An Assessment of the 2024 Food Crime Strategic Assessment

The National Food Crime Unit (NFCU) and Scottish Food Crime & Incidents Unit (SFCIU) jointly prepared and recently published their assessment of what they believe are the major risks in terms of threats posed to the UK food system from food crime.

Probably not surprising to many people, but this is a document that I read and study with great interest. It’s been four years since the last assessment was published – way too long in my opinion – and an awful lot has happened in the interim.  So, the first point I want to make is why such a long  gap? If this is to be useful to the food industry, surely an annual assessment is required to help them modify and improve their resilience plans against fraud?  

My second point is that to produce a reliable assessment of food crime threats is an incredibly difficult undertaking. Fraud has been perpetrated in myriad different ways in just about every type of feed and food, and their individual ingredients. There are so many distinct products susceptible to rogues who want to exploit weaknesses in control systems and changes in the market environment. So having such an assessment published by regulatory agencies is hugely beneficial and this should be acknowledged. Many other countries in the world are not provided such information.

There will always be questions asked about the robustness of the methodology employed to determine the high priorities and my assumption is that the agencies used a combination of the intelligence they receive from a wide variety of sources in addition to their own investigations, as well as a good degree of horizon scanning. This is similar to the approach I use in my work and the only additional resource I use is AI modelling of global trends in food fraud. As government agencies work through how best to exploit the benefits of AI, I would guess the next food crime assessment will incorporate some form of machine learning to aid the risk assessment processes.

Risk assessments also involve balancing the likelihood of an event against the impact the event will have. There is clear evidence, as far as I can determine, that this is how the agencies have produced some of their highest risk categories. Correctly, in my opinion, the potential impacts to human and animal health figure strongly in the report and the current risks to both are well articulated.

While sometimes the risks of fraud are obvious, often they are not. I listened to a particularly good presentation from a member of the NFCU recently who outlined a case in the south of England where a company was importing poultry meat and claiming it was of UK origin. So, what is the big health risk here? The company was forging laboratory certificates to say the products had been tested for Salmonella and were all clear – the result of which was fines of over £50,000 to the rogue company; not high enough in my book but at least it serves as some form of punishment and deterrent.

If I compare my ‘high risk’ food categories with those contained within the report, there is strong alignment. They include the growing amount of meat products being smuggled into the country or coming in with false certification, massive issues with the adulteration of various types of vegetable oils, and the ever-increasing adulteration of different herbs and spices. All these are serious and pose significant risks to health.

It is fair to say that most of the cheating occurs with food imported into the UK but as the assessment clearly points out, there is often a need for bad actors in UK food companies to help cover up the fraud and aid in the sale and distribution of the tainted goods.

I regularly read reports from various government agencies, DEFRA comes to mind—where what is written has a degree of spin to indicate all is well. I found the joint NFCU and SFCIU assessment to be a very accurate and honest view of the current situation. The US Government uses the Defense Readiness Condition (DEFCON) scale of 5 to 1 in terms of severity of risks to the country (with 1 being the highest alert level).

My reading of the current assessment is that we have moved the UK Food Crime DEFCON alert level from 3 to 2 over the past four years, owing to greater threats due to changing times and overall worsening national and global conditions. Our government and feed and food industries need to understand this and continue to think of food crime as a serious threat to UK security and consumer health, and provide the required resources to combat the ever growing risks.