Cleaning up the supplement supply chain

Food fraud in supplements can be costly, not only economically but also for a company’s reputation. The growth in the EU food supplements market has resulted in longer supply chains leaving ingredients more vulnerable to adulteration. We caught up with Luca Bucchini, Managing Director of Hylobates, ahead of his presentation at Hi Europe, to learn more about this problem and how to avoid it.

Your presentation is going to focus on food fraud within the EU. How big an issue is this for the supplements sector?
"The issue of food fraud of food supplements is big; it is economically relevant, and sometimes has a public health dimension. It is underestimated in the attention received by the industry at large and by regulators. My assessment is based primarily on the scientific literature, and professional experience. We see an increasing amount of reports of food supplement ingredients which are not what they should be. Even if very few products are affected, the consequences can be vast when customers, consumers, stakeholders, authorities, or your own business discover the issue. Opportunity for fraud is provided by prices of some raw materials, and pressure to reduce costs, while analytical methods and quality controls may not keep pace with the raw materials."

Has the situation got worse in recent years? If so, why do you think that is?
"We do not have good numbers, especially in the EU. Supply chains have been extremely long for some time, and it has not been matched by more auditing, testing, procedures, and voluntary or mandatory controls. What has changed in recent years is awareness of the issue - at least in parts of the industry - across the world. However, we still fall short of an acceptable situation. For example, recently, there have been analytical reports of progesterone in Commiphora wightii, or gugul. When some suppliers were asked to explain the finding, whether it was case of natural occurrence or of fraud, they simply shrugged off the issue. While some suppliers have stepped up their processes, and their traceability, some simply do not take responsibility for what they supply."

"I presume the situation has got worse as the food supplement market in the EU has grown, the supply chains of botanicals have got longer, and industry and regulators have not kept up with the new challenges."

Can you give some examples of common ways that supplements are adulterated?
"First, it is important to remember that the vast majority of food supplements are not adulterated. When they are, the primary form of fraud is to add a substance or plant material of lower quality. For example, aminoacids are added to whey protein to artificially increase the apparent nitrogen content (this is called protein spiking). Sophora japonica is used to adulterate Gingko."

"In general, when an analytical method has weaknesses, they are exploited for adulteration. Of course, when no testing is done, any filler will do to increase the apparent amount of a powder. A plant may be entirely substitute with another one. Sometimes, fraud concerns efficacy, or appearance. For example, pharmaceutical compounds are added to a natural substance, and suddenly consumers start to submit enthusiastic reports - that plant really works! But it's really the drug added to it."

"We know that spices are adulterated for colour since the Sudan Red crisis - but reports from France suggest that the issue has not gone away, and some spices are used in  supplements as well. Italy's leading trade organisation for food supplement manufacturers, Fedesalus, has recently issued detailed guidance on monacolin from red yeast rice, also because of adulteration concerns. Sometimes studies submitted to regulators have surprising findings, against the interests of applicants, because the study materials were adulterated."

What regulations are in place currently to prevent food fraud?
"There is no definition of food fraud in EU law, though the concept exists in national legislation. The European Commission (EC) states that food fraud covers cases where there is a violation of EU food law, which is committed intentionally to pursue an economic or financial gain through consumer deception. I think more could be done to apply the work done by the EU on food fraud on food in general to food supplements as well."

"Basically, if an ingredient is not as described, or not in the amounts declared on the label, then you have a violation of EU labelling law. If the food is not safe, a recall is necessary, and that would trigger action through the EU's Rapid Alert System for Food and Feed. That's the most rapid tool the EU has. Member States may also cooperate in other ways, and the EC can also coordinate control programs, provide training, and activate controls. In general, the new Regulation on official controls provides tools for authorities to address food fraud - the problem is awareness and assigning priorities."

"Where the EU falls short, I think, is in prescribing the inclusion of food fraud in the HACCP process; we do not have good manufacturing processes for food supplements yet and at least for botanicals that would be very important."

What should supplement companies look for when choosing suppliers to avoid buying adulterated ingredients?
"The suppliers need to have full control of their supply chains; this means full traceability, and auditing when necessary. They have to excel in analytical capabilities, and they need to understand their plants, preparations, and to be aware of potential fraudulent practices. What analytical methods do they use? If the literature has reported fraud with the existing method, and the supplier is purchasing externally the raw material, while continuing to use only the existing method, I would have questions to be addressed."

What are your top 3 tips for preventing or avoiding food fraud?
"1. Traceability from field to extract or product
2. Up to date analytical controls, knowledge of plant composition and potential adulteration of the specific plant
3. Carefully chosen partners - work within a responsible supply chain"