of fraudulent documentation used to hide the true quality of the product.
5.6.29 This takes place through the misrepresentation of product from Class B or C beds,
or prohibited areas, as a higher class. Declaring as a higher class reduces processing
requirements for the product, lowering costs and facilitating sale at a higher price.
However the product may still contain harmful toxins, raising consumer safety
concerns.
5.6.30 Spirits, particularly vodka, are vulnerable to misrepresentation of quality, with reporting
received in relation to multiple instances of counterfeit product being marketed.
5.6.31 The UK wine and spirit industry generates around £49bn annually in economic activity,
with £10.6bn in sales of wine and £11.1bn in sales of spirits in 2018.65 In the UK, 81% of
adults who consume alcohol, drink wine, and 79% drink spirits. As a result, the alcohol
industry is a lucrative target for criminal activity.
5.6.32 In some instances, counterfeit vodka has been found to be harmful to health due to
levels of methanol and other industrial chemicals, as referred to earlier in this chapter.
5.6.33 Reporting in June 2019 highlighted an issue with lower quality wine being placed in
counterfeit bottles bearing the name of a popular and familiar brand. It is likely that
counterfeit wine is circulating on the consumer market in the UK on a broader basis
5.6.34 Recent operational activity co-ordinated by the Units has targeted the presence
of illicit alcohol in UK marketplaces under Operation OPSON IX. Across thirteen
participating European countries, 1.2 million litres of alcoholic beverages were
seized66.
Misrepresentation of Origin
5.6.35 Misrepresentation of origin encompasses falsely labelling a food as coming from a
to a number of factors, including higher prices for products of that origin, to evade
import controls, or to make a product appear more desirable, or of higher quality.
65
Facts and Figures, Wine and Spirits Trade Association (WSTA)
66
OPSON IX press release, Europol
47
5.6.36 Making choices about where your food comes from is a key feature of current
consumer behaviours, and as such, desirable origins make for a very marketable
status. The misrepresentation of British origin is a noted theme here. FSA research67
of food from the UK and Ireland, compared to that produced abroad.

5.6.37 It is assessed as almost certain that misrepresentation of origin is occurring
amongst a variety of food types. Foods of note include eggs and poultry, although
misrepresentation of origin is noted across other food areas too.
5.6.38 Reported incidences include non-UK origin poultry being relabelled and sold as British
or marketed as locally sourced and free range.
Case Study – Meat misrepresentation

A Warwickshire businessman was convicted in 2019 of labelling and
marketing imported meat and poultry as British and frozen products
as fresh, as well as falsely claiming that products were from premium
status or high-welfare livestock.
Following the successful Trading Standards prosecution, supported in
5.6.39 Intelligence has historically indicated misrepresentation of origin for meat products
(at varying scales); more recent industry sampling found 3.7% of red meat and poultry
requiring further investigation) although testing is indicative rather than conclusive.68

5.6.40
businesses, as opposed to major producers and suppliers who have much greater
visibility of, and control over, their supply chains.
5.6.41
instance, the eggs were from battery hens but were marketed as organic (thereby
also incorporating misrepresentation of quality).
5.6.42
67
FSA Public Attitudes Tracker, Wave 19 Report, Food Standards Agency (FSA), February 2020
68
10 out of 268 samples tested for geographic origin within this dataset
48
5.6.43 Non-foods are substances that have no place in the human diet yet are marketed
5.6.44 2,4-Dinitrophenol (DNP) is a dangerous non-food, marketed as a diet pill. It has
The chemical has explosive

69
properties and although sometimes marketed as suitable for some agricultural

applications, is not authorised for these purposes in the UK.
5.6.45
loss aid, often with no mention of the severely detrimental health impact which can
result from consuming the product.
5.6.46 The Units have worked extensively since 2015 to target the sale of DNP, particularly
with regards to online availability, and to hold to account those responsible. This has
included removing over 350 online listings, including websites, marketplace listings
priority. The Units are working with partners across the Government and enforcement
landscape, both in Whitehall and in the Scottish Government, to seek to ensure
that this issue is tackled collaboratively and under the most appropriate legislative
framework.
Case Study: Operation OPSON VIII – DNP
5.6.47 It is almost certain that DNP is still circulating the consumer market in the UK, and that
sellers will continue to market their product towards certain groups of consumers.
5.6.48 A number of criminal proceedings relating to DNP supply, supported by or initiated
on the basis of intelligence from the Units, are ongoing or recently concluded in the
United States. These relate to sellers linked to transactions known to be made to UK
consumers and some custodial sentences have resulted.
69
Data compiled by National Poisons Information Service, 30 June 2020
49
5.6.49 Miracle Mineral Solution (MMS), a sodium chlorite solution, is a non-food which is
marketed as a health cure, with some sellers claiming that it can cure conditions such
as autism, malaria or Lyme disease.
5.6.50
and the Units take action to impede their activity. It is almost certain, however, that
this trade will continue to be observed, potentially in ways which are oblique or covert
about the intended use of the product.
5.6.51 Food supplements are another strong theme within the misrepresentation of
products.70 Some of these novel foods may be close in nature to substances whose
presence in food is unauthorised owing to health issues, for example in terms of
analogues of the unauthorised medicine 1,3-di-methylamylamine (DMAA).
5.6.52
regards to the labelling of food supplement products. These range from prohibited or
inaccurate health and nutrition claims to the inappropriate use of the term ‘natural’.
5.6.53
ingredients of interest include CBD and selective androgen receptor modulators
(SARMs).
5.6.54 The lucrative market for food supplements may incentivise some within the sector to
appeal to some consumers but which do not comply with UK legislation. The ease of
informal entry into this sector, and the fact that supplements can be shipped globally
through the postal system, makes this an area of note.
5.6.55 It is highly likely that other non-food substances are present in the consumer market.
light as a result of serious injury or death linked to their consumption. We are vigilant
to this threat and also note positive exchanges of industry intelligence with regards
Misrepresentation of Freshness
5.6.56 The misrepresentation of date in relation to food involves the false declaration of
the freshness or durability date of a product. This practice can range from low-level
attempts to deceive, to more complex frauds requiring planning, with wider-reaching
impact.
5.6.57 The extension of durability dates can occur at all stages of the supply chain, with
incentives, but motivation may depend on whether the crime is an expedient
70
before May 1997.
50
response to short-term stock management issues or is focused and sustained activity

with a level of complicity.
5.6.58 Activity in this area focuses on products where the level of freshness will go
unnoticed in the short term, or where there is limited testing opportunity or capability
and eggs.
5.6.59 Methodologies utilised by fraudsters to falsely declare the freshness or date of a
product can vary from simple label changes to complex levels of deception, such as
physically altering dates on labelling, masking product with marinades or additives; or
freezing product before later defrosting for sale as ‘fresh’. Issues also include mixing
product past its durability date with fresh and also use of chemicals or additional
ingredients to change the appearance of the food, a form of qualitative adulteration.
5.6.60 The misrepresentation of kill dates
to make meat seem fresher. The re-dating of poultry carcasses and subsequent
5.6.61 Reporting relating to the freshness of eggs continues, with the age of eggs being
masked by ‘forward coding’ the product. Shelf-life is extended through false ‘laid’
5.6.62 The true scale of this fraud in the UK remains unknown, but it is likely that some
forward coded eggs are present in the market. Forward coded eggs also pose
potential consumer health concerns, although the scale of any resulting illness
Case Study – Date extension

of out-of-
71
date meat being placed back into the food chain. A meat processing
plant and cold store were found to be removing labels on frozen meat
products, including minced meat and oxtail, and replacing them with
withdrawing the company’s approval.
71
VEVIBA Consumer FAQ, Federal Agency for Food Safety (FAVV), March 2018
51
5.7 Document Fraud
5.7.1 Fraudulent documentation can be used to support varied practices within food
crime, particularly misrepresentation. The motivation to commit document fraud will
5.7.2 Food criminals make use of both fraudulently produced paperwork and misused
legitimate documentation. It is highly likely to occur where a commodity might
undersize or over quota.

5.7.3 Document fraud is principally used to cloak the true origin of a product (either for
as legitimate and safe, or make a product appear to be of a higher quality. The level
of sophistication varies. Basic checks are often able to identify fake or falsely applied
approval codes; targeted audits might be required to identify criminality within the
organic sector.
5.7.4
5.7.5 Understanding the scale of document fraud within the supply chain is an ongoing
challenge. Continued work to develop information from industry experts will be key
to having a greater understanding of the exact nature and scale of this activity. This
partnership will help with developing preventative measures to mitigate this risk.
5.7.6 The UK continues to be vulnerable to attempted imports of food products where
labelled with fake approval numbers, being stopped at the UK border. The nature of
cross-border trade – involving a high volume, quick turnaround inspection process –
presents a window of criminal opportunity.
52
5.7.7 The following table lists some key forms of document fraud and our associated
assessment.
Document Assessment
Health Bypass pre-export health
checks and/or EU import
controls on imported vegetables imported from India, which
shipments. would not pass health checks.
Customs Import of restricted and/or False or inaccurate customs declarations

declarations prohibited food products have been used in attempts to import
by falsifying customs prohibited goods from Nigeria and Ghana,
declarations. including bushmeat and adulterated palm
oil. They have also been used to facilitate
the illegal importation of veterinary
medicines and antibiotics.
It is also highly likely that DNP enters the
UK though intentional misdeclaration
of contents on customs forms, whether
on postal packets or in more wholesale
quantities.
Export health Misrepresentation of

non-UK products as
originating from the UK, Europe.
or EU products as from
an alternative country, to
increase the value of a
disguise the EU origin of agricultural
product or hide its origin.
products owing to the ban on the transfer
of these products to Russia.
to facilitate the export of ruminant

processed animal protein to third
countries by stating an EU destination.
Approval Falsely conferring

numbers standards of hygiene and the removal of original health marks on
safety onto products. poultry, the use of fraudulent approval
numbers by unapproved freezer vessels
products in the egg sector.
53
Document Assessment
Facilitate entry of illegally Fraudulent documentation has been
landing harvested and/or falsely
across the UK, potentially allowing unsafe
into legitimate supply
chains.
False or Facilitate illegal movement False, doctored or reassigned horse

reassigned of restricted, stolen or
animal with horses presented for slaughter in
England. This includes the use of multiple
livestock into legitimate microchips to obscure original microchip
supply chains. identities of horses. This has been noted
in the Republic of Ireland and been subject
to operational activity in 2019 including as
part of Operation OPSON IX.
This poses potential human health risks
used to hide treatment with veterinary

medicines such as phenylbutazone, but
these health risks are assessed to be
It is highly likely that stolen cattle are

given new identities in order to enter
legitimate abattoirs (or are slaughtered
illegally and enter the food chain
through the use of other fraudulent
documentation).
Industry and Increase the value and The Units have received reporting around
laboratory market price of products fraudulent farm assurance and organic
or confer a safety or
authenticity status based
on laboratory analysis.
There has been very limited reporting
54
6. The Future of Food Crime
6.1.1 Food crime can thrive when the established supply and demand relationship changes
that in the next 36 months, the scale and pace of changes in supply and demand will
increase. Developments in the political, environmental, societal, technological, legal
and economic landscapes may provide greater opportunity for food crime to occur
but could also enhance our ability to identify and combat the threat.
6.1.2 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
less familiar countries of origin into supply chains.

6.1.3 Arrangements under the Northern Ireland Protocol, relating to the nation's continued
presence in EU and United Kingdom markets, will also be noteworthy in terms of
impacts on product movements and commercial behaviours.
6.1.4 The current economic downturn is highly likely to have an impact on some
consumer and business behaviours. For businesses, the motivation to commit fraud
would increase, as other opportunities to make money reduce. From a consumer
perspective, food bills become more substantial as a percentage of household
consumer choices. These factors could lead to a larger potential victim base for those
forms of food crime which relate to the entry of poor quality food into the market for
sale at low prices.
6.1.5 Conversely, the rising purchasing power of the global middle class has been driving
demand for luxury foods, that will increasingly outstrip supply. Even in harder times,
it could still make premium foods, such as those holding a protected food name or
cherished origin, and perhaps some preferred protein sources (such as pork in the eyes
of Chinese consumers), an attractive target for fraudulent trade – particularly if practical
limitations on volumes of production arise.
6.1.6 Social media use in the UK is likely to increase in the coming years and will have
rapid and widespread changes in consumer preference, which are increasingly

international.
6.1.7 We perceive a decrease in the length of time it takes new products to become
popular at scale, especially within more novel foods. This is in part due to social
55
6.1.8 On the current trajectory, more food and drink will be sold direct to consumers
through social media, exacerbating existing concerns around this marketplace.
6.1.9
food products, not traditionally consumed within the UK. Where such products are not
permitted in the UK, an increase in non-conventional and illicit supply routes should
be expected.
6.1.10 It is already possible to buy food on the dark web, and a general rise of dark web
use for more commonplace purposes, would likely include consumers buying more
products on the dark web. We still assess, however, that food purchases through
dark web sites would be focused on illegal foods, novel foods, harmful non-foods
and supplements – products on or beyond the threshold of legality and for which a
visibility on the surface internet).

6.1.11
the capability to detect fraud across a wide range of food types. The value of these
deployed reliably and at scale, and on their inclusion or otherwise into any suite of
accepted international standards.
6.1.12 We predict that blockchain technology72 will continue to be adopted within the
expectations of supply chain transparency should encourage the movement of food

businesses towards openness around traceability.
6.1.13
to food fraud in sectors where uptake is strong, the system does not address the
root cause of potential fraud. Also, if some blockchain applications are successful
in assuring traceability, criminal activity could be displaced to other sectors or
food supply chains. The cost of implementing end-to-end blockchain may be cost
prohibitive to some sectors.
6.1.14 Measures will also be taken to strengthen a joined-up approach to food fraud
internationally, including within the European Union.
6.1.15 Whilst the UK is no longer an EU Member State, it is highly likely that the EU will remain
a key trading partner for food commodities. Increased, co-ordinated activity looking
to better understand and tackle food crime issues within the EU-27 will therefore be
72
Blockchain is a list of records, called blocks, that are linked using cryptography. It is a
secure method of linking data together.
56
6.1.16 The European Council plan to adopt an approach to improve cross-sectorial

cooperation and raise awareness amongst consumers, following a clear direction
from the incoming President73 regarding food fraud.
6.1.17
Control Regulations must be able to securely handle reports of infringements and
protect the identity and rights of those making reports. This may result in more food
crime reporting to EU member states, enriching intelligence pictures and potentially
identifying issues relevant to the UK.
6.1.18 The activity of the EU Food Fraud Network is also anticipated to continue to provide
a valuable forum to EU member states to discuss food fraud, agree shared plans of
activity and consider strategic issues. This will be complemented by a dedicated
food fraud working group under the auspices of the European Heads of Food Safety
Agencies framework.
6.1.19
the world, with more countries developing dedicated capabilities to tackle food crime
or intending to do so. This represents a positive development within the global food
chain.
6.1.20 This international focus will include the continued development of the Global Alliance
on Food Crime, which brings together the UK, USA, Canada, Australia and New
Zealand to discuss, develop and deploy counter-food crime capability.
6.1.21 There is current work by the Food and Agriculture Organisation (FAO) Codex
conferences focusing on food safety and food production.

6.1.22 The combination of population growth and climate change presents challenges for
future food production. We will need more food, but it will get increasingly harder to
produce and supply, using current methods. If food prices increase in line with this
constriction of supply, then the incentive to commit food crime would increase.
6.1.23 Future changes in UK environmental policy may result in new threats in the food crime
landscape. This could include illicit chemical interventions in crop production and
goods transit methods outside of the cold chain being areas of potential growth in
response to regulatory controls over vehicle emissions and pesticides.
6.1.24 The drive towards a low carbon economy could have unintended consequences for
food safety and authenticity. More UK cities may introduce low emission zones, which
could deter food suppliers from using older, polluting refrigerated vehicles within
those areas, a practice which will attract a penalty fee. This could result in food being
removed from the cold chain during distribution, raising safety and hygiene issues.
73
Mission Letter, Stella Kyriakides (President-elect of the European Commission, September
2019
57
6.1.25
assessment that a continued focus on the tangible threat which food crime poses
.
6.1.26 There will be a continued requirement to protect the UK and its interests from food
sector partners to tackle the issue.

6.1.27 The Units will continue to develop a more sophisticated understanding of the UK food
crime threats and vulnerabilities, in order to best protect consumers and businesses.
We will continue to explore and assess the consequences of future regulation, and
monitor the interplay between our food systems, food crime and other serious
product safety or authenticity.

6.1.28 We will work with partners to ensure that the future threat of food crime in the UK is
reduced, controlled and continues to be thoroughly understood. We will require the
assistance and support of our all partners if we are to credibly and collectively meet
this goal.
58
7. Next Steps
7.1.1 This assessment demonstrates the complexity of understanding food crime, and the
degree to which vulnerability to fraud takes on many forms, presenting varying levels of
harms within the UK. We can make judgements about which aspects of the food crime
threat merit prioritisation based on our current understanding of this landscape.
7.1.2 The assessment is used as a driver for strategic prioritisation by the Units, as well
as supporting broader work within the Food Standards Agency and Food Standards
Scotland.
7.1.3 Each Unit has developed their own control strategy and an associated plan of activity
to deliver it, including identifying new intelligence requirements. This includes activity
of food crime, and preventing individuals from engaging in food crime, as well as
pursuing food criminals.
7.1.4 We also want to continue to understand more from those working in the food
partners. There are a number of routes to contact the Units, which are listed on the
following page. This interaction is essential to best focus, and to continually improve,
59
Tell us what you think

We value feedback from everyone who has read this document.
Please complete a short survey – completely anonymously if you wish – to help
us improve future iterations of the assessments.
Tell us what you know

If you have information to share about food crime, you can contact us one of
several ways.
National Food Crime Unit, Food Standards Agency

Call 5
Report concerns via the FSA website
Email foodcrime@food.gov.uk
Visit the food crime section of our website
Scottish Food Crime & Incidents Unit, Food Standards Scotland

Call the Scottish Food Crime Hotline free on 0800 028 7926 (24 hrs)
Report your concerns via a dedicated online reporting form
Email foodcrime@fss.scot
Visit the food crime section of our website
60
Appendix A – List of Contributors
Animal and Plant Health Agency (APHA)

British Retail Consortium (BRC)
Food Authenticity Network

Food Industry Intelligence Network (FIIN)
Food Safety Authority in Ireland (FSAI)
Food Standards Agency (FSA), including FSA Wales and FSA Northern Ireland
Food Standards Scotland (FSS)
Gangmaster and Labour Abuse Authority (GLAA)
Global Alliance on Food Crime
Inshore Fisheries & Conservation Authorities (IFCA)
Laboratory of the Government Chemist (LGC)
Marine Management Organisation (MMO)
Marine Scotland
National Wildlife Crime Unit (NWCU)
NFU Mutual
Rural Payments Agency (RPA)
SeaFish
Scottish Government
Trading Standards Scotland
Transported Asset Protection Association (TAPA)
UK Border Force
102 Environmental Health and Trading Standards Departments and Food Groups across
England, Scotland, Wales and Northern Ireland
61

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FOOD CRIME

STRATEGIC ASSESSMENT 2020

This document is produced by the

Probability and Uncertainty............................................................................................... 2

3. Current Environment .................................................................................................... 12

4. Food Crime and Serious Organised Crime .....................................................................19

5. Threat Assessment ..................................................................................................... 23

6. The Future of Food Crime ............................................................................................ 55

7. Next Steps ................................................................................................................... 59

Appendix A – List of Contributors .....................................................................................61

ranges considered when such language is used:

from food crime.

Darren Davies Ron McNaughton

due to gaps in accreditation or assurance scheme membership, as well as means to

Threat assessment – highlights

Commodity or theme Assessment summary

Criminality relating to the marketing of substances unsafe for

Illegal harvesting continues around the UK coastline,

The high harm but low prevalence issue of spirit drinks

assessed as at high risk of food fraud owing to their nature or

Fish non-compliance than local authority checks; the application

Cross cutting themes and techniques

Commodity or theme Assessment summary

Misuse of premium status labels, including designated origin

Routes via which the internet enables the provision of

A noted modus operandi which leaves suppliers out of pocket

2.1 Purpose and structure

2014-15. This assessment covers a principal reporting period from 1 September

2.2 Information sources and limitations

tackling food crime.

in these three nations.

face competing priorities and resourcing constraints.

Consumer Trends and Attitudes

products in this area.

constitute a food crime. We are working partners at points of entry to better

African Swine Fever

infected are being used in food production.31

supplied to a number of charities, was adulterated with substances including soya,

and thereby to identify who is responsible for administering controls.

Figure 1: Intersections between food and crime and e-commerce

4.2 Exploitation of the food system

Exact methodologies have been varied, perhaps to avoid detection.

leading to an increased risk of detection and the

4.3 Food criminals and serious organised criminals

order supply of food supplements of varying degrees of legality and safety.

duty evasion are also considered).

Figure 3: The seven types of food crime

5.1.5 Substitution and adulteration,

while the product is in the control of an intermediate owner or processor, or in the

result of the price.

Figure 4: Process diagram of food crime types

processed or transported in line with food safety and hygiene requirements, or

legitimate supply chains.

5.2.4 Livestock theft

Case Study: Operation STOCK

5.2.7 We assess that poaching

5.2.8 The in coastal regions across the UK continues to

launched, in respect of the harvesting of razor clams.

harvesting to other coastal regions.

orders with overseas suppliers, is commonly referred to as European Distribution