Issue #43 2022-06-20
More Wonka counterfeits, how dry cereals can make you sick, how to solve labelling problems caused by supply shortages, making peanut butter
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More counterfeit Wonka Bars - why this is just the tip of the iceberg
How do dry cereals like Lucky Charms and Cheerios make people sick?
Food supply crunch: how to deal with label change challenges
Just for Fun: How Peanut Butter Is Really Made (a Humorous Video)
Food fraud incidents and horizon scanning updates from the past week
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In this week’s issue, Issue #43 of The Rotten Apple, I can’t resist saying “I told you so!” after more counterfeit chocolate bars were seized in England. I think this is - unfortunately - just the tip of the iceberg, and I explain why below.
Also this week, I describe six possible scenarios to explain the alleged links between dry, ready-to-eat breakfast cereals and thousands of illnesses in the USA. Plus, suggestions for how to deal with ingredient list changes due to supply chain shortages.
Finally, a slightly silly and possibly offensive video that shows how peanut butter is really made.
As always, food fraud incidents and horizon scanning news are included for paid subscribers.
Have a great week, I hope you can stay cool (if you’re in Europe),
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Totally Not Surprising… More Counterfeit Wonka Chocolate Bars
Here’s where I get to say…. “I told you so”, albeit with a sad smile.
In April I warned there was a food safety risk from undeclared allergens in counterfeit Wonka chocolate bars. Then last month, a British man who was caught selling the bars pleaded guilty and the court heard some concerning evidence:
- He had he been caught and prosecuted for doing it before, and
- he had been officially warned about the allergen risks from the products at least SIX times previously.
Sad to say, his food fraud act was not a one-off… not for him, and not on a global scale.
While researching that story last month, I discovered that online candy stores in my country and elsewhere were also selling Wonka chocolate bars. I mused on social media that the products are probably being manufactured in large quantities in a single, sophisticated operation and distributed to multiple countries globally.
My basis for that claim? The equipment needed to wrap chocolate bars in genuine-looking food packaging is expensive to purchase and operate. The packaging film/wrap is also expensive and can usually only be ordered in very large print runs.
Want to see what the products look like? This BBC news report includes a close-up photograph of the Wonka bars that were confiscated last week. (I can’t display it due to copyright rules). The bars in the photograph look professionally produced, with expensive, glossy foil-paper wrap.
The cost of production means that if you want to make counterfeit chocolate you must make a significant upfront financial investment. And, for the exercise to be worthwhile, you need to make – and sell! - an awful lot of chocolate bars to make a profit.
This is not the sort of product you can put together on your kitchen bench.
As I feared, the seizures earlier this year were just the tip of the iceberg. Last week, more Wonka bars were seized, when candy shops in London were raided by the British trading standards office which confiscated food products worth £100,000, including “fake” Wonka bars.
Why does this matter?
The counterfeit bars were made or repackaged “by unregistered businesses… who could be bypassing food hygiene, labelling and traceability laws.” (United Kingdom Food Safety Agency (FSA).)
Counterfeit bars can contain allergens that are not listed on labels.
There appear to be many more outlets selling the same types of counterfeit chocolate products.
The FSA warns consumers that Wonka-branded chocolate that doesn’t carry a Ferrero trademark on the label should be treated as suspect.
If a food safety problem does arise from unauthorised chocolate bars made by unregistered business(es) then a successful recall would be extremely difficult or impossible. Without a successful recall, dangerous products remain circulating in the community, exposing more people to contaminated or allergen-containing food.
In short: 🍏 Authorities claim that unauthorised Wonka chocolate bars can contain undeclared allergens 🍏 Bars seized in the United Kingdom were manufactured by an unregistered business, which might not be following food safety or traceability protocols 🍏 There are probably many tens of thousands more bars in circulation globally 🍏 This could cause major food safety problems, which would be difficult to mitigate due to a lack of traceability 🍏
Lucky Charms and Cheerios, Part Two – How Could They Make People Sick?
Dry breakfast cereal is allegedly making people (thousands of people!) sick in the USA, as I mentioned last week.
This week, I put on my food scientist hat to dive into the possible causes.
In an attempt to keep this brief, what follows is a not-at-all in-depth discussion of six possible causes.
One. There is no causal link between the cereals and the illnesses
The illnesses could be caused by something other than the cereal, but since so many people eat these cereals they are blaming the cereal.
For example, one person who posted on an online illness reporting site didn’t decide that her illness was caused by breakfast cereal until she heard about other people getting sick: “Reporting nausea and vomiting from a double pack of Honey Nut Cheerios …. I’m currently pregnant so I thought nothing of it at first but it traces back to the [last] few times I had this cereal”
Two. There is a microbiological problem with the cereal
Viable cells of bacteria or fungus could be present in the cereal pieces, although this is unlikely. Lucky Charms and Cheerios are both made using a process called extrusion, followed by drying or baking. Extrusion and baking will reliably kill all vegetative bacterial cells, moulds and viruses, although not necessarily spores of bacteria or mould.
For live bacteria or mould pathogens to be present at infective numbers – levels enough to make you sick – the manufacturer would have had to hold the extruded (damp) cereal for more than four hours before baking it. Even then, you would need to start with severely contaminated material for enough growth to occur.
Post-baking contamination is possible, but this would require pretty severe mishandling to result in infective doses of bacteria - such as Salmonella - on the cereal. Contamination with a food-borne virus is more likely.
The food-borne virus norovirus is one of the most infective agents known to man and just a few viral particles can cause illness. For example, in 2011, a single source of contamination – possibly one infected food handler - caused 11,000 norovirus illnesses in Europe. Enteric viruses can survive on low moisture foods, including cornflakes, for at least four weeks.
So, norovirus contamination is possible, noting that the contamination would have to occur after baking. It’s also worth noting that it is extremely difficult to isolate viral particles from foods. This means it would be very difficult to find “the smoking gun” if a food-borne virus like norovirus was the cause.
Three. There are microbiological problems with the marshmallow pieces
Lucky Charms contain small marshmallow pieces. The marshmallows could have a microbiological problem. However, this theory does not explain the links between the illnesses and Cheerios, which do not contain marshmallow pieces.
Four. There are natural toxins in the products
Natural toxins are produced by microorganisms such as bacteria, moulds and algae. In a cereal product, the most likely class of natural toxin is a mycotoxin, because these can occur in grains like oats and corn. Both of the affected cereals, Lucky Charms and Cheerios, contain oats, making mycotoxin a good candidate.
A bacterial toxin is less likely to be present than a mycotoxin, although the heat-stable Staphylococcus aureus toxin might be able to survive the baking process. This toxin causes nausea, vomiting and stomach cramps within a few hours of eating contaminated food, which matches some of the victims’ symptoms. For it to be present in the cereal, the unbaked product would need to have been wet enough for the bacteria to grow and make the toxin. This seems unlikely because grains are usually fed into an extruder in a dry(ish) format.
Five. There are man-made chemical toxins in the product(s), by accident
Lucky Charms contain four artificial colours, including two that have been linked to health problems by some groups. An accidental overuse of one of those colours might have caused problems for some consumers.
Some food safety specialists have speculated that a change of source for one of the colours, or even a fraud problem with one of the colours could cause a chemical contamination event.
Interestingly, the maker of both products, General Mills, said in March that it was having problems acquiring ingredients and that it had to find new sources of some ingredients.
“We’ve adjusted formulations,” said John Nudi, the company’s president of North America retail. “In some of our products, we’ve reformulated over 20 times year to date. Every time you make an ingredient change, you have to change the formulation.” (as quoted in the New York Post)
Fraudulent food colourants could definitely cause problems. There is a long-established history of poisonous and cancer-causing textile dyes being used illegally to colour spices including paprika and turmeric.
A fraud problem in one of the colourants would affect multiple batches of Lucky Charms but doesn’t explain why Cheerios are being linked to the outbreak, since they contain no artificial colours.
Pesticide contamination of the oats used in both products could be a source of accidental chemical toxins and this would also affect multiple batches of both products. However, I judge this scenario unlikely, because you would need a seriously large overdose of pesticide within any given shipment of oats to cause acute symptoms like those that are being reported.
Six. Deliberate contamination with chemical or biological agents
This is a nasty scenario to consider, but one that the authorities are no doubt investigating right now. They will be asking (a) What type of contaminant could cause these symptoms? (b) How much contaminant needs to be present to cause these symptoms? (c) How could that amount be added to the products – that is, where in the production process would such addition be possible? (d) Who would be able to perpetrate such adulteration during multiple production runs without being detected?
In short: 🍏 There are multiple possible ways for dry breakfast cereal to make people sick 🍏 The most probable scenario is post-baking contamination with norovirus or another food-borne enteric virus 🍏 Other possibilities cannot be ruled out, including the possibility that these cereals are not actually causing the illnesses at all 🍏
Norovirus outbreak: https://link.springer.com/article/10.1007/s12560-013-9118-0
Viruses on low moisture foods: https://link.springer.com/article/10.1007/s12560-020-09457-7
More weird facts about Lucky Charms: https://www.mashed.com/204843/the-untold-truth-of-lucky-charms/
Food Supply Chains
Food supply crunch; how do you deal with labelling when reformulating in a hurry?
Okay, so we all know there are shortages of all types of foods and agricultural commodities right now. But what do you do if an ingredient you need for your food business is unavailable?
You can’t just switch to an alternative ingredient, without also updating your food label or menu information. At least you are not legally allowed to!
If you reformulate your food, you need a new ingredient list. And that means a new label.
Creating, ordering, printing and receiving new label stock takes a long time. When I worked in food product development in the 1990s, label production was our longest development timeframe and the one that caused the most angst for the marketing gals and guys. It took three full months to receive printed packaging films to our factories after the ingredient lists were approved.
On top of that, label changes cost our company a fortune, particularly if old printed stock had to be discarded.
So food businesses everywhere are struggling with the need to reformulate their products… not just because reformulating can be difficult, but because of the labelling challenges and costs.
Some countries are allowing some ingredients to be substituted without changing ingredient lists. These are only for specific ingredients that are deemed low risk from a food safety perspective.
For example, certain edible oil substitutions were legally approved in the United Kingdom earlier this year. Food manufacturers and food service businesses in the United Kingdom were permitted, from 24th March to substitute refined rapeseed oil for sunflower oil in their products without updating their labels. That was later expanded to include fully refined soybean oil, fully refined palm oil and fully refined coconut oil.
In other places, food companies are over-stickering their current labels. Some countries allow this under normal circumstances, and others have made special exemptions to allow it.
For example, Irish authorities have recently decided to allow food manufacturers to over-sticker their ingredient lists if they have had to reformulate due to food shortages.
Other countries, including France, are allowing food companies to apply for exemptions to labelling rules.
What to do
Check for updates to food labelling rules for all the countries your products will be sold into. A trusted food regulatory specialist lawyer can help.
Use exemptions; apply stickers over old labels; or apply for special approvals if such mechanisms are available.
Going forward, check whether any of your ingredient lists can be amended to make use of broader nomenclature. For example, if allowed, you might change an ingredient listing from “Sunflower Oil” to “Blended Vegetable Oils”. Such changes will allow more flexibility when supplies of one ingredient fail. Note that this might also need to be accompanied by new on-pack allergen information.
Just for Fun
How Peanut Butter is Really Made
This video contains weird passive-aggressive humour 😊. It also contains at least one f-bomb and isn’t a 100% accurate representation of peanut butter manufacturing processes.
You have been warned!
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