By Allison McLeod, technical scheme lead, Quality Assurance International
According to the Organic Trade Association, organic product sales continue to trend upward, with consumer demand fueling $71.6 billion in sales in 2024 (a 5.2% increase from 2023 and double the growth rate of the total food marketplace). Greater demand, however, also results in increased opportunities for fraud.
Recent analysis by Quality Assurance International (QAI), an NSF company and organic certification body, has identified food fraud in eight specific categories of food ingredients that are particularly vulnerable to fraudulent practices, underscoring the need for robust, secure supply chains and third-party verification.
The Organic Fraud Landscape
The organic industry is no longer the niche market it was several decades ago. To support growing demand across multiple demographics and locations, retailers and manufacturers are relying on complex and intricate international supply chains.
This growth has increased financial incentives for bad actors to misrepresent and market conventional products as organic.
To better support the industry in identifying higher-risk ingredients, QAI completed a rigorous evaluation of sources, including USDA Agreements and Decisions, the National Organic Program (NOP) Enforcement Dashboard, Fraudulent Organic Certificates, Annual Oversight and Enforcement Reports, and the Organic Integrity Database, which lists suspended and revoked farms and businesses.
The analysis revealed patterns in vulnerability and specific categories that may face verification challenges, complex supply chains or significant price differentials, creating a market ripe for food fraud.
High-Risk Organic Ingredient Categories
QAI identified the following high-risk categories for organic food fraud:
- Grains and oilseeds
This category includes corn, soybeans, wheat and oils such as sunflower, flax, and canola, particularly those imported from Eastern Europe, the Black Sea region, or Asia. North America consumes more organic grains and oilseeds than it produces. The sheer volume of imports, combined with complex international supply chains and price premiums, creates significant verification challenges. Recent USDA investigations have uncovered instances of conventional grain being “laundered” through multiple handlers and falsely sold as organic. - Animal feed inputs
Based on reports from 2021 and 2022, NOP complaint trends demonstrate an increased focus on livestock feed fraud and origin documentation. The organic livestock sector relies on verified organic feed; however, inputs such as alfalfa, soybean meal, corn gluten, and feed premixes are frequently under-tested and fraudulently labeled. Unlike row crop farms, most organic livestock and poultry producers don’t grow their feed, making them reliant on certified suppliers. Feed often represents the most significant cost component for producers, creating economic pressure that can lead to cutting corners. - Spices and botanicals
High-value spices, such as turmeric, black pepper, cumin and ginger, from India, Southeast Asia, and the Middle East frequently appear in enforcement actions. The fragmented nature of production, with thousands of small producers feeding into consolidated processing facilities, makes verification particularly challenging. Additionally, testing limitations for residues in dried materials can hinder detection. - Sweeteners
Honey, agave syrup, and cane sugar are especially susceptible to adulteration and mislabeling, mainly when imported. For example, organic honey commands a significant premium, yet verification of bee forage areas and testing for prohibited treatments present unique challenges for certifiers. - Juice concentrates and dried fruit
The processing steps involved in concentrates and dried fruits imported from Turkey, China, and South America create opportunities for comingling or substitution that can be difficult to detect solely through testing. - Livestock inputs and animal-derived products
Dairy, eggs, and frozen meat products present verification challenges related to the organic status of feed and compliance with pasture requirements. The seasonality of pasture access and challenges in verifying feed sources across extended periods and borders create vulnerability gaps that can be exploited. - Processed imports
Ingredients such as soy lecithin, glycerin, cocoa derivatives, and flavor extracts often involve opaque international supply chains with multiple processing steps. NOP Fraudulent Certificate Listings typically include “organic processors” with revoked certifications that continue to issue documentation. - High-value specialty crops
Hemp/CBD, aloe vera, chia, flax, medicinal mushrooms, and other specialty crops used in supplements or wellness products carry high fraud incentives due to their premium pricing. The relatively new market status of many of these ingredients means verification systems may not be as robust as those for more established organic crops.
The Strengthening Organic Enforcement Rule
The implementation of the USDA’s Strengthening Organic Enforcement (SOE) Rule in 2023 marked a significant step forward in addressing vulnerabilities to food fraud. Requirements for improved recordkeeping, mandatory certificates for each transaction, unannounced inspections, and fraud prevention procedures are already enhancing traceability throughout the organic supply chain.
QAI has observed that clients who proactively implement robust SOE compliance systems have identified and addressed potential vulnerabilities in advance. This proactive approach can help reduce risks and the need for corrective actions due to certification issues or product recalls. The rule’s import certificate requirements have been particularly effective in creating accountability for foreign suppliers.
Practical Strategies for Mitigating Fraud Risk
The following strategies can be used to mitigate risk when sourcing high-risk ingredients:
- Implement robust supplier verification processes that extend beyond certificate checking, including periodic supplier audits, thorough documentation reviews, and targeted testing programs.
- Develop ingredient specifications that include not just organic status but also quality parameters that may indicate authenticity.
- Utilize technology solutions, such as NSF’s TraQtion platform, to maintain real-time visibility into certification status, testing results, and traceability documentation.
- Establish testing protocols designed explicitly for high-risk ingredients, focusing on residues or markers that may indicate the use of conventional production methods.
- Build direct relationships with ingredient suppliers and certification bodies to enhance communication and minimize fraud in extended supply chains.
- Participate in industry information-sharing initiatives to stay informed about emerging fraud risks and detection methods.
The Path Forward
As the organic industry continues to grow, maintaining consumer trust through supply chain integrity becomes increasingly critical. The identification of high-risk ingredients represents not a crisis but an opportunity to strengthen verification systems and demonstrate the industry’s commitment to authentic organic production.
Through intentional collaboration, the industry can ensure that the organic label continues to represent the gold standard in sustainable, transparent food production.
Allison McLeod is a Technical Scheme Lead at Quality Assurance International (QAI), an NSF company and leading provider of organic certification services worldwide. McLeod has played a crucial role in supporting fraud prevention protocols for complex global supply chains.
