181 | Food Fraud's Links to Animal Welfare | Regenerative Ag |
Plus, the guy who decides Use-by dates
Animal welfare claims and food fraud;
Food Safety News and Resources;
What is regenerative agriculture, actually?;
The guy who decides Use-by dates;
Food fraud news special: EU Agri-food suspicion reports unpacked.
Hi lovely readers,
Thank you to everyone who signed up last week, welcome to our global food safety community, and a big shoutout to ๐๐ Robyn and Susan ๐๐ for upgrading to paid subscriptions and to ๐๐ Sam, Emily and Rani ๐๐ for renewing your subscriptions - I couldnโt do this without readers like you.
Welcome to Issue 181 of The Rotten Apple where I explore the links between animal welfare and food fraud in the context of ablation-free shrimp raising. I didnโt know what shrimp ablation was until recently, and now I kind of wish I still didnโt.
Also this week, what (exactly) is regenerative agriculture, and does it actually work? Plus a dose of Aussie humour from the guy who decides Use-by dates and a long food fraud news section, as I unpack recent EU reports to separate the useful information from the noise.
Thanks for being here,
Karen
P.S. Technical difficulties galore this month! If youโve had trouble with the credit card processor while trying to get a paid subscription, reach out to me directly by replying to this email and I will send an alternative payment method.
Food fraudโs links to animal welfare
Positive welfare claims are a double-edged sword
We all love to imagine the animals we eat have had happy lives strolling in green fields or swimming in sparkling oceans before they ended up on our plates. But those of us whoโve seen the conditions some food animals endure know better.
Consumers, too, are increasingly aware of the welfare issues in animal food productionโฆ issues like tiny cages in egg-laying operations, sow stalls and farrowing crates in pig farms, heat stress in cattle feedlots and diseases in fish farms.
We care about the animals we eat, and some of us seek out foods that have been produced with animal welfare considerations. Foods likeโฆ
Pasture-raised chickens,
Grass-fed beef,
Sow-stall-free pork,
Wild-caught salmon,
Free-range eggs,
No doubt youโve heard of these foods produced with animal welfare considerations.
But you might not have heard of this one: ablation-free shrimp. I heard about it for the first time last week. If youโre a paying subscriber you might have seen my food fraud horizon scanning note about it.
Ablation-free shrimp are farmed shrimp that have been raised without being subject to the (frankly horrific-sounding) practice of eyestalk ablation. This month a major British retailer made a commitment to use only ablation-free shrimp in its products from now.
This is great news for shrimp, right? But itโs perhaps not such good news for consumers and ethical business owners. Because welfare claims for animal food are an opportunity for criminals to profit.
Eyestalk ablation involves removing one or both eyestalks from female prawns to stimulate ovarian development and increase egg production. It has been widely used in the shrimp aquaculture industry since the 1970s.
The process typically involves cutting off one eyestalk using scissors or razor blades, which can result in the female prawn laying up to ten times more eggs, perhaps because of the presence of hormone secretion glands in the eyestalks which prevent ovarian development when shrimp are kept in captivity.
The procedure is often performed without anaesthesia. Yeowch. Non-ablation shrimp farming is more expensive because larger broodstock populations and more resources are required.

The problem with welfare-related claims like ablation-free or grass-fed is that they are impossible for consumers to verify. Such trust-based claims are often called โcredence claimsโ.
Consumers expect to pay more for foods with welfare claims. Free-range eggs in Canada, for example, were 70% more expensive than cage eggs in 2022.
When consumers and customers pay more for foods with credence claims, this creates food fraud vulnerabilities. There have been countless incidents in which unscrupulous egg sellers have supplied cage eggs labelled as free-range, like one in Australia which resulted in a $300,000 penalty for the supplier, and one in Singapore in 2021.
The same vulnerabilities apply to grass-fed beef, wild-caught salmon and now, perhaps, ablation-free shrimp.
So, if such shrimp are vulnerable to false claims, does that mean I donโt think the major British retailer will stay true to their word about the welfare status of their shrimp? Not at all.
I trust that retailer because they have a valuable brand and they risk damaging it if they are caught misleading consumers. They also have enough technical resources and expertise to keep a close eye on their supply chain.
If big brand retailers are not likely to commit food fraud with false animal welfare claims, which businesses are likely? Which places are most likely to supply - for example - traditionally raised shrimp with ablation-free claims?
We donโt know, of course - thatโs the nature of food fraud - but other seafood frauds have typically been more prevalent in independent restaurants and small stores compared to major retailers and big brands (like in this study), noting small outlets may themselves be the victims of fraud by their suppliers.
A final difficulty is that foods marketed with false claims about animal welfare are rarely targeted by authorities for enforcement because they donโt represent as great a risk to food safety as other fraud-affected foods.
Takeaways for food professionals
Credence claims, which include animal welfare claims, greatly increase the vulnerability of a food to food fraud.
Food frauds in which the perpetrator labels a conventionally-raised animal food with a special welfare claim like free-range or grass-fed are high profit, easy to perpetrate, and, when the customer is a business with few technical resources, or a consumer, unlikely to be detected. These factors make such frauds attractive to criminals.
Potential frauds like this are rarely the subject of official investigations or enforcement actions because resources are mostly directed towards frauds that can pose food safety risks.
In short ๐ Animal welfare claims are easy to โfakeโ and difficult to detect, making them attractive to food fraud perpetrators ๐ Foods supplied by major retailers with valuable brands and technical resources are less likely to be affected by false claims related to animal welfare than small, independent outlets and restaurants ๐
Sources:
All sources for this article have been hyperlinked within the body of the text.
Food Safety News and Resources
Thereโs a fantastic resource for senior managers, directors and company board members, called Food Safety Good Governance Guide for Directors in this weekโs food safety news. Plus produce safety researchers are looking for your input to assist with their research. And more.
Click the preview below to read.
Regenerative agriculture - what is it exactly?
Earlier this month, the UK government commissioned work to define and describe regenerative agricultural practices, saying they are poorly understood and โsocial and economic aspects of regenerative agriculture remain uncertain.โ
In this article, I share what you need to know about it in 2025.
What is regenerative agriculture?
Regenerative agriculture was a hot topic a few years ago, as large companies such as General Mills and McDonalds started issuing press releases about their commitments to sustainability through the lens of regenerative ag.
But itโs been a few years since Iโve heard much about regenerative ag in international food news. Guess weโve been too worried about rising costs and tariffs lately.
Now, the UK government has committed to investigating its benefits, seeking submissions from interested parties until the 6th of April 2025. With that in mind, I decided to provide you with a quick primer.
Regenerative agriculture is the practice of farming crops and animals in a way that restores soils that have been degraded by past agricultural practices. Strategies such as adaptive grazing, no-till planting and careful selection of fertilisers are often mentioned in the context of regenerative agriculture.
Adaptive grazing is the management of livestock grazing patterns based on environmental conditions and plant recovery needs. High-density, short-duration grazing is interspersed with pasture rest periods with the aim of improving soil health, biodiversity, and overall ecosystem function.
With no-till planting, crops are sown directly into undisturbed soil without tilling, with the aim of preserving soil structure and organic matter, reducing erosion, increasing water retention, and supporting beneficial soil microorganisms.
In regenerative agriculture, fertiliser selection strategies include minimising synthetic inputs, using soil tests to determine precise needs to reduce overdosing, and prioritising natural and organic inputs.
Is regenerative ag just about soil health?
Depends on who you ask.
The World Economic Forum says โRegenerative agriculture focuses on improving the health of soil, which has been degraded by the use of heavy machinery, fertilizers and pesticides in intensive farming.โ (source).
However, General Mills includes social and economic elements in their definition of regenerative agriculture, saying โItโs a holistic, principles-based approach to farming and ranching that delivers positive environmental, social and economic outcomes.โ (source)
Certification scheme owner Regenerative Organic Alliance says regenerative agriculture should also include elements of animal welfare and farmworker fairness while a different scheme (AGW) says regenerative certified operations must be managed in a socially responsible way.
Newton et. al (2020) reviewed 229 journal articles and 25 practitioner websites to characterize the term โregenerative agricultureโ and concluded that there were so many different understandings of the term that individual users should define it for their own purposes and contexts.
Does regenerative agriculture work?
It depends on what its aims are, the initial state of the land where it is practised and the methods used to achieve regeneration.
Regenerative agriculture practices can increase carbon sequestration in soils, and improve crop yields according to research published by the West Australian government but itโs harder to unravel the outcomes with respect to social, economic and animal welfare due to a lack of published comparable data. In addition, results from individual studies are highly dependent on the initial state of the land.
Soil sequestration of carbon appears to be the most well-researched area of regenerative agriculture, with one study (Poeplau & Don (2015)) showing that the use of cover crops can increase the amount of carbon in soil without decreasing yields and providing benefits that remain for up to 155 years.
Soil health and biodiversity appear to benefit from regenerative practices, at least in some soil types and climates (source, source). Animal welfare improvements may occur from regenerative agriculture due to an improvement in animal health but evidence is lacking (source).
Whether there are direct financial benefits from regenerative agriculture is context-dependent, with large yield increases reported in sub-Saharan Africa (source). Similarly, the lower production costs of no-till methods can provide financial benefits, even if yields are not improved, says the United States Department of Agriculture in a 2025 report.
Takeaways for food professionals
There is no universally accepted definition of regenerative agriculture.
Therefore, if your company wants to use claims about regenerative agriculture for products or ingredients, be sure to include your own context-specific definition, to avoid misleading consumers.
There is evidence that regenerative agriculture can provide better outcomes for the environment and for farmers than standard agricultural practices, however the results are context-dependent.
Sources
Newton, P., Civita, N., Frankel-Goldwater, L., Bartel, K. and Johns, C. (2020). What Is Regenerative Agriculture? A Review of Scholar and Practitioner Definitions Based on Processes and Outcomes. Frontiers in Sustainable Food Systems, [online] 4(1). doi:https://doi.org/10.3389/fsufs.2020.577723.
Other sources are cited inline using hyperlinks.
๐ More like this: More food with less farming - the regenerative ag debate | Issue 100 ๐
The Guy Who Decides Use-By Dates (Just for Fun)
If youโre up for some Aussie humour, youโll enjoy this video by comic Jimmy Rees.
He doesnโt always get the food science exactly right and references Australian rules, which are a little different from those in other countries, but I reckon youโll love it anyway. And itโs safe for work. Enjoy.
Below for paying subscribers: Food fraud news
๐ Food Fraud News ๐
Highlights from the recent EU monthly fraud suspicions reports
Every month the European Commission publishes the EU Agri-Food Fraud Suspicions report1 which lists food safety non-compliances that might be caused by food fraud.
The reports contain European information but often mention foods from outside Europe. They only pertain to cross-border issues, because within-country data is not usually shared by the networks that compile information for the reports.
The reports include food safety alerts that have been deemed โsuspiciousโ. The incidents listed in the reports are not confirmed frauds and the root causes are not published.
The data is drawn from the European Unionโs Rapid Alert System for Food and Feed (RASFF), with information shared by members of the Alert and Cooperation Network (ACN), the Administrative Assistance and Cooperation Network (AAC) and the Agri-Food Fraud Network (FFN).
EU Agri-Food Fraud Suspicions reports are among the dozens of sources I review each month looking for information that will help you with your knowledge of food fraud in specific commodities.
Another source I use is the European Joint Research Commission's (JRC)โs monthly food fraud reports, which contain completely different information, not drawn from official alerts but from international media.
I source other media reports and research papers too โ itโs surprising how many stories I find that havenโt appeared in the JRC report and vice versa.
The EU Agri-Food Fraud Suspicions reports typically include 200 to 300 separate alerts and are dominated by alerts for fruit and veg, mostly related to the presence of residues of pesticides illegal in the EU or higher than the EU limits.
As Iโve mentioned before, itโs likely that most of these fruit and veg non-compliances are accidental, with farmers in non-EU countries possibly unaware of the pesticide regulations in Europe.
In The Rotten Apple, I share incidents and alerts that reveal new information such as potential new hazards, new vulnerabilities and those that can provide information about the magnitude, frequency or types of frauds occurring for specific commodities.
With this in mind, I usually donโt feature alerts and incidents related to substandard quality of food, pesticide limit breaches, businesses trading without proper permits and seizures of goods for hygiene breaches. We all know these happen consistently and such information doesnโt add to the sum of our knowledge (plus they would waste your time by making my reports too long).
The past two EU suspicions reports contain a few items that merit attention and can be used to inform food fraud vulnerability assessments. Iโve listed these below. They include frauds in animal feed, live food animals and food contact items as well as in human food.
Perhaps unsurprisingly, since Iโve been flagging coffee and cocoa in horizon scanning reports for months, Februaryโs EU suspicions report2 includes fraudulently adulterated chocolate and robusta beans in shipments of arabica coffee.
Also notable, but not unusual, Januaryโs report lists multiple cases of apparent fraud in nutrition panel declarations and health claims including large discrepancies between the declared and actual protein contents and fat contents of various seafoods and meat products.
Sauces from the Netherlands were marketed with inflated nutri-score ratings, some supplements were found to contain significantly lower concentrations of vitamins than declared on the label and many supplements were flagged for having non-compliant health claims.
Notable items from the January report3 include:
Undeclared sugar, sweeteners and colourants in fruit juice from Vietnam
Beet sugar in wine from Italy
Faked "Prosciutto di Parma" ham from the Netherlands