Food Fraud Annual Report 2020 to 2021
On this page
- Enhanced surveillance activities
- Compliance and enforcement
- Collaboration and engagement
- Next steps
Food fraud may occur when food is misrepresented, and is an emerging issue around the world. In Canada, it is prohibited to sell food that is falsely labelled or misrepresented, but such labelling may still occur. This impacts buyers economically, by not receiving what they expected, and can also pose health risks if, for example, undeclared allergens or hazardous materials are added to food products.
Addressing food fraud supports consumer confidence that food purchased in Canada is accurately represented and safe to consume. It also helps Canadian businesses compete more fairly in the Canadian and global marketplace.
Purpose of this report
Food fraud is a priority under the Food Policy for Canada. As part of this initiative, the Canadian Food Inspection Agency (CFIA) is enhancing its work to address food misrepresentation through strategies to prevent, detect and deter food fraud in Canada within its mandate. (For purposes of this report, CFIA's work on food misrepresentation and other areas of food fraud within its mandate are collectively referred to as "food fraud".)
This report is an overview of the food fraud initiative activities performed by CFIA during the 2020 to 2021 fiscal year, with a focus on the results of surveillance of certain high-risk commodities (honey, fish, olive oil, other expensive oils and spices) susceptible to food fraud.
CFIA received $24.4 million over 5 years and an additional $5.2 million per year on-going as part of the 2019 Federal Budget, to enhance the federal capacity to prevent, detect and deter food fraud in Canada. This funding includes $3.1 million for Health Canada over 5 years to support CFIA's work through research, intelligence gathering and risk assessment related to potential human health risks.
CFIA is doing the following activities to prevent, detect and deter fraud as part of the food fraud initiative:
- enhancing and continuously improving program design, based on research, intelligence, and global best practices
- conducting ongoing environmental scanning, risk assessment and analysis on food fraud vulnerabilities
- gathering data and conducting surveillance to develop intelligence to inform inspection activities
- researching and developing new methodologies to detect food fraud
- enhancing inspection, investigation and tactical intelligence capacity
- promoting awareness with industry, and collaborating with other jurisdictions and other government departments
CFIA inspects, samples and tests commodities that may be the most susceptible to being misrepresented. This work to detect potential food fraud is called surveillance.
This report summarizes two types of surveillance: directed and monitoring.
- Directed (or targeted) surveillance focuses on sampling at establishments with a history of non-compliance or other risk factors.
- Monitoring surveillance involves sampling that is unbiased, and samples are obtained randomly.
The testing results summarized in this report reflect both types of sampling, and so are not representative of overall compliance within the Canadian marketplace.
In 2020 to 2021 fiscal year, CFIA conducted surveillance to detect adulteration of honey with foreign sugars, adulteration of oils (olive oil and other expensive oils) with other ingredients, species substitution in fish, and the dilution of spices with other ingredients.
CFIA carries out sampling, testing, inspection and enforcement activities under the following authorities:
- Safe Food for Canadians Act and Safe Food for Canadians Regulations
- Food and Drugs Act and Food and Drug Regulations
The COVID-19 pandemic
The beginning of the 2020 to 2021 fiscal year coincided with the onset of the COVID-19 pandemic. In response, CFIA prioritized critical activities and temporarily suspended activities that were of lower risk to the health of consumers, including the planned surveillance of honey, fish, olive oil, other expensive oils and spices for food fraud.
CFIA resumed its non-critical work gradually. As a result, delivery rates were 26 to 58% of planned sampling done by the CFIA inspectorate, and 83% of planned sampling done at retail by third-party samplers on behalf of CFIA. Because of this, the sample sizes reflected in this report are lower than originally planned.
Additionally, CFIA is monitoring any increased risk of food fraud that may have arisen from the uncertainties during the COVID-19 pandemic. Appropriate oversight of domestic production and imported food products is essential to providing safe food for consumers while also supporting trade and the supply chain.
Enhanced surveillance activities
Results at a glance
Honey with added sugars deceives consumers and creates an unfair playing field for those selling authentic honey. CFIA conducts surveillance activities to detect misrepresentation of honey adulterated with foreign sugars in both domestic and imported honey sold in Canada.
The sampling and testing was similar to the surveillance conducted in 2018 to 2019 and 2019 to 2020.
- Report: Enhanced honey authenticity surveillance (2018 to 2019)
- Report: Honey authenticity surveillance results (2019 to 2020)
CFIA has been conducting enhanced honey authenticity surveillance since 2018. This work has enabled CFIA to identify and take appropriate action on food misrepresented as authentic honey. It has also provided data and intelligence that can be used to better detect the adulteration of honey with foreign sugars (such as sugars derived from sugar cane, corn syrups, rice syrups) in Canada.
CFIA collected and tested 182 honey samples for adulteration with foreign sugars. As in previous years, Stable Isotope Ratio Analysis (SIRA) and Nuclear Magnetic Resonance (NMR) methodologies were both used. SIRA detects adulteration with C4 sugars (such as sugar cane and corn syrups) and NMR detects added C4 sugars as well as C3 sugars (for example, rice syrups).
CFIA collected 58 samples, mostly from high-risk entities that were found to be non-compliant during the 2018 to 2019 and 2019 to 2020 honey surveillance work. CFIA also conducted sampling based on other risk factors such as history of non-compliance, gaps in preventive controls or unusual trading patterns.
Products represented as containing only honey or blends of honey from multiple sources were sampled. This included honey products such as bulk and honey used for further processing from importers. A small proportion from domestic establishments were also sampled.
Retail survey sampling
CFIA contracted an independent third party to collect 124 honey samples at retailers in various cities across Canada as part of its compliance monitoring of the marketplace. All samples were prepackaged honey sold to consumers at retail. CFIA uses the sample testing results of these monitoring activities to gain a better understanding of the Canadian marketplace and to inform future follow-up activities.
The following results are provided according to sampling type.
- Of the 58 samples collected, 13 were domestic, 45 were imported
- 43 samples were satisfactory by both SIRA and NMR methods: 74.1% (43/58)
- 15 samples were unsatisfactory by one or both methods: 25.9% (15/58)
Of the 15 unsatisfactory samples, 13 samples were wholly or partially imported honey from Egypt, Germany, Greece, India, India/Canada blend and Taiwan, and 2 samples were domestic Canadian honey.
Retail survey sampling
- Of the 124 samples, 96 were domestic, 28 were imported
- 118 samples were satisfactory by both SIRA and NMR methods: 95.2% (118/124)
- 6 samples were unsatisfactory by one or both methods: 4.8% (6/124)
Of the 6 unsatisfactory samples, 3 samples were imported honey from Australia/Brazil blend, Bulgaria/Greece blend, India, and 3 samples were domestic Canadian honey.
The detailed analytical results are available on the Open Government Portal.
As a result of this surveillance, the following amounts of adulterated honey was prevented from entering the Canadian market.
- 142 kg of imported honey was voluntarily destroyed
- 17 800 kg were removed from Canada
- 10 963 cases and 5 barrels were detained
CFIA continues to follow up on cases of non-compliance where necessary.
Fish products continue to be at risk for species substitution, which generally involves higher value species being replaced with less expensive species. Fish species substitution and mislabelling is a global issue, with various third party reports contributing to increased public awareness.
CFIA continued targeted surveillance of fish as part of its efforts to prevent, detect, and deter the prevalence of fish species substitution and mislabelling in Canada.
The sampling, testing, and collaboration was similar to the surveillance done in 2019 to 2020.
As in the previous year, samples were targeted based on risk factors such as an establishment's history of non-compliance and species of fish most likely to be substituted. The 9 types of fish of highest interest were: butterfish, cod, halibut, kingfish, sea bass, snapper (red and other), sole, tuna and yellowtail. CFIA also sampled other types of fish suspected to be substituted or mislabelled.
Prepackaged fish filets in fresh, frozen, dried, or salted format were collected to determine if the common name on the label accurately represented the species of fish in the package. CFIA collected fish samples at domestic processors, importers and retail establishments (fish packaged at retail). The Ministère de l'Agriculture, Pêcheries et l'Alimentation du Québec collected retail samples in Quebec on behalf of CFIA.
The samples were tested at a CFIA laboratory using deoxyribonucleic acid (DNA) barcoding to identify fish species. This method compares the DNA sequences from a fish sample against a DNA sequence database connected to the CFIA Fish List. If the declared name on the fish sample label matches the common name on the CFIA Fish List for the species identified from the DNA sequence database, the sample is satisfactory.
CFIA analyzed 110 samples and was able to assess 102 samples. Eight of the fish samples could not be assessed because a DNA barcode could not be generated for various reasons (for example, due to DNA degradation or fish cross contamination).
The results are as follows.
- 93 samples were assessed as satisfactory: 91.2% (93/102)
- 9 samples were assessed as unsatisfactory: 8.8% (9/102)
- Domestic processors: 93.8% satisfactory (15/16 samples), 6.3% unsatisfactory (1/16 samples)
- Importers: 89.2% satisfactory (33/37 samples), 10.8% unsatisfactory (4/37 samples)
- Retailers (fish packaged at retail): 91.8% satisfactory (45/49 samples), 8.2% unsatisfactory (4/49 samples)
Of the 9 unsatisfactory fish samples, 2 were declared as yellowfin sole, 1 Atlantic cod, 1 hairtail, 1 halibut, 1 pollock, 1 sea bass, 1 snapper, and 1 wild pacific snapper.
Detailed test results are available on the Open Government Portal.
As a result of this surveillance, CFIA detained 1672 cases of fish. Some of these non-compliant products were permitted to be relabelled as part of corrective action plans, after confirmation of the correct fish species and common name. CFIA continues to follow up on cases of non-compliance where necessary.
Olive oil is at risk of being adulterated with cheaper oils, both in Canada and abroad. Higher value olive oils are cold pressed and produced without the use of heat or chemical treatments. Extra virgin olive oil, followed by virgin olive oil, are the highest grades and the purest quality, and they tend to be darker in colour.
Adulteration occurs when a higher value olive oil is substituted by, or diluted with, a cheaper vegetable oil, or with refined olive oil or virgin olive oils of lower quality. It can also happen when colour is added to mimic the appearance of virgin olive oil.
To respond to the risk of olive oil adulteration in the Canadian market, CFIA undertook an enhanced surveillance strategy. The objectives of this strategy were to:
- detect adulteration of olive oil in Canada (including imported products)
- take control action and enforcement action to address non-compliance and deter future non-compliance
- generate information to inform strategies that will better prevent misrepresentation of olive oil going forward
CFIA focused enhanced inspection activities on olive oil establishments with a history of non-compliance, as well as other risk factors.
CFIA tested extra virgin olive oil, virgin olive oil and olive oil composed of refined and extra virgin olive oils. The following oils were outside the scope of testing: blends of different types of oils (such as, olive oil and canola oil) or oils mixed with other ingredients (for example, flavoured extra virgin olive oil). Samples were taken from a variety of establishments, including importers, domestic blenders, packers or bottlers and bulk oil distributors.
The samples were tested by gas chromatography for authenticity, adulteration or substitution with less expensive oils (such as soya, canola). This was done by assessing the sterol and fatty acid profile, and other parameters, based on the International Olive Council (IOC) Standard and the Codex Standard for Olive Oil and Olive Pomace Oil (CXS 33-1981). Dilution of more valuable extra virgin or virgin olive oil with refined olive oil was also tested.
CFIA analyzed 49 samples and the results are as follows.
- 43 samples were assessed as satisfactory: 87.8% (43/49)
- 6 samples were assessed as unsatisfactory: 12.2% (6/49)
Of the 6 unsatisfactory samples, 2 samples were labelled as from Italy, 1 from Lebanon, 1 from Spain, 1 from Syria and 1 sample was a blend from Greece, Italy and Spain.
Detailed test results are available on the Open Government Portal.
Highlights of CFIA actions taken as a result of this surveillance include detaining 13 873 L of product and shipping 2880 L of oil back to the country of origin. For the non-compliant samples, CFIA also followed up to determine at what point in the supply chain the non-compliance originated. CFIA continues to follow up on cases of non-compliance where necessary.
Other expensive oils
Expensive oils other than olive oil can be misrepresented due to their high value. They are at risk of substitution and dilution with lower quality oils. In addition to the presence of other less expensive oils, virgin or cold pressed oils can also be diluted with refined oils of the same type, lowering their quality and value.
CFIA's retail surveys conducted between 2018 and 2020 detected a number of expensive oils that did not meet the sterol and fatty acid profile, and other parameters for the oil declared on the label, in particular in the case of avocado, coconut, grapeseed and sesame seed oils. Other oils that were found to be adulterated in the past include almond oil and flaxseed oil. This data allowed CFIA to target higher-risk products when planning its 2020 to 2021 fiscal year sampling and inspection activities.
The following types of expensive oils were sampled as part of the 2020 to 2021 fiscal year surveillance: almond oil, avocado oil, coconut oil, flaxseed oil, grapeseed oil, hazelnut oil, mustard seed oil and sesame seed oil.
CFIA collected samples at establishments that trade in expensive oils, such as importers, blenders, bottlers and bulk oil distributors. CFIA places a higher enforcement priority on those with a history of non-compliance or with other risk factors.
Of the 65 samples collected and assessed, 23 were sesame seed oil, 14 grapeseed oil, 13 coconut oil, 6 almond oil, 4 avocado oil, 3 flaxseed oil, 1 hazelnut oil and 1 mustard seed oil.
The authenticity of the oils was tested by gas liquid chromatography to determine if the fatty acid, sterol profiles and other parameter, met the standard for these oils in the Codex Standard for Named Vegetable Oils (CXS 210-1999). Blends of oils or oils with other ingredients, such as flavourings, were not sampled.
CFIA analyzed 65 samples and the results are as follows.
- 43 samples were assessed satisfactory: 66.2% (43/65)
- 22 samples were assessed unsatisfactory: 33.8% (22/65)
Of the 22 unsatisfactory samples:
- 8 were coconut oil (61% or 8/13 samples)
- 6 were sesame seed oil (26% or 6/23 samples)
- 3 were grapeseed oil (21% or 3/14 samples)
- 2 were almond oil (33% or 2/6 samples)
- 1 was avocado oil (25% or 1/4 samples)
- 1 was flaxseed oil (33% or 1/3 samples)
- 1 was hazelnut oil (100% or 1/1 sample)
Detailed test results are available on the Open Government Portal.
As a result of this surveillance, CFIA prevented adulterated expensive oils from entering into the Canadian marketplace. Examples include:
- destroying 25.5 L of product labelled as sesame seed oil
- detaining 47 L, 181 cases and 28 units of food labelled as coconut oil
- shipping of 750 kg of product listed as avocado oil back to the vendor
CFIA also issued letters of non-compliance for the unsatisfactory products and did follow-up actions to determine where the non-compliance originated in the supply chain. CFIA continues to follow up on cases of non-compliance where necessary.
Spices can be subject to misrepresentation. These foods tend to be of relatively high value relative to weight. They are often sold or transported in bulk form, which facilitates dilution or substitution of an ingredient with relative ease compared to whole or prepackaged foods.
Bulking agents, dyes and other unpermitted ingredients have been added to spices to adulterate high value spices. These additions may also have food safety implications, such as undeclared allergens (for example, the addition of peanut shells or flour) or unpermitted chemicals or colours.
Examples of spices most likely to be at risk of misrepresentation include black pepper, cinnamon, cumin, paprika, turmeric, and white pepper. CFIA determined this based on environmental scanning, past inspections, compliance issues, trade volumes and published reports.
Single ingredient and ground spices are particularly prone to adulteration. The milling or grinding step changes the shape of both the spice and adulterant to a powder, making it difﬁcult to visually detect adulterants in the ﬁnal product.
Surveillance was based on risk intelligence, to focus on risk areas such as spice importers and domestic facilities with a history of non-compliance.
Sampling included single ingredient ground spices most at risk of misrepresentation, as mentioned above. Spice blends and whole spices were not assessed.
Of the 127 samples collected and assessed, 25 were cumin, 24 black pepper, 24 cinnamon, 24 turmeric, 16 paprika and 14 white pepper.
The sampled spices were tested for the presence of fillers such as wheat (gluten) and nut protein (peanut and almond) and for undeclared additives used to enhance their apparent value such as colouring agents (colours, dyes and lead chromate).
CFIA analyzed 127 samples and the results are as follows.
- 118 samples were assessed satisfactory: 92.9% (118/127)
- 9 samples were assessed unsatisfactory: 7.1% (9/127)
Of the 9 unsatisfactory samples, 1 cinnamon sample contained undeclared colouring and 8 cumin samples contained a potential nut allergen. It is important to note that while non-compliant, the cumin samples found to have nut allergen all contained low concentrations of allergens. These levels are more indicative of cross contamination than intentional adulteration or substitution.
Detailed test results are available on the Open Government Portal.
As a result of this surveillance, CFIA detained 73.8 kg of non-compliant cinnamon which was ultimately destroyed by the regulated party. For the 8 cumin samples found to contain low concentrations of allergens at cross-contamination levels, CFIA took action to mitigate risks to people with allergies. For example, 96 kg of cumin was relabelled with a precautionary statement regarding the presence of peanut. CFIA continues to follow up on cases of non-compliance where necessary.
Compliance and enforcement
CFIA takes a strategic, consistent, fair and transparent approach to compliance and enforcement actions and decisions. CFIA takes these actions using CFIA's Compliance and Enforcement Continuum, which allows for a range of responses, including compliance promotion, compliance verification, regulatory response, and recourse and feedback mechanisms.
A variety of compliance promotion products and services are available from CFIA to help industry understand and follow the acts and regulations that are administered and enforced by CFIA that apply to them. These include the industry labelling tool, traceability interactive tool, the Automated Import Reference System, and industry guidance for combatting food fraud.
CFIA conducts inspections to verify that regulatory requirements within its mandate are met. These are prioritized based on risk, taking into account factors such as the types of activities a regulated party conducts and its compliance history. When regulatory requirements are not met, CFIA may use control actions to address any immediate risk, as well as enforcement actions once non-compliance has been determined.
CFIA publishes the outcome of enforcement activities. It does this as part of its commitment to openness and transparency, as well as to increase awareness and deter non-compliance.
Enforcement actions are guided by the Standard Regulatory Response Process and are considered on a case-by-case basis. They take into consideration the harm caused by the non-compliance, the compliance history of the regulated party and whether there is intent to violate federal requirements.
When a CFIA inspector determines that federal requirements enforced by CFIA have been contravened, CFIA has the authority to remove, seize, detain and/or dispose of food products that do not meet Canadian requirements. Where warranted, non-compliant food products are disposed of in a safe manner, thereby preventing their entry into the Canadian marketplace.
CFIA may also impose administrative monetary penalties and issues notifications of charges laid to inform the public when charges have been laid. When a conviction is obtained, the CFIA issues prosecution bulletins.
As part of the 2020 to 2021 fiscal year targeted surveillance of honey, fish, olive oil, other expensive oils and spices, inspectors followed up on non-compliant samples to determine where the non-compliance originated in the supply chain. Appropriate action was taken on regulated parties when necessary, as outlined in the summary for each commodity.
In addition, in 2020 to 2021 fiscal year, there were 4 notifications of charges laid for violations related to food misrepresentation. While these charges do not stem from the surveillance strategies presented in this report, they are the result of CFIA activities to address misrepresentation beginning in previous years.
These charges for non-compliance included misrepresentation of the following:
- extra virgin olive oil sold in a format that was false, misleading or deceptive or is likely to create an erroneous impression regarding its character, value, composition, merit or safety
- previously frozen fish sold as "fresh"
- beef falsely sold as "certified organic"
- American lobster packaged and sold in a manner that was false, misleading or deceptive regarding its origin
Of these 4 notifications, 3 resulted in convictions, with a total fine amounting to CAD 560 000. One notification is still pending court decision.
Collaboration and engagement
During 2020 to 2021, CFIA continued to work with domestic and international stakeholders and partners to improve its ability to address food fraud. This engagement plays an important role in prevention, and includes the following:
- leading a working group with industry and academia
- sharing information with industry, other government departments and jurisdictions
- exploring best practices with international partners
- working with academia to identify misrepresentation, discuss better ways to test for substitutions, and share information and scientific research
- looking at innovative solutions to combat food fraud, specifically new technologies
- raising awareness of food fraud and encouraging others to play an active role in addressing the issue
Collaboration and engagement with others supports CFIA work in a number of ways. For example, in 2020 to 2021 fiscal year, non-governmental organizations met with CFIA to discuss the results of independent surveys on fish substitution, and these findings, along with other data, inform CFIA activities. When CFIA speaks with industry associations, as was done in 2020 to 2021 fiscal year with a number of sectors including the retail, spice, fish and honey sectors, CFIA promotes compliance with food regulatory requirements and also hears insights about industry sectors and supply chains, which can also guide its work.
CFIA works with Canadian provinces and territories on activities to prevent and take actions against food fraud, and will continue to do so. For example, in 2020 to 2021 fiscal year, CFIA engaged with the Ministère de l'Agriculture, des Pêcheries et de l'Alimentation du Québec to obtain samples in Quebec for the delivery of the fish species surveillance strategy on behalf of CFIA.
CFIA partners with Health Canada, which supports CFIA through research, environmental scanning, method development and risk assessment related to potential human health risks. These activities are funded by the investment under the Food Policy for Canada.
Along with Agriculture and Agri-Food Canada, and Fisheries and Oceans Canada, CFIA engaged industry and industry associations, non-government organizations, academia, other levels of government and the general public on the Minister of Health's 2019 mandate letter commitment regarding boat-to-plate traceability, which relates in part to protecting consumers from fish and seafood misrepresentation. CFIA and partner government departments published a discussion paper to inform approaches to address fish misrepresentation in Canada, as well as other topics.
CFIA has also contributed to international efforts. Along with 82 other countries, CFIA participated in the Operation OPSON IX, a Europol/INTERPOL joint operation targeting fake and substandard food and beverages. Under the food fraud initiative, Canada was able to participate in Operation OPSON for the first time, and OPSON IX results were released in the 2020 to 2021 fiscal year.
Also at the international level, Canada is a member country of the Codex Alimentarius Commission and is actively involved in developing international food standards and guidelines. Canada actively participates in various Codex committees that contribute to health protection and fair practices in the trade of food, including:
- Codex Committee on Food Labelling
- Codex Committee on Fats and Oils
- Codex Committee on Spices and Culinary Herbs
- Codex Committee on Food Import and Export Inspection and Certification Systems, which has an electronic working group on food fraud
CFIA actively raises awareness about food fraud in Canada. For example, CFIA published an ad campaign during the COVID-19 pandemic on e-commerce that included information about food fraud with respect to products bought or sold online. CFIA also conducts public opinion research to measure Canadians' awareness and to better understand the needs and concerns of the public and industry in order to improve its programs and services.
Information sharing and awareness building is also accomplished through various means, such as news releases, social media posts, articles and videos. CFIA specifically focuses on industry communications with notices to industry and email notifications.
CFIA also offers interactive food labelling tools to help consumers better understand food labels and labelling requirements. If consumers have a safety concern, such as an unlabelled allergen, or have reason to believe a label is false or misleading, they can report it to the CFIA.
CFIA is committed to carrying out risk-informed activities to protect people in Canada from deceptive practices and to contribute to a fair marketplace, with a focus on continuous improvement. This includes risk-based inspection and surveillance of high-risk food commodities.
The results of the sampling and testing for honey, fish, olive oil, other expensive oils and spices will be used to inform future efforts, identify areas of high risk, and plan future inspection, compliance promotion and guidance work.
To strengthen collaboration and engagement and to help industry protect itself from food fraud, CFIA will continue to build domestic and international networks relating to its mandate and further explore information-sharing arrangements. CFIA will also engage industry to reinforce its responsibility to comply with regulatory requirements and leverage opportunities and partnerships with industry, academia, and others to collectively address food fraud.
As the pandemic progresses, CFIA continues to monitor for new and emerging food fraud risks and will apply effective strategies to protect Canada's food supply as necessary.
Combatting food fraud in Canada is a shared role of government, industry, and consumers.
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