food fraud in nigeria: challenges, risks and solutions

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Technological University Dublin Technological University Dublin ARROW@TU Dublin ARROW@TU Dublin Theses School of Food Science and Environmental Health 2020 Food Fraud in Nigeria: Challenges, Risks and Solutions Food Fraud in Nigeria: Challenges, Risks and Solutions Joy Ewomazino Opia Technological University Dublin Follow this and additional works at: https://arrow.tudublin.ie/sfehthes Part of the Computer Sciences Commons Recommended Citation Recommended Citation Opia, J. E. (2020). Food fraud in NIgeria: challenges, risks and solutions. Masters dissertation. Technological University Dublin. doi:10.21427/nm91-rk58 This Dissertation is brought to you for free and open access by the School of Food Science and Environmental Health at ARROW@TU Dublin. It has been accepted for inclusion in Theses by an authorized administrator of ARROW@TU Dublin. For more information, please contact [email protected], [email protected]. This work is licensed under a Creative Commons Attribution-Noncommercial-Share Alike 4.0 License

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Page 1: Food Fraud in Nigeria: Challenges, Risks and Solutions

Technological University Dublin Technological University Dublin

ARROW@TU Dublin ARROW@TU Dublin

Theses School of Food Science and Environmental Health

2020

Food Fraud in Nigeria: Challenges, Risks and Solutions Food Fraud in Nigeria: Challenges, Risks and Solutions

Joy Ewomazino Opia Technological University Dublin

Follow this and additional works at: https://arrow.tudublin.ie/sfehthes

Part of the Computer Sciences Commons

Recommended Citation Recommended Citation Opia, J. E. (2020). Food fraud in NIgeria: challenges, risks and solutions. Masters dissertation. Technological University Dublin. doi:10.21427/nm91-rk58

This Dissertation is brought to you for free and open access by the School of Food Science and Environmental Health at ARROW@TU Dublin. It has been accepted for inclusion in Theses by an authorized administrator of ARROW@TU Dublin. For more information, please contact [email protected], [email protected].

This work is licensed under a Creative Commons Attribution-Noncommercial-Share Alike 4.0 License

Page 2: Food Fraud in Nigeria: Challenges, Risks and Solutions

1

Food Fraud in Nigeria: Challenges, Risks and Solutions

Joy Ewomazino Opia

Msc. Food Safety Management

Submitted to Technological University Dublin, Cathal Brugha

Street, in partial fulfilment of the requirements of the Degree

of Science (Food Safety Management, DT9437)

Supervisor: Christine O’Connor

School of Food Science and Environmental Health

College of Sciences and health

Technological University Dublin

January 2020

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ABSTRACT

Food fraud is one of the most urgent and active food research and regulatory areas. It is an evolving

problem in Nigeria that has led to the deaths of many people especially the vunerable groups that includes

mostly children, the elderly and immunocomprised persons. Therefore the aim of this study is to

investigate the current challenges of food fraud in Nigeria, identify the risks it poses on the health and

wellbeing of Nigerians and propose measures to tackle food fraud at local and international levels by

regulatory and government agencies. This study explored the relationship between food fraud, food

security and the UN Sustainable Development Goals. This study is relatively new as it has never been

carried out before so it relied on information from previous research articles, journals and publications. A

total of 68 participants from the general public took part in this study and some key officers from the

National Agency for Food and Drug Administration and Control (NAFDAC) were interviewed to obtain

their opinions on the current state of food fraud in Nigeria.The findings revealed common foods being

adulterated in Nigeria are mostly fats and oils, alcoholic and non-alcoholic drinks and honey. Poverty,

corruption and poor food safety and control systems were identified throughout this study. The study

concluded by reviewing several policy framework and actions taken by the Nigerian government to proffer

solutions that can actualise the goals of the Sustainable Development Goals by 2030.

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DECLARATION

I hereby certify that this material, which I now submit in part fulfilment of the requirement for the award

of MSc in Food safety Management, is entirely my own work and has not been taken from the work of

others save and to the extent such work has been cited and acknowledged within the text of my work.

The thesis was prepared according to the guidelines for dissertation production in the MSc. Food Safety

Management and has not been submitted in whole or in part for an award in any other Institute or

University.

The Institute has permission to keep, to lend or to copy this thesis in whole or in part, on condition that

any use of the material of the thesis be duly acknowledged.

Signed

Date

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ACKNOWLEDGEMENTS

My sincere appreciation goes to God Almighty for the wisdom and idea in making this research study a

reality. May his name be praised.

I also like to thank my family for their prayers, encouragement and relentless efforts with my survey

questionnaire and interviews with regulatory officers from NAFADAC. Thank you so much for all your

assistance in making this research a success.

My profound gratitude to the Director General of NAFDAC for her timely intervention and permission to

collect data from her agency and to the staffs for their insights and wisdom in the course of this research

study. Your assistance has proved to be a milestone in the accomplishment of my end goal.

I am deeply grateful to all the participants who took part in my survey questionnaire. I acknowledge and

appreciate your help and support with my research work.

I wish to express my special thanks to my supervisor, Christine O’Connor for her contributions and support

towards this study. It is whole-heartedly expressed that your advices for my research proved to be a

landmark effort towards the success of my thesis.

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ABBREVIATIONS

AESAN Agencia Española de Seguridad Alimentaria y Nutrición

AFBE Association of Food, Beverage and Tobacco Employers

AFFCON Association of Fast Foods and Confectionaries Operators of Nigeria

APP Agriculture Promotion Policy

APHIS Animal and Plant Health Inspection Services

ATA Agricultural Transformation Agenda

ATWAP Association of Table Water Producers

BHA Butylated hydroxyanisole

CAC Codex Alimentarius Commission

CBN Central Bank of Nigeria

CFSAN Center for Food Safety and Applied Nutrition

CQP Coffee Quality-Improvement Program

DG SANCO Directorate General for Health and Consumers

DSS Department of State Services

EMA Economically Motivated Adulteration

EP European Parliament

EPA Environmental Protection Agency

EVOO Extra Virgin Olive Oil

EU European Union

FAO Food and Agriculture Organization

FCCPC Federal Competition and Consumer Protection Commission

FEC Federal Executive Council

FDA Food and Drug Administration

FIRS Federal Inland Revenue Service

FMARD Federal Ministry of Agriculture and Rural Development

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FMH Federal Ministry of Health

FSAN Food Safety and Applied Nutrition

FSIS Food Safety and Inspection Services

FT Fourier Transform

FTIR Fourier Transform Infrared

GAPs Good Agricultural Practices

GC Gas Chromatography

GC-MS Gas Chromatography-Mass Spectrometry

GDP Gross Domestic Product

GFSI Global Food Safety Initiative

GLC Gas-Liquid Chromatography

GHPs Good Hygiene Practices

GMPs Good Manufacturing Practices

GSC Gas-Solid Chromatography

HACCP Hazard Analysis and Critical Control Point

HICs High-Income Countries

HPLC High-Performance Liquid Chromatography

IAEA International Atomic Energy Agency

IEA International Energy Agency

IECT Information, Education, Communication and Training

IR Infrared

IR-MS Infrared-Mass Spectrometry

KFDA Korea Food and Drug Administration

LC Liquid Chromatography

LDA Linear Discriminant Analysis

LFN Law of the Federation of Nigeria

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LMICs Low and Middle-Income Countries

LOD Limits of Detection

MDGs Millenium Development Goals

MIR Mid-Infrared

MLR Multiple Linear Regression

MRM Mechanically Recovered Meat

MS Mass Spectroscopy

NAFDAC National Agency for Food and Drug Administration and Control

NAQS Nigerian Agricultural Quarantine Service

NASSI National Association of Small Scale Industrialists

NCSC NAFDAC Consumer Safety Club

NCDs Non-Communicable Diseases

NEPC Nigerian Export Promotion Council

NIR Near-Infrared

NIS Nigeria Immigration Service

NIPC Nigerian Investment Promotion Commission

NMR Nuclear Magnetic Resonance

OSIC One Shop Investment Centre

OMC O-Methylcafestol

OPEC Organization of Petroleum Exporting Countries

PARAFAC Parallel Factor Analysis

PCA Principal Component Analysis

PCR Polymerase Chain Reaction

PDO Protected Designation of Origin

PGI Protected Geographical Indication

PLS Partial Least Squares

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PMS Post Market Surveillance

POO Pomace Olive Oil

PV Pharmacovigilance

QUID Quantitative Ingredient Declaration

RASFF Rapid Alert System for Food and Feed

RMSEC Root Mean Squares Error of Calibration

RMSEV Root Mean Squares Error of Validation

SD Sustainable Development

SDGs Sustainable Development Goals

SFVs Street Food Vendors

SMEs Small and Medium-sized Enterprises

SON Standard Organization of Nigeria

SORS Spatially Offset Raman Spectroscopy

SPS Sanitary and Phytosanitary

TLC Thin-Layer Chromatography

TSG Traditional Speciality Guaranteed

US United States

USA United State of America

USDA United States Department of Agriculture

USFDA United States Food and Drug Administration

UV Ultraviolet

UV-Vis Ultraviolet Visible

WHO World Health Organization

WTO World Trade Organization

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Table of Contents

ABSTRACT

DECLARATION

Acknowledgements

Abbreviations

List of Figures

List of Tables

1. LITERATURE REVIEW

1.1 Introduction

1.2. History of Food fraud

1.3. Food Authenticity and Authenticity factors

1.3.1. Production method

1.3.2. Variety and species

1.3.3. Geographical origin

1.3.4. Genuiness

1.3.5. Shelf life

1.3.6. Labelling

1.4. Legal Framework

1.5. Analytical methods for the detection of food fraud

1.5.1. Chromatographic techniques

1.5.1.1. Gas Chromatography

1.5.1.2. High-performance liquid chromatography

1.5.2. Spectroscopy techniques

1.5.2.1. UV-Vis spectroscopy

1.5.2.2. Fluorescence spectroscopy

1.5.2.3. Infrared spectroscopy

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1.5.2.4. Nuclear magnetic resonance spectroscopy

1.5.3. Stable isotope analysis

1.5.4. DNA-based methods

1.5.5. Examples of spectral data for various food products

1.6. Sustainable Development Goals (SDGs): An overview

1.7. Nigeria: An overview

1.8. Aims and objectives

2. METHODOLOGY

2.1. Data collection

2.2. Interview questions

2.3. Survey questionnaire design

2.4. Data analysis

3. FOOD FRAUD – CURRENT STATUS IN NIGERIA

3.1. Food smuggling and trafficking

3.2. Street food practices

3.2.1. Sources and quality of raw foods and ingredients

3.2.2. Food preparation, handling and vending

3.2.3. Vending environments

3.2.4. Hygiene practices

3.2.5. Agricultural practices

3.3. Nigerian food fraud incidents/fradulent commodities

3.4. Food control systems

4. FOOD SAFETY LEGISLATION IN NIGERIA

4.1. Regulatory and legislative framework

4.2. Key actors in regulating and monitoring of food safety standards and practices

4.2.1. The Federal Ministry of Health (FMH)

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4.2.2. The National Agency for Food and Drug Administration and Control (NAFDAC)

4.2.3. Standards Organization of Nigeria (SON)

4.2.4. The Federal Ministry of Agriculture and Rural Development (FMARD)

4.2.5. Nigerian Agricultural Quarantine Service (NAQS)

4.2.6. Federal Competition and Consumer Protection Commission (FCCPC)

4.2.7. The Federal Ministry of Environment

4.2.8. Local Governments (LGs)

4.3. National food control systems

4.4. National Agency for Food and Drug Administration and Control (NAFDAC)

4.4.1. Functions of NAFDAC

4.4.2. Regulatory strategies of NAFDAC

5. RESULTS

5.1. Interviews with regulatory officers at NAFDAC

5.2. Consumer Survey Questionnaire

6. DISCUSSION, RECOMMENDATIONS AND LIMITATIONS

6.1. Recommendations

6.2. Limitations

7. CONCLUSION

8. REFERENCES

9. JOURNAL ARTICLE

Abstract

Keywords

1. Introduction

2. Methodology

3. Food fraud – current status in Nigeria

4. Food safety legislation in Nigeria

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5. Results

6. Discussion, Recommendations and Limitations

7. Conclusion

8. References

10. APPENDIX

10.1. Guide for Authors for Food Control Journal

10.2. Survey questionnaire

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List of figures

Figure 1.: Structure of Tetrodotoxin

Figure 2.: Flow diagram of food fraud and food authenticity factors

Figure 3.: Structure of Ochratoxin A

Figure 4.: Picture showing a GC-MS instrument

Figure 5.: Picture showing a HPLC instrument

Figure 6.: Picture showing an NMR spectrometer

Figure 7.: 1H NMR spectra in the region of the 16-OMC signal in experimental Arabica/Robusta mixtures

with 0–7% of Robusta content

Figure 8.: 1H NMR spectrum of typical Robusta and Arabica coffees (roasted coffee, lipophilic extracts).

The following signals are marked: 16-OMC (a), caffeine (b), triglycerides (c), kahweol (d)

Figure 9.: The region of the 16-OMC signal for selected coffee samples

Figure 10.: Overall 1H-NMR 95% confidence spectral envelope of the set of spectra from 26 BIPEA

Quality Control honey analyses performed over more than one month. In blue: 2.5% quantile, in red:

97.5% quantile, in green: median. The zooms are focused on spectral regions with smaller signals and

more discriminant information

Figure 11.: FT-Raman spectra of: (a) skimmed and (b) whole spreadable cheese

Figure 12.: FT-Raman spectra of: (a) standard spreadable cheese, (b) 2% (w/w) starch, (c) 6% (w/w)

starch, (d) 10% (w/w) starch and (e) pure starch

Figure 13.: The 17 UN Sustainable Development Goals (SDGs)

Figure 14.: Map of Nigeria showing the six geopolitical zones

Figure 15.: Street food retailing on major street

Figure 5.1.: Bar graph showing the overall ratio of commonly adulterated food commodities in percentage

Figure 5.2.: Bar graph showing the percentage of participants that agree/disagree on poor implementation

of food laws in Nigeria

Figure 5.3.: Pie chart showing the percentage of participants that agree/disagree on the efforts of

NAFDAC in tackling food fraud

Figure 5.4.: Bar graph showing the percentage of participants that are aware/unaware of the UN

Sustainable Goals (SDGs)

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Figure 5.5.: Bar graph showing percentage of participants that agree/diagree on the problem of food

smuggling in Nigeria

Figure 5.6.: Bar graph showing the percentage of participants that agree/diagree that consumers are partly

responsible for food adulteration in Nigeria.

List of Tables

Table 1.: Elements of food integrity

Table 2.: Participants’ profile (n = 68)

Table 3.: Food commodities commonly adulterated in Nigeria

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1. LITERATURE REVIEW

1.1. INTRODUCTION

Fraud can be defined as an intentional misrepresentation of fact by one person alone or acting on behalf

of an organization in order to deceive another person to part with something of intrinsic value. Food fraud

is a collective term used to include intentional and deliberate substitution, diversion, exploitation or

misrepresentation of food, food ingredients or food packaging, or a misleading or false assertion about an

economic benefit commodity (Spink and Moyer, 2011a). Food fraud forms include adulteration, bribery,

overrun, stealing, diversion, simulation, and falsification (Spink and Moyer, 2011b). Food supply chain

fraud may result from (1) product integrity (authenticity) misrepresentation–the inherent quality attribute

of totality or completeness (Manning and Soon, 2014) which is intrinsic; (2) process integrity – the

practices undertaken to manufacture food items that include the design, evaluation, monitoring and

inspection of processes within the product life cycle to ensure they remain genuine and intact i.e. extrinsic;

(3) people integrity may be defined as the honesty and morality shown by individuals and/or (4) data

integrity of information accompanying food items throughout the supply chain, consistent and accurate

data through the life cycle of food products (Table 1).

Elements of food

integrity

Examples

Product integrity Adulteration and economically motivated adulteration

(EMA), counterfeit product, expiration date, simulation and

tampering.

Process integrity Diversion of products outside of intended markets, illegal

importation, over-run, theft.

People integrity Characterizations such as cyber criminals and hacktivist,

disgruntled individual, extortionist, extremist, irrational

individual, opportunist, professional criminal.

Data integrity Illegal importation, improper, fraudulent, missing or absent

health certificates, expired, fraudulent or missing common

entry documents or import declarations, mislabelling.

Table 1: Elements of food integrity (Adapted from Bouzembrak and Marvin (2016); PAS 96 (2014);

Spink and Moyer (2011).

Fraud in connection with food is not recent. For economic gain, most early food laws and codes

concentrated on adulterants. Philosophers have raised doubts since the 4th century B.C and the penalty of

Roman law for food adulteration included servitude or exile (Fortin, 2009). Some of the earliest reported

cases of food fraud involving olive oil, wine, spices and tea dating back thousands of years (Foster, 2011;

Norton et al., 2011; Wilson, 2008). The same products, along with a number of other products, continued

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to be associated with fraud. Food and food additives typically associated with food fraud usually include

olive oil, fish, honey, milk and dairy products, highly processed foods, meat products, grain-based foods,

fruit juices, wine and alcoholic beverages, organic foods, spices, tea and coffee. How widespread food

fraud is in the U.S. or internationally is not known conclusively. This is partially because those who

commit fraud do not intend to cause physical harm and do not want to be found. Many accidents go

undetected because they typically do not result in a risk to food safety and customers are often unaware of

a quality problem. However, since the motive to commit food fraud is unlawful monetary gain, a secondary

concern is the type of food that could be or become adulterated is a secondary consideration (i.e. any kind

of food or food ingredient); rather, it is the probability or likelihood of fraud that usually causes fraud

(CRS, 2013). Although the vast majority of incidents involving food fraud do not pose a risk to public

health, there have been incidents involving fraud that do not pose a risk to public health, and cases of fraud

have resulted in actual or potential threats to public health. Food theft, whatever the definition of crime, is

a type of criminal behaviour. Food fraud's effects are catastrophic. Food companies and their image are

harmed, reports go viral, entire supply chains are painted with the same brush, erodes consumer

confidence, failure of markets and management and/or staff are fired, charged and locked up. The overall

effects are comparable to other corporate fraud (Kuang and Lee, 2017). Losses for individual businesses

may include social losses and sanctions, losses from third parties (e.g. additional tests), losses of

confidence, losses of sales and overpayment, as well as losses from recall (Bindt, 2016). There is some

popular belief that food theft is primarily an external threat from organized crime groups who aim to

permeate the food supply chain. While politically convenient, in fact, actors in the food supply chain who

make the most of the criminal opportunities that emerge are more often a problem (Lord et al., 2017).

Fraud is the product of the relationship between motivated criminals and the opportunities offered by

victims and those responsible for controlling risks according to Levi (2012). While food fraud is not really

a new phenomenon, food authentication and the truthfulness of food labels are currently a major concern

for many different groups of people, including the food industry, regulators, customers, etc. (Charlebois

et al., 2016).

The American Chemical Society (ACS) SciFinder database explicitly shows that there is a significant

increase in the number of publications concerned with “food fraud” and “food fraud research”. Food fraud

originally began in the Greek and Roman Empires, but only recently, due to the advent of distinct

analytical techniques, it has become possible to detect deficiencies in the distribution of food. To be

“authentic”, a food product must comply with labelling requirements, the composition of ingredients,

manufacturing procedures, other methods and technologies, and genetic identity. Because of the 2013

European horsemeat scandal and the 2008 Chinese milk scandal, it became clear that mislabelling has

become a real big issue in modern society, and violations could occur on a huge scale. Another reason for

the catalytic growth of food counterfeiting could be attributed to the increase in world trade and emerging

new markets as well as the fact that food prices are increasingly growing globally (Holbrook, 2013).

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Increasingly, manufacturers and retailers are forced to substitute specific ingredients or even whole

products in order to set a competitive price for an intended market. Supply bottlenecks, the opportunity to

make more profit, insufficient regulation in different countries have facilitated inaccurate labelling, also

leading to consumer fraud. Fish and seafood products are the most known and documented cases (Jacquet

and Pauly, 2008). Fake products sold in southern Europe are stated to have been mislabelled by 30 percent

as confirmed by DNA analysis (Garcia-Vazquez et al., 2011). A meat study conducted in 2015 found a

substitution rate of 57 percent and, subsequently, major discord with the label details (Di Pinto et al.,

2015). In addition, chicken sausages are often mislabelled, posing significant issues of food safety and

market prediction (Bottaro et al., 2014). In Europe, the European authorities discovered an operation that

allegedly made goods from decomposed apples, tainted with mycotoxins and other toxic chemicals,

unsuitable for human consumption and detrimental to public health. Italian and Serbian authorities have

confirmed that they cracked the fraud ring involved in the production and trade of supposedly organic

food and beverages from rotten apples. Nine members of an alleged organized crime group were charged

in a joint action, coordinated by Eurojust. Illegal properties valued at €6 million ($6.7 million) and 1,411

tons of adulterated items were seized at an estimated value of approximately €5 million ($5.6 million). In

Italy and Serbia, the assets of six firms suspected to be involved have been identified. Pisa's Public

Prosecutor in Italy launched the international group investigation, which officials say had branches in

several countries. Investigations uncovered an illegal trade in adulterated fruit, preserves, and other canned

foods. Foods had been processed with water and sugars and falsely branded as organic products of

European origin and marketed.

Eight arrest warrants had been issued in Italy and one in Serbia. People charged are accused of fraud and

involvement in a criminal organization. The Guardia Civil confiscated 300 tons and 39,000 litres of

falsified food and beverages in Spain. Three people were detained in Grenada after reportedly selling about

500 tons of vegetables including zucchini, peppers and cucumbers as organic, while their suppliers were

not certified as organic. Two consignments of eggs were sold as organic in Madrid but were of a lower

category and, according to officials, did not meet the requirements laid down by legislation. Police

confiscated a total of 45,360 eggs and prosecuted six individuals (Food Safety News, 2019). An analysis

of 50 coffee and 50 juice samples by Danish officials found that in four cases, the manufacturer had

unlawfully added either water or sugar to the drink. In nine cases, lower-priced Robusta beans were found

in Arabica coffee in Germany, Portugal, and Switzerland. The quality of Robusta ranged from 7% to

100%. Spain's authorities have arrested a group in Malaga province reportedly transporting young fish

without sanitary controls. Officials said the group were fishing in the Port of Malaga between sunset and

sunrise, and monthly earnings were projected to be as high as € 50,000 ($56,000). In an operation called

“Diximus”, which started more than a year ago, the Guardia Civil detained 16 people and prosecuted

another seven. Also involved was the Spanish Food Safety and Nutrition Agency (AESAN), as the group

reportedly used formaldehyde to protect the fish they caught. According to official reports from the

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Guardia Civil, they cautioned that purchasing and eating immature fish could present a health hazard

because it is caught, treated and transported under poor hygienic and sanitary conditions, it is not known

to be traceable and formaldehyde is an illegal additive (Food Safety News, 2019). With the increasingly

poor food safety and security practices in Nigeria, there is a tendency to suffer severe health consequences

and to report massive death rates from pollutants every day. Sadly, there are poor food safety practices

and standards in Nigeria which, according to the National Agency for Food and Drug Administration and

Control (NAFDAC), has resulted in enormous economic losses, as can be seen in the myriad of rejections

of some Nigerian food exports at international borders as a result of contamination, inadequate storage

methods and adulteration of food products. A 2015 internal memo issued to Sahara Reporters from the

National Agency for Food and Drug Administration and Control (NAFDAC) Nigeria's Food Safety and

Applied Nutrition (FSAN) office disclosed that tomato paste imported from China and sold in Nigeria fell

well below national food safety standards. This was discovered by the FSAN after conducting a study in

which 314 tomato paste packets purchased in Lagos were tested in a laboratory to determine if they had a

tomato content of at least 28 percent, the minimum requirement stated by Codex Alimentarius Standards

and Nigerian Industrial Standards. The study results showed that 286 samples, or 91.1% of the samples

analysed, had tomato content below the minimum of 28%. In the internal FSAN report obtained by Sahara

Reporters, the FSAN considered the consequences of the test results to be very alarming and concluded

that tomato paste product companies were working with Chinese tomato paste manufacturers to sell to

unsuspecting Nigerian consumers because Nigeria consumes approximately 300,000 tons of tomato paste

imported from China annually. As a result, the FSAN recommended that retailers refrain from selling

imported tomato paste from China until further notice and released a national recall of imported tomato

paste brands from China (Sahara Reporters 2016). A dietary study conducted at Lagos and Kano revealed

at the point of consumption, an alarming amount of contaminated food. The food was allegedly

contaminated with chemicals, metals and traces of pesticides (Premium Times, 2019). In 2018, a warning

was issued by the Ghanaian Health Authority against the consumption of puffer fish which resulted in the

death of two family members while four others were hospitalized after eating the fish for dinner. They

revealed that the puffer fish contains tetrodotoxin, a neurotoxin that makes the fish lethal and is stated to

be 1000 times more toxic than cyanide, and that it does not have an antidote and kills by suffocating the

diaphragm (NAFDAC, 2018).

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Figure 1.: Structure of tetrodotoxin

1.2. HISTORY OF FOOD FRAUD

Human beings have modified the condition of food since prehistoric times to prolong their longevity or

enhance their taste. Early humans had harnessed fire to cook and preserve meat at least as ancient as

300,000 years ago, and later determined that salt could be used to preserve meat and that salt could be

used to preserve meat without cooking. Wine was often blended with honey, herbs, spices and even

saltwater, chalk or lead in ancient Rome and Greece, serving both as a sweetener and as a preservative.

The act of adulterating food for economic gain started to emerge overtime. Imported spices were pretty

valuable during the Middle Ages. Merchants often mixed spices with multiple cheap substitutes such as

groundnut shells, ashes, seeds, juniper berries, stones or dust because of their high prices and limited

supply. In response, trade guilds were established to control product quality and prevent food adulteration,

and legislation was drawn up throughout Europe to regulate the quality of bread, wine, milk, butter and

meat. Nevertheless, after the reformation, the guilds’ influence waned and their rules along with them.

The loss of food for profit was widespread during the 18th and 19th centuries, as the United States moved

from an agricultural to an industrial economy and urbanization separated people from food production.

Milk has often been treated and coloured with chalk or cement substances that have also been applied to

the flour volume. Wine and beer were added to lead, and coffee, tea, and spices were combined with water,

sand, or other leaves on a regular basis. Although a number of laws prevented the introduction of harmful

substances to food, they were difficult to enforce as there were no reliable testing to prove the existence

of contaminants. In 1820, when his book “A treatise on adulteration of food and culinary poisons” was

published, a chemist called Fredrick Accum drew attention to numerous cases of food poisoning.

Microscopes have been able to detect variations between ingredients and chemical reactions to recognise

the presence of toxic substances by this time (Schumm, 2014).

Nevertheless, the growing number of urban dwellers relied on others for food–frequently transported long

distances with inadequate cooling and poor sanitation–and the custom of applying harmful additives to

prolong the shelf life of a product persisted. By the end of the 19th century, the increase of analytical

chemistry made it possible for manufacturers to conceal the degradation of food in ways that were difficult

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to detect. Simultaneously, herbal elixirs, tinctures, and “medicines” containing morphine, cocaine, heroin,

and other narcotics were marketed without limits, warnings, or labelling of ingredients. In 1906, the chief

chemist in what is now the Department of Agriculture, Dr. Harvey W. Wiley, assembled a group of

volunteers to test the effects of ingesting some of the most common food preservatives in use at the time,

such as borax, copper sulphates, sulphuric acid and formaldehyde. This group of men, known as the poison

squad, decided to eat increasing amounts of each chemicals while tracking their effect on their bodies

carefully. The alarming findings received widespread attention and both the Meat Inspection Act and the

Original Food and Drugs Act were passed by Congress in 1906 banning the manufacture and interstate

sale of adulterated and misbranded products and drugs. Nevertheless, it was not until 1958 that

manufacturers had to carry out the checks necessary to prove the safety of a drug before it was introduced

to the public. Although the security of our food supply has greatly improved over the last century, food

fraud involving cases of dilution, duplication and mislabelling in the global food industry continues to

persist. Since processed foods with different ingredients come from many countries and the supply chain

has become more complicated, tracking contamination origins – whether deliberate or not – has become a

major challenge (Schumm, 2014).

1.3. FOOD AUTHENTICITY AND FOOD AUTHENTICITY FACTORS

Food fraud and adulteration problems include a study of the definition and nature of the food-related

authenticity concept. Food authenticity is a major concern for customers, food authorities, food producers

and processors, as inaccurate food labelling and other forms of fraudulent practices have been shown to

have a negative impact on the consumer's trust and health (Barnett et al., 2016). Regulation (EU) No

1169/2011 (EU, 2011) of the European Union allows consumers to be properly informed about the food

they eat. This is crucial for maintaining a high level of health security and upholding their right to

information, as well as protecting companies from unfair competition from scrupulous suppliers. Health,

economic, environmental, social and ethical factors can influence the choices of consumers. Nevertheless,

the general dictionary definition of' authenticity' is' the quality of being true, trustworthy, or genuine,' and

the related dictionary definition of' authentic' includes' not fake or copied; genuine; actual' and' having an

unquestionable evidence-based origin; authenticated; checked.' More specifically with regard to food

authenticity, a CEN standard recently produced describes food authenticity in the sense of food and feed

as the connection between the features of the food product and the corresponding representations of the

food product (CEN WS/86). Such criteria for labelling, which are legally defined and vary depending on

the product, may include the scientific name or breed and method of processing (e.g. organic, free-range,

wild-caught, etc.). Nevertheless, certain product features may also be included by manufacturers to inform

consumers, including (i) ethical issues (halal, vegetarian, etc.), (ii) nutritional composition (vitamins,

omega 3, etc.) (iii) areas where the product has been captured or farmed (for purposes of sustainability or

with particular regard to EU legislation on safe designation of origin (PDO), protected geographical

indication (PGI), assured traditional specialities (TSG), etc., (iv) product status (e.g. whether the product

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was previously frozen or defrosted) and (v) the inclusion of undeclared products that may also pose a

health risk to consumers (e.g., gluten, nuts, etc). Consumers are increasingly interested in knowing the

geographical origin along with the perceived quality of the products they eat and drink because of the

globalization of food markets and the resulting rise in variety and availability of food items from other

countries. Quality assurance and food authentication approaches are of great interest from both

commercial and legal viewpoints (Drivelos and Georgiou, 2012). Consumers, suppliers, and regulators

have been concerned about authenticity since ancient times (Posudin et al., 2015). Modern equipment,

developments in basic sciences and information and communication technology provide the means to

accurately measure and elucidate the origin of foods (Georgiou and Danezis, 2015). Food validity depends

on the following factors to be addressed in more detail.

Figure 2: Flow Diagram of Food Fraud and Food Authenticity factors.

1.3.1. PRODUCTION METHOD

The manner in which certain food items are produced or processed can be viewed as a measure of

authenticity for a particular food product. Oils and, in particular, olive oil are among the most frequently

adulterated food items. Olea europaea, commonly referred to as the olive tree, is native to the

Mediterranean region and is one of the oldest tree species whose fruits and by-products, such as olive oil,

have traditionally served as a food source for indigenous populations residing in the area. Roughly 70%

of olive oil production is currently undertaken in Mediterranean countries, including Spain, Turkey,

Greece, Italy, Morocco and Tunisia (EP 2017). Nevertheless, in other parts of the world, including

Australia and the USA, olive oil is also made. Due to the identification of distinct polyphenol profiles even

between different types of olive oil developed within a single country (Vossen, 2007), different olive oil

varieties with different qualities exist. Unlike olives, olive oils have different characteristics and qualities.

The legislation specifies olive oil characteristics and marketing criteria for both regulatory and producer

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and consumer-friendly purposes. Overall, eight separate categories are classified within the EU, of which

only four are available to consumers, including the following:

• Extra virgin olive oil

• Virgin olive oil

• Olive-pomace oil

• Blended olive oil

The following categories within the EU are not retailed:

• Refined olive oil

• Lampante olive oil

• Refined olive-pomace oil

• Crude olive-pomace oil (Ebeler et al., 2007)

Thanks to its perceived health benefits, olive oil's popularity has increased worldwide in recent decades.

This is particularly true for extra virgin olive oil (EVOO). According to the legal definition by EC

1019/2002 of extra virgin olive oil, it is a superior form of olive oil obtained directly from the fruit of the

olive tree by mechanical or other means only and according to the Fats and Oil Regulation of Sections 5

and 30 of the NAFDAC Act Cap N1 LFN 2004 and Section 12 of the Food, Drugs and Related Products

Act Cap F33 LFN 2004, it contains no processed olive oil, it has superior sensory characteristics and

consistency based on chemical composition of free acidity, expressed as oleic acid, of not more than 0.8

g per 100 g and whose other characteristics correspond to those applicable international standards for this

category (NAFDAC, 2019). The easiness to adulterate EVOO, identification complexity, disparity

between supply and demand, economic factors, as well as cultural and behavioural risk factor, and lack of

control measures lead to EVOO's vulnerability to fraud. Three standard olive oil frauds have been reported:

(a) mixing with other vegetable oils is the most common way (Jabeur et al., 2014), (b) replacing vegetable

oil with added chemical compounds to mask adulteration (Roca et al., 2010), and (c) replacing EVOO

with lower grades of olive oil. Refined olive oil (ROO) (Karbasian et al., 2015) and pomace olive oil

(POO) (Škevin et al., 2011), as well as soft deodorized oils (Aparicio-Ruiz et al., 2017) may be included.

Calvano et al., (2012) stated that the most important source of agricultural fraud in the EU is adulteration

of EVOO. In some cases, particularly the processing and manufacturing method can be registered as a

traditional specialty guaranteed (TSG).

1.3.2. VARIETY AND SPECIES

Food authenticity and traceability are important issues in our modern society as it can be deduced, for

example, from past events involving the adulteration of meat products with non-declared species such as

horse meat (Premanandh, 2013). It reflects the global demand of customers around the world to have

accurate and reliable information about the food they eat. This is particularly true for processed meat

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products where a simple visual inspection would not make it as easy to differentiate between the various

components as in the case of intact fresh meat (Flores-Munguia et al., 2000). Of course, there are essential

underlying reasons for this argument. Today, price and lifestyle will influence the individual's choice of

food products depending on their composition, along with different religions or health concerns. An

example is the Muslim community's growing interest in certifying the Halal status of the meat they

consume in an evolving global meat market, and a number of reports on this topic have been published

(Ali et al., 2012; Farouk, 2013; Nakyinsige et al., 2012). One example is the growing demand for

conventional and/or regional meat products that customers view as high-quality, value-added foods

(Montowska and Pospiech, 2012). To ensure food safety and preference for customers, honest and accurate

food labelling is important. There is a provision in meat products to signify the quantity of each ingredient

present in them, what is known as the QUID. The declaration sets out a new definition of meat for the

proper marking of the drug. The definition limits the word “meat” to the skeletal muscle along with the

connective tissue and fat content limitations. Excess fat and/or connective tissue cannot be treated as meat

and must therefore be listed separately on the bottle. This also ensures that each animal species found in

the commodity is stated and quantified separately. Moreover, mechanically recovered meat (MRM) and

other parts of the carcass such as the liver, lung, heart, or tongue, for example, cannot be classified as meat

and must also be defined separately (Zukal and Kormendy, 2007). The main areas vulnerable to fraud in

the meat industry include: (a) the origin of meat and the animal feeding scheme (for example, in the case

of approved regional products), (b) the substitution of meat ingredients with other animal species, tissues,

fat or proteins, (c) the modification of meat product processing methods and (d) the addition of non-meat

components such as water or additives (Ballin, 2010). Honey is the natural sweet substance from the nectar

of plants or secretions of living parts of plants produced by honey bees. It could also be derived from

excretions of plant-sucking insects on the living parts of plants that the bees collect, turn by combining

with their own different substances, deposit, dehydrate, store, and leave to grow and develop in the

honeycomb (CAC, 2001). Honey has long been a subject of adulteration as a natural product with a

relatively high price (Bogdanov and Martin, 2002). Honey's credibility is of great importance both in terms

of trade and wellbeing. It is difficult to detect adulteration in honey due to the large natural variability in

honey due to differences in plant species, maturity, climate, processing and storage techniques (Sivakesava

and Irudayaraj, 2002). Honey can be adulterated by adding foreign substances such as molasses, starch

solution, glucose, sucrose, water and inverted sugar, or by modifying the physiochemical parameters (El-

Bialee and Sorour, 2011). Of honey adulteration, the following sweeteners were used: acid-inverted

syrups, maize syrups, naturally occurring syrups such as maple, cane sugar, beet sugar and molasses. On

the other hand, the use of excess heat for pasteurization and liquefaction may adversely affect the quality

of the honey, e.g. loss of volatile compounds and reduction of enzyme activity (Nasir et al., 2010). Honey

harvesting with high humidity or subsequent addition of honey water can result in fermentation and

spoilage of honey (Bogdanov and Martin, 2002).

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Dairy products have high nutritional value and are widely consumed food groups for public nutrition, and

ingredients for everyday use are also widely used in the food industry. Because of their great economic

value, they are therefore one of the most frequently adulterated goods (Cattaneo and Holroyd, 2013; De

La Fuente and Juarez, 2005). Buffalo, goat and ewe milk are used worldwide in conventional fermented

dairy products such as Roquefort, Feta and Manchego cheeses, some mixed varieties in Austria, and

Erzincan Tulum and Mihalik cheeses in Turkey (Mayer, 2005). Bovine milk is the most prevalent in the

world for human consumption. However, particularly among children, cow milk allergy is very common

(Ceballos et al., 2009). The composition of goat milk is similar to cow milk, but it lacks beta-carotene and

agglutinin, has smaller fat globules and different types of casein, making it easier to digest (Ceballos et

al., 2009). Furthermore, during heat treatments, goat's milk stability is lower than that of cow's milk

(Montilla and Calvo, 1997; Karoui and Blecker, 2011). Goat milk production in many countries, especially

in the Mediterranean region and the Middle East, is an important part of the national economy. It is

particularly important in France, Italy, Spain and Greece, where goat milk and dairy products are

traditional practices of great social, cultural and environmental significance (García et al., 2014; Zachar et

al., 2011). Pure goat cheeses are considered to be specialties with very unique flavours and aromas that

are well received on the Italian market. Goat milk and dairy products command much higher prices than

cow's and sheep's milk in relation to the seasonality of production and naturally small milk production per

animal (Golinelli et al., 2014). The fraudulent use of cheaper bovine milk during cheese production is

common practice due to its excellent nutritional properties and higher commercial value. Goat by-product

mislabelling, related mainly to the undeclared complete or partial substitution of goat's milk with cow's or

sheep's milk, has been widely reported worldwide and is a major safety concern due to significant

consumer protection consequences (Mašková and Paulìčková, 2006). In addition, for reasons of

intolerance or allergy, political, ethical or cultural objections, and legal requirements, it can become an

issue (Agrimonti et al., 2015; López-Calleja et al., 2007; Van Hengel, 2007, Wal, 2004). Adulteration of

roasted coffee that include the quality of beans, i.e. species, geographic origin, and defective beans, as

well as the addition of other substances, i.e. coffee husks and stems, corn, barley, chicory, wheat middling,

brown sugar, soybean, rye, triticale, and açai, to coffee blends to make them less expensive (Toci et al.,

2016). Two varieties are economically and commercially important among the several species of the genus

Coffea known so far: Coffea arabica (Arabica coffee) and Coffea canephora (Robusta coffee). Because

of their superior flavour, Arabica beans are more popular than Robusta beans (Barbin et al., 2014).

Although fresh coffee beans can be separated macroscopically or organoleptically, chemical analysis is

required after roasting and grinding to detect the adulteration of Arabica beans with Robusta beans. The

International Coffee Council (ICC) has released a document outlining a plan of action needed to implement

a Coffee Quality-Improvement Program (CQP) for the control of coffee adulteration. CQP sets minimum

requirements for exportable coffee, specifying that for Arabica, more than 86 defects per sample of 300 g

and for Robusta, more than 150 defects per 300 g are not to be exported. The main concern about the

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presence of ochratoxin A is likely. To this end, the Food and Agriculture Organization (FAO) has been

named to audit a project aimed at eliminating or minimizing mould formation (Toci et al., 2016).

Figure 3: Structure of Ochratoxin A

1.3.3. GEOGRAPHICAL ORIGIN

Consumer behaviour is geared towards a greater preference for goods whose geographical origin is stated

as this knowledge clearly increases their trust when buying food. Due to its unique organoleptic properties,

monosaturated fatty acid content and antioxidant properties, olive oil is a highly desirable food product on

the international market (Bendini et al. 2007; Frankel, 2011). It is of utmost importance to maintain the

consistency of these olive oils. The value of geographical declaration on the label is largely due to the fact

that extra virgin olive oil (EVOO) is viewed by customers as an additional guarantee of their consistency

and authenticity. For that purpose, a standard scheme of geographical indications such as Protected

Designation of Origin (PDO) (EU, 2012) was adopted by the European Union (EU). In addition to the

PDO information on the bottle, in the case of non-PDO oils, the user can also request information on the

origin. The specific PDO and labelling regulations, however, do not prescribe an empirical method for

checking the details recorded on the mark. This reality has given rise to the interest of analysts and

researchers in developing a reliable authentication process. Following extensive research on the chemical

characterization of olive oils from different locations, often even from the same cultivar, there are now

enough chemical and mathematical histories to indicate that oils ' chemical compositions are partially

correlated with their sources. A recent review summarizes the most interesting and innovative approaches

(e.g., using optical techniques, measuring electrical characteristics, instruments equipped with electronic

chemical sensors) with a potential and practical application to develop simple, easy-to-use,

environmentally friendly instruments to track the geographical origin of virgin olive oil (Valli et al., 2016).

The ingredient that is of great interest to the commodity's provenance is honey. Honey is commonly

pursued throughout the world. Nevertheless, it is necessary to ensure its innocuousness and validity in

order to commercialize it. In this regard, the law of the European Union specifies that honey exported

must be traceable over time (EU Directive 178/2002). This legislation is intended to prevent false claims

of geographical and botanical origin that have occurred in the past due to a significant variance in the price

of honey by origin (Camina et al., 2012; Dong et al., 2016). In general, traceability is stated in documents

of the product life cycle that are obviously susceptible to fraud (Olsen and Borit, 2013). For this reason, it

is important to back up traceability reports with more reliable information, such as analytical tests or

product chemical data (Zhao et al., 2016; Soares et al., 2017). Because knowledge on the geographical

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and botanical origin of honey is a guarantee of product quality, the ability to prove its origin is crucial for

the acquisition and preservation of consumer niches (Mohammed et al., 2018). Historically, microscopic

pollen inspection has been carried out to verify the botanical origin of honey (Louveaux et al., 1977; Jaafar

et al., 2017), but this melissopalynological approach involves knowledge that can be expensive. Therefore,

efforts have been made to define other honey criteria that can be implemented systematically in procedures

for certification of origin. Chemometric knowledge has been one of the most effective methods (Soares et

al., 2017). Such variables include physiochemical properties, mineral content (including trace elements),

concentration of phenolic, flavonoid and volatile compounds, as well as details on the strength of honey

absorption or reflection at different wavelengths, from visible to near infrared spectrum, among others

(Camina et al., 2012; Cosonni and Cagliani, 2015; Bontempo et al., 2017; Laza et al., 2017). For example,

Kropft et al., (2010) and Bontempo et al., (2017) used 13C and 15N in addition to other variables of

chemical composition to differentiate between different honey floral sources. Therefore, to assess the

honey authenticity for sugar adulteration, stable isotopes were used (Dong et al., 2018). Such information

is then analysed to classify related honey groups using multivariate statistical methods such as discriminant

analysis, logistic regression (LR) or neural network models (Camina et al., 2012). The model developed

will later be used to assign a new sample of honey to one of these groups of origin.

1.3.4. GENUINESS

The most obvious factor of authenticity is that it must be genuine (i.e. authentic) food product.

Nevertheless, adulteration in the form of a mixture of a cheaper product is perhaps one of the most

frequently encountered problems of food authenticity. In 2007, more than 60,000 false food cases were

reported by the Xinhua News Agency; more than 15,500 tons of under-standard food were seized, and 180

food producers were listed as processing under-standard food or using inedible ingredients in food

production (Veeck et al., 2010). Nevertheless, Lord et al., (2017) and Van Ruth et al., (2017) claim that

food fraud is not only perpetrated by highly organized crime syndicates infiltrating food systems (Elliott,

2014; Europol, 2015), but can also be perpetrated by legitimate food chain actors who have access to a

location where food fraud can be perpetrated and where criminal opportunities arise to participate in

fraudulent activity. Coffee is one of the beverages with higher consumption worldwide, mainly due to its

sensory and calming properties, along with enhanced awareness of potential health effects (Ludwig et al.,

2014). However, it has been the subject of adulteration for decades due to the high commercial value of

coffee, particularly Arabica coffee. In Brazil, the world's largest coffee manufacturer, with a high

percentage of adulterated roasted coffee samples sold in the internal market, this is of particular concern

(Domingues et al., 2014; Souto et al., 2015). Coffee adulteration can also impair the sensory properties

and chemical composition of the beverage, in addition to being against regulations and consumer rights,

thereby minimizing its beneficial health effects. The most popular coffee frauds include the introduction

of lower commercial value roasted and ground vegetable items such as maize, barley, rye, wheat, and so

on (Jham et al., 2007; Toci et al., 2016). Such products are distinct from coffee, making it possible to

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differentiate them by physical and chemical characteristics, but the new frauds using coffee by-products,

such as coffee husks and stems, pose an increased challenge for analytical chemists (Reis et al., 2013a;

Toci et al., 2016). Milk is a rich source of nutrients including proteins, carbohydrates, vitamins and

minerals, and the increased nutritional value of milk has led to higher worldwide consumption and

production of milk and milk products (Nascimento et al., 2017). Nonetheless, due in part to this demand,

milk powder is an adulteration product, ranking second to olive oil on food fraud and economic

adulteration according to the USP database (Moore et al., 2012). Milk powder can be diluted and/or mixed

with inexpensive, readily available, fairly odourless, colourless and tasteless substances to mask inferior

quality, increase quantity, or substitute cheaper adulterants for economic gain for natural constituents

(MacMahon et al., 2012; Nascimento et al., 2017). Sadly, milk powder is sometimes adversely affected

by economically motivated adulteration (EMA). For starters, in two cases of milk and wheat gluten

adulteration with nitrogen-rich melamine, EMA of food ingredients received worldwide attention. In 2007,

co-contamination of a wheat gluten product with melamine and cyanuric acid induced renal failure

associated with pet food in a number of cats and dogs in the US (Brown et al., 2007; Qin et al., 2013). In

2008, infant formula melamine adulteration in China resulted in thousands of cases of kidney infection, at

least six confirmed deaths, and multi-country precipitation of mass product recalls (MacMahon et al.,

2012; Qin et al., 2013; Xin and Stone, 2008). Widespread global attention to the melamine controversy,

increased government agency controls, and the development of various analytical methods have reduced

the risk of melamine events occurring (Draher et al., 2014; MacMahon et al., 2012; Turnipseed et al.,

2008; FDA, 2017a, b, c). EMA of milk powder, however, remains a serious concern with many other

nitrogen-rich adulterants.

The Food Safety Division of the Canadian Food Inspection Agency has compiled a list of potential

economic adulterants based on the criteria for a potential milk powder adulterant (MacMahon et al., 2012).

Combined with other information on intelligence, this list led the FDA to establish a targeted LC-MS

system for six potential economic adulterants: dicyandiamide, urea, biuret, triuret, cyromazine and

amidinourea (MacMahon et al., 2012). In addition, cyanuric acid (Draher et al., 2014), ammonium sulfate

and aminotriazole are possible nitrogen-rich adulterants (DeVries et al., 2017; Finete et al., 2013). There

are signs of falsified MP content due to the addition of plant proteins, according to studies from the

European Union (Luykx et al., 2007; Maraboli et al., 2002; Scholl et al., 2014). Low prices and protein

abundance, such as soybeans and peas, make them attractive in milk powder as possible adulterants. To

change the physical characteristics of milk powder such as viscosity, taste, and nutrition, these plant

protein isolates can be added. Overall, for commercial gain, EMA of these foreign proteins is not expected

to occur at concentrations below 1% in milk powder (Haasnoot et al., 2001; Luykx et al., 2007). Ironically,

melamine controversies have overshadowed the production of accurate analytical test methods for

detecting EMA from milk powder products with plant proteins (Scholl et al., 2014). In addition, possible

milk powder adulterants are polysaccharides / disaccharides such as starch, sucrose, and maltodextrin

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(Borin et al., 2006). To change the density and freezing point of the adulterated drug, these adulterants

could be applied (de Almeida et al., 2012). EMA from these food additives is generally expected to range

from 20% to 25% of total weight; however, rates suspected to be as high as 60% were suggested (Borin

et al., 2016). Finally, certain inorganic salts, such as carbonates and bicarbonates, may be used as

neutralizers to change the pH of poorly preserved milk to freshly transmit the processed milk (Handford

et al., 2016).

1.3.5. SHELF LIFE

Under Regulation EC 1169/2011 (EU, 2011), the label of any product must signify the “use by date” or

the “best before date”; this regulation also very clearly describes the distinction between these two

phrases: the “best before date” is used in the case of foods which may undergo chemical, physical or

sensory modifications without prejudice to the health of consumers, while the “use by date” is used in

the case of foods which may undergo chemical, physical or sensory modifications that poses a health risk

to consumers. From a scientific and technological viewpoint, these dates are considered “shelf life”

(McGinn, 1982), which is a very important aspect for business management (Stone and Sidel, 2004).

Under Regulation 11 of Sections 5 and 30 of the National Agency for Food and Drug Administration and

Control Act Cap N1 Laws of the Federation of Nigeria (LFN) 2004 of the Governing Council of NAFDAC

on the 2019 date labelling of pre-packaged food, water and ice labelling, all pre-packaged foods shall

indicate and display on the label the day, month and year of manufacture. To ensure the safety and quality

of a food to be consumed before a certain date, the “use by date” or “expiration date” must be declared

and “the best before date” or “best quality before date” must be declared when such phrases are not

needed (NAFDAC, 2019). Those requirements ensure that the product is safe for use over a period of time

and that the product typically meets reasonable sensory standards including freshness, texture, and taste.

1.3.6. LABELLING

While food fraud is hardly a new phenomenon (Shears, 2010), food authenticity and food label veracity

are currently major concerns for many, including academics, consumers, regulators, and the food industry

at all levels of the food spectrum. Food theft dates back as far as the Greek and Roman Empires, but in

recent years, exposure to better technology has made it possible for people to recognize flaws in food

distribution (Charlebois and Haratifar, 2015). An authentic finished food product must comply with

labelling regulations, particularly with regard to composition of ingredients, manufacturing processes and

procedures, technology and genetic identification. In view of the European horsemeat crisis, mislabelling

has now become a much larger issue in modern society, and violations can occur on a very large scale

(Falkheimer and Heide, 2015; Le Vallée and Charlebois, 2015). The growing number of cases of food

fraud can be due in part to the increase in world trade and new emerging markets as well as the steady rise

in food prices around the world (DeKeiffer, 2006; Holbrook, 2013). Both producers and distributors are

often tempted to substitute ingredients or products in order to reach the appropriate price level for an

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intended market (Charlebois and Haratifar, 2015). The scarcity of resources, the opportunity for higher

profits, and insufficient regulation have all facilitated inaccurate labelling, which often leads to consumer

fraud. Many food groups were more affected than others. Fish and seafood products are the most

documented cases in the food industry (Jacquet and Pauly, 2008; Leal et al., 2015). For example, on the

basis of species substitution, DNA analysis of hake products marketed in southern Europe has shown more

than 30% mislabelling (Garcia-Vasquez et al., 2011). However, other groups have also been identified in

previous years. In meat, a previous study reported a high 57 percent substitution rate and, subsequently,

significant discord with label details (Di Pinto et al., 2015). A study involving chicken sausages found

similar results (Bottaro et al., 2014). Obviously, this poses important issues of food safety and consumer

protection. Mislabelling can also impact marketability and brand equity. Food fraud has been argued to

affect the security of an area or country's intellectual property and may hamper innovation by displacing

legitimate sales (Qian, 2014). Mislabelling can potentially affect a region's or even a country's brand

image. With regard to the assessment of knowledge on food labels, several past studies have already

examined the interaction between customers, industry and regulators. Nocella et al. (2014) concluded that

trust in food knowledge disseminated by public regulators is greater than that commonly found in industry.

Researchers also say that conduct directly affects the ability of public and private providers to pay for

reliable food information. Nonetheless, a few studies have investigated how information would be

interpreted in an atmosphere in which customers could determine the validity of information given to

them. Kjærnes (2012) notes that continuing changes in food systems are that the powerlessness of

consumers, and consumers may not feel in control of their own purchases. It's hard, if not difficult, for

customers to know where their food comes from with high accuracy. Food labels are a primary

communication tool for industry, regulators, and customers (Charlebois and Summan, 2015).

It can be argued that falsified or counterfeited food products will reduce the symbolic value of authentic

goods and dilute a region's brand and country of origin. Counterfeits are reproductions or replacements

that are closely similar or identical to authentic food products. These provide packaging, marking, and

trademarks that are passed as the original product. This act may or may not be deliberate as it is always

difficult to understand the extent of adulteration in the supply chain. Many customers will purchase

counterfeit food products unknowingly and unwittingly because they are closely similar to the genuine

product. It has been recognized that mislabelling can be present in various forms as well as at any point of

the supply chain (Meloni et al., 2015). The list of ingredients may stay the same on labels as unreported

substitutes are made during the production process or the country of origin may have been modified to

promote local goods or a region, despite having a different origin. Ingredients such as allergens may also

be considered mislabelling. Industry at various levels of the food supply chain exercises stringent protocols

to ensure that the information given to customers about the sources, make and conditions of production is

in line with the standards and regulations of consumers. Considering how complex food systems are,

breaches of confidence between organizations are possible and require higher levels of scrutiny. It is also

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known that food authorities play a role in controlling the quality of food labels. While some countries

routinely proactively analyse labels, others respond to complaints from customers. When consumers are

expected to learn more about food and how food is produced and distributed, regulators are trying to

monitor and implement existing legislation (Barker et al., 2011). Consumers often agree that it is the

industry's duty to market food products with clear labelling. Both food systems, policies and market

dimensions have a profound impact on consumer confidence (Ringsberg, 2015). Of course, what's hanging

in the balance is consumer confidence. Although there is broad consensus on the interrelationship between

consumer confidence and food purchasing, there is little or no general agreement within the social sciences

on how to conceptualize faith in food buying space (Chen, 2013). Research shows that consumers are

particularly concerned about food safety and label accuracy (Drescher et al., 2012; Zhou and Hui, 2003).

Consumers need to be convinced that food label knowledge truly defines the items they want to purchase

in grocery stores. Understandable concerns regarding deception, fraud, and uncertainty have resulted in

mistrust and increased government traceability regulation (Gutman, 1999). Consumers ' trust could

potentially erode overtime by accumulating explosive cases of food fraud (Charlebois et al., 2014). Since

allegations of food fraud have proliferated, whether organic, kosher, halal or other product types are

mislabeled, many customers have expressed doubts about the authenticity of food labels (Conrad, 2009).

Nevertheless, research on where buyers have become more cynical about brands in the world is not

definitive.

1.4. LEGAL FRAMEWORK

The National Agency for Food and Drug Administration and Control (NAFDAC) is the regulatory agency

in Nigeria with the mandate to regulate and control the manufacture, importation, exportation, distribution,

advertisement, sale and use of food, drugs, cosmetics, medical devices, packaged water, chemicals and

detergents which is collectively known as regulated products and it is the lead agency for food safety and

quality. In relation to food authenticity, According to sections 5 and 30 of the NAFDAC Act Cap NI Laws

of the Federation of Nigeria (LFN) 2004 on pre-packaged food, water and ice labelling regulations 2019,

Regulation 5 of this act specifically prohibits any labelling, presentation and advertisement of pre-

packaged food to be “false, misleading, deceptive or likely to create an erroneous impression regarding its

identity, character, quality, quantity, composition or origin” (NAFDAC Act Cap NI LFN 2004 Regulation

5, Section 1a). This act also prescribes the minimum required information needed to be included in food

labelling:

• The name of the food (Regulation 3, Section 1 - 6).

• The brand or trade name (Regulation 4, Section 1 - 2).

• List of ingredients (Regulation 6, Section 1 - 12).

• The net content of pre-packaged food (Regulation 8, Section 1 - 4).

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• The name, address and contact information of the manufacturer and distributor (Regulation 9,

Section 1 – 6).

• The date marking, which includes the “use-by date or “expiration date” as well as the “best-before

date” or “best quality before date” (Regulation 11, Section 1 – 9).

• The storage conditions (Regulation 12).

• The batch number (Regulation 13).

• The registration number (Regulation 14).

• Instructions for use (Regulation 18).

• Nutritional information (Regulation 19, Section 1 – 4).

• Quantitative labelling of ingredients, expressed as the percentage of the ingredient by mass in the

final product (Regulation 20, Section 1 – 4).

The main purpose of this act is to ensure that information on labelling and advertisements of food products

in Nigeria is accurate, clear and designed to promote credibility and trust by the general public and to

protect consumers from misrepresentation of food products either directly, indirectly or by implication

which can influence the consumer behaviour towards the purchase of a food product (NAFDAC, 2019).

1.5. ANALYTICAL METHODS FOR THE DETECTION OF FOOD FRAUD

There has been a range of different detection methods developed and used in the determination of the

authenticity of food. In a review by Reid et al., (2006), many methods of detections were scrutinised

including spectroscopy (UV, NIR, MIR, Raman), isotopic analysis, chromatography, electronic nose,

polymerase chain reaction, enzyme-linked immunosorbent assay and thermal analysis – all of which are

techniques that have been applied to food authentication since 2001 and will be discussed below.

1.5.1. CHROMATOGRAPHIC TECHNIQUES

Chromatographic techniques in their various forms are amongst the important methods used in food

analysis. The term “chromatography” encompasses techniques based on adsorption and/or partition of

analytes between a mobile and a stationary phase. They are usually classified according to the character

of the stationary and mobile phases, the form of the stationary phase and the driving forces of separation

(Forgács and Cserháti, 2003). Chromatographic techniques provide rapid and reliable separation of

chemically similar compounds in complex food matrices (Cserháti et al., 2005). Thus, gas chromatography

(GC), either performed as gas-liquid chromatography (GLC) or gas-solid chromatography (GSC),

represents a method where the mobile phase is gaseous. In liquid chromatography (LC), usually referred

to as high-performance liquid chromatography (HPLC), the solid stationary phase is applied in a column

and the mobile phase is pumped through the column. Thin-layer chromatography (TLC) systems consist

of a planar solid phase and a liquid mobile phase. Owning to the superior capability of GC and HPLC, the

latter technique has only rarely been used for authentication purposes for example, in differentiating

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between authentic and adulterated Noni (Morinda citrifolia L.) juices (Lachenmier et al., 2006) and

fingerprinting of flavonoids and saponins from Passiflora species (Birk et al., 2005).

1.5.1.1. GAS CHROMATOGRAPHY (GC)

Gas chromatography (GC) is a common type of chromatography used in analytical chemistry for

separating and analysing compounds that can be vaporised without decomposition. In gas

chromatography, the mobile phase (or moving phase) is a carrier gas, usually an inert gas which moves

through a column which is packed with the stationary phase. The mobile phase flows through the column

at a set rate. Depending on the affinity of the component to the stationary phase, the sample components

will travel through the column at different rates and are separated. For analytes to be determined by gas

chromatography, they need to be easily vaporized without being decomposed. Therefore, volatile food

constituents such as aromatic compounds are particularly suitable candidates for GC analysis, mostly in

combination with mass spectrometric detection. According to a review published by Cordella et al.,

(2002), GC-MS coupling is the most widely used technique (>50%), followed by GC coupled to other

types of detectors. GC has found wide application in food authentication studies in dairy products such as

milk (Li et al., 2009; Molkentin and Giesemann, 2007), herb and spice (Ma et al., 2015; Bononi et al.,

2010; Wielogorska et al., 2018), and as quality markers of cocoa beans (Caligiani et al., 2007) and beer

(Erbe and Bruckner, 2000; Junge et al., 2007).

Figure 4: Picture showing a GC-MS instrument

1.5.1.2. HIGH-PERFORMANCE LIQUID CHROMATOGRAPHY (HPLC)

High-performance liquid chromatography (HPLC) is one of the most versatile analytical techniques and

is extremely widely used in food authentication, as both polar and non-polar compounds can be analysed.

In normal phase, HPLC polar stationary phases are used and the analytes separated using non-polar mobile

phases, whereas reversed-phase (RP) HPLC is characterized by hydrophobic stationary phases e.g. C18

or C8, and polar eluents. The application of HPLC has been successfully used in detecting triacylglycerols

and fatty acids in vegetable oils (Lee et al., 2001; Marikkar et al., 2005; Kamm et al., 2001). It is also a

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good tool for analysis of triacylglycerols and tocopherol (Gonzáles et al., 2001; Segall et al., 2005b) or

phenolic acids (Andrade et al., 1997), which are present in coffee. HPLC has also been reported to be

effective in dairy products authenticity (Simpkins and Harrison, 1995; De la Fuente and Juárez, 2005;

Karoui and Baerdemaeker, 2007) and in the analysis of several fractions of milk proteins, such as casein

(Veloso et al., 2002, 2004; Mayer et al., 1997; Mayer, 2005) and/or β-lactoglobulins (Ferreira and Caçote,

2003; Enne et al., 2005) or furosine, which comes from the fructolysine complex at the beginning of the

Maillard reaction during heat treatment of milk.

Figure 5: Picture showing a HPLC instrument

1.5.2. SPECTROSCOPIC TECHNIQUES

Most spectroscopic techniques used in food authentication and fraud detection are based on near infrared

(NIR), mid infrared (MIR), Fourier transform infrared (FTIR), Raman or nuclear magnetic resonance

(NMR) spectroscopy as well as ultra-violet visible (UV-Vis) and fluorescence spectroscopies. They are

frequently combined with chemometrics, which is a chemical discipline that uses mathematical and

statistical methods to provide maximum chemical information by analysing chemical data (Leardi, 2003).

The choice of methods depends mainly on the chemical nature and the physical state of the sample, prior

knowledge and the timescale required for results (Belton, 2000). Other issues that need to be considered

are the costs of obtaining and running the analytical equipment and the specificity of the measurement.

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1.5.2.1. ULTRA-VIOLET VISIBLE (UV-Vis) SPECTROSCOPY

UV-Vis spectroscopy is one of the most widely used techniques for measuring amounts of absorbing

species in food analysis. The main advantages of this technique include ease of operation, the ability to

determine a wide range of compounds in a non-destructive manner, good sensitivity and accuracy, and

moderate selectivity. The principle of quantitative analysis with this technique is Beer’s law, based on

which the concentration of an analyte dissolved in a solvent will be proportional to the amount of light it

absorbs. A large number of spectrophotometric and fluorometric methods have been developed to

characterize a variety of food products such as cheese, milk and honey for substances such as peptides,

amino acids, fatty acids, sugars, vitamins or mineral elements (Cordella et al., 2002). UV-Vis spectroscopy

has found useful application in authentication studies. In a study by Mignani et al., (2010) to discriminate

high-quality extra virgin olive oils from adulterated samples containing lower-grade olive oils commonly

used in commercial counterfeits, the oil samples were analysed with a set-up based on optical fibre

technology and diffuse-light absorption spectroscopy over the wavelength range of 400-1700 nm.

Spectroscopic data were subjected to PLS regression in order to quantify adulterant concentrations, and

PCA and LDA were subsequent used to identify the type of adulterant used.

Mignani et al., (2010) also used a fibre-optic setup for diffuse-light absorption spectroscopy over the range

of 400-1700 nm in order to detect and quantify adulteration of extra virgin olive oil with lower-grade olive

oil. Absorption measurements provided spectral fingerprints of authentic and adulterated oils that were

successfully analysed with multivariate methods to identify the type of adulterant used and predict its

proportion in the adulterated oil. Alamprese et al., 2013 investigated the potential of UV-Vis, NIR and

MIR spectroscopies in combination with multivariate data analysis methods for detecting minced beef

adulteration with turkey meat. The spectral data for minced meat samples from pure bovine, pure turkey

and mixtures of minced beef adulterated with turkey meat in proportions of 5 to 50% (w/w) were analysed

by PCA, LDA and PLS regression. A variable selection method was used before classification and

regression, and the NIR, MIR and UV-Vis spectroscopy results were compared. Using a combination of

UV-Vis, NIR and MIR data was found to improve model performance for both qualitative analyses.

Dankowska et al., (2017) evaluated the potential of fluorescence and UV-Vis spectroscopies for

quantifying roasted Coffea arabica and Coffea canephora var. robusta in coffee blends. They assessed the

classifying ability of LDA as applied to fluorescence and UV spectral data for samples of the two types of

coffee and their mixtures. PCA-LDA analysis performed best when applied to a combination of UV and

fluorescence data. LDA exhibited an average sensitivity of 96% for the test set and 100% for the training

set. The results showed that fluorescence and UV-Vis spectroscopy had a complementary effect on the

quantification of roasted Coffea arabica and Coffea canephora var. robusta in blends.

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1.5.2.2. FLUORESCENCE SPECTROSCOPY

Fluorescence spectroscopy provides a fast, sensitive, selective analytical tool for extracting nutritional,

functional and compositional information that can be used as a fingerprint for foodstuffs such as dairy

products, fish, edible oils and wines. The use of this technique for food characterisation and authentication

has grown steadily over the past decade, probably as a result of its potential being enhanced by

chemometrics (Sádecká and Tóthová, 2007). Characterisation and classification of different food products

such as dairy products, meat, egg, fish, wine, honey and edible oils based on different chemometric

methods such as principal component analysis (PCA), hierarchical cluster analysis, k-nearest neighbours,

partial least squares (PLS), linear discriminant analysis (LDA) and parallel factor analysis (PARAFAC)

have been reported. Dankowska et al., (2015) investigated the potential of fluorescence spectroscopy for

the detection and quantification of butter adulteration with palm and coconut oils. Fluorescence spectral

data over the range of 240-700 nm were obtained at 10, 30, 60 and 80 nm intervals of which 60 nm

provided the lowest limits of detection of adulteration (LOD, 5.5%). MLR models allowed adulteration to

be detected with RMSEC and RMSEV of 3.8 and 3.9% respectively. Ruoff et al., (2005) applied front-

face fluorescence spectroscopy to honey samples for the authentication of unifloral and multifloral honey

types that were previously classified by using traditional methods such as chemical, pollen and sensory

analysis. Spectral data were subjected to PCA and LDA. Based on the results, front-face fluorescence

spectroscopy was effective for authenticating the botanical origin of honey and identifying geographical

origin within the same unifloral honey type.

1.5.2.3. INFRARED SPECTROSCOPY (IR)

Infrared spectroscopic methods operate in various electromagnetic wavelength regions including near-

infrared (NIR, 14,000-4000 cm-1), mid-infrared (MIR, 4000-400 cm-1) and far infrared (400-50 cm-1).

Only the MIR and NIR regions are typically used for food authentication, however. IR spectroscopy has

become an attractive, flexible research tool on account of its ease of operation and little sample preparation

required (Abbas et al., 2012; Rodriguez-Saona and Allendorf, 2011). Also, the high sensitivity and

specificity of IR spectroscopy has enabled its use as a fingerprint generator in food analysis. NIR

spectroscopy is based on the absorption of electromagnetic radiation at wavelengths over the range of 780-

2500 nm. NIR bands arise from molecular overtones and combinations of vibrational modes (Stuart,

2004). Mid-infrared (MIR) spectroscopy (4000-400 cm-1) is based on real-time monitoring of the

vibrations of functional groups and associated rotational-vibrational effects. Infrared spectroscopic

methods provide simple, expeditious, inexpensive tools for preliminary sample screening in routine

authentication analyses. NIR spectroscopy is particularly promising in this respect by virtue of its

expeditiousness, accuracy and ability to provide spectra for solid and liquid samples with no need for prior

manipulation (Blanco and Villarroya, 2002). Raman spectroscopy is a non-destructive measurement

technique based on Raman scattering of light from molecules, which results in shifted energy frequencies.

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Raman signals result from inelastic scattering of light samples, the resulting frequency shift containing

information about the vibrational modes involved (Craig et al., 2013; Larkin and Larkin, 2011). Raman

spectroscopy encompasses Fourier transform (FT) Raman spectroscopy, dispersive Raman spectroscopy,

spatially offset Raman spectroscopy (SORS) and surface-enhanced Raman spectroscopy (SERS). The

ensuing spectra can provide a fingerprint of a particular substance that is useful for analysing compounds

present in different samples; also, they provide the basis for structural and qualitative analyses (Yang and

Ying, 2011).

NIR, Raman and, mainly, MIR spectroscopy have been used to develop simple, fast methods for

authentication, quality control and adulteration detection in a variety of food products. Zhao et al., (2015)

used dispersive Raman spectroscopy in combination with multivariate data analysis to detect adulteration

of comminuted meat products with beef offal (kidney, liver, heart and lung). Georgouli et al., (2017)

proposed a method based on FTIR and Raman fingerprinting coupled with a novel dimension reduction

method for identifying adulterants such as hazelnut oil in extra virgin olive oil. Hussain et al., (2014)

examined the feasibility of discriminating pure canola oil from samples adulterated with palm oil by using

NIR spectroscopy coupled with multivariate analysis. Using LDA allowed adulterated samples to be

detected with an overall accuracy of 100% at a lowest detection level of 3.23%.

1.5.2.4. NUCLEAR MAGNETIC RESONANCE SPECTROSCOPY (NMR)

NMR-based metabolomics has proved to be an efficient method for authenticating food from raw materials

to end-product for quality control and the tracing of fraudulent labelling. Also, as shown by extensive

research, NMR spectroscopy has proved advantageous for the analysis of olive oil and a useful tool for

assessing its quality and authenticity. The two methodological approaches to metabolomics (viz.,

metabolic profiling and metabolic fingerprinting), and multivariate analysis methods for food

authentication, have proved effective in this field (Dais and Hatzakis, 2013). In the past decade, NMR

spectroscopy has been successfully used to analyse various types of edible oils for quality and authenticity.

Thus, Kim et al., (2015) confirmed the authenticity of sesame oils by using a combination of 1H-NMR

spectra and fatty acid profiles for the oils. Based on the results, the proposed method allowed the

authenticity of the samples to be accurately verified. The NMR spectrum can provide an informative

“fingerprint” for various agricultural products; in fact, it contains useful information about variety and

origin for classification purposes for example, Rezzi et al., (2005) used 1H-NMR fingerprinting of olive

oil from various Mediterranean areas to specify their geographical origin and year of production. Hohmann

et al., (2014) used 1H-NMR to authenticate organically produced tomatoes (Solanum lycopersicum). They

analysed tomato samples of two different cultivars from four different producers over a seven-month

period. PCA afforded differentiation between organically and conventionally produced tomatoes. Also,

LDA revealed significant differences between growing regimes and external validation confirmed 100%

accuracy in the classification of tomato samples.

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Figure 6: Picture showing an NMR spectrometer

1.5.3. STABLE ISOTOPE ANALYSIS

Of the many techniques available to aid in authenticity and traceability testing, the most widely used

method is isotope ratio mass spectrometry (IRMS). The reasons for this are the high accuracy method, the

small amount of sample required for analysis and the fact that the same technique can be used for almost

any type of food or beverage and the results are generally not altered by the production technique. Stable

isotope analysis has been used in food control, since around 1975, to detect adulteration of products like

wine, honey, fruit juice, or maple syrup with cheaper extenders, such as sugar syrup made from maize or

cane carbohydrates, industrially produced acids, or simply water (Rossmann, 2001). These “traditional”

applications of stable isotope analysis in food control rely on the measurement of the isotopic ratio of only

one or two elements (13C/12C and 18O/16O, 13C/12C and D/H). This can confirm if a certain component

of a food material was a non-natural (exogenous) additive from other plants or industrial production. More

recently, other applications based on multi-isotope ratio analysis (2H/1H or D/H, 13C/12C, 18O/16O,

15N/14N, 34S/32S, 87Sr/86Sr) have included geographical origin verification studies of olive oil (Camin

et al., 2010), orange fruit (Rummel et al., 2010), honey (Schellenberg et al., 2010), cereals (Goitom Asfaha

et al., 2011; Luo et al., 2015), tomato (Bontempo et al., 2011; Trincherini et al., 2014), Chinese cabbages

(Bong et al., 2012), animal products (Rees et al., 2016; Vinci et al., 2013) and feeds (Nietner et al., 2014),

seafood (Kim et al., 2015), and coffee (Santato et al., 2012).

1.5.4. DNA-BASED METHODS

DNA-based techniques have been highlighted for the authentication of processed foods, owing to their

sensitivity and accuracy regardless of growing condition, harvesting period, and manufacturing process.

Real-time PCR, a more recently developed technique, can detect multiple species from a mixture and

quantify the amount of PCR products formed during the amplification process (Arya et al., 2005).

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Moreover, its reliability, sensitivity, specificity and rapidity are suitable for the development of advanced

detection methods to regulate EMA foods and food allergens. Real-time PCR systems have been

previously used for the authentication of various foods including meat products, seafood products, dairy

products, spices and dietary supplements (Amaral et al., 2017; Di Pinto et al., 2000; Kang, 2018a, 2018b;

Kang and Tanaka, 2018; Kim et al., 2017; Kim et al., 2018; Taboada et al., 2017; Velasco et al., 2013), as

well as for the detection and quantification of allergenic foods including soybean, lupines, nuts,

crustaceans, and fish (Costa et al., 2017; Eischeid and Stadig, 2018; Fernandes et al., 2018; Garino et al.,

2016; Herrero et al., 2014; Villa et al., 2018).

1.5.5. EXAMPLES OF SPECTRAL DATA FOR VARIOUS FOOD PRODUCTS

Coffee: NMR spectroscopy was used to verify the presence of Arabica and Robusta species in coffee.

Lipophilic extracts of authentic roasted and green coffees showed the presence of established markers for

Robusta (16-O-methylcafestol (16-OMC)) and for Arabica (kahweol). The integration of the 16-OMC

signal (δ 3.165 ppm) was used to estimate the amount of Robusta in coffee blends with an approximate

limit of detection of 1–3% (Monakhova et al., 2015).

Figure 7: 1H NMR spectra in the region of the 16-OMC signal in experimental Arabica/Robusta mixtures

with 0–7% of Robusta content

Figure 8: 1H NMR spectrum of typical Robusta and Arabica coffees (roasted coffee, lipophilic extracts).

The following signals are marked: 16-OMC (a), caffeine (b), triglycerides (c), kahweol (d).

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Figure 9: The region of the 16-OMC signal for selected coffee samples.

Honey: The detection of the most common adulterations and quality deviations in honey were reported

by Spiteri et al., (2015). Also using 1H NMR profiling coupled with chemometric procedures, labelling

verification of monofloral and multifloral honey types was possible. With spiking experiments (i.e.

addition of pure compound into authentic food matrices), the authors showed that sugar addition down to

10% levels is detectable. In combination with chemometric procedures, quantification of regulated

parameters such as glucose, fructose, sucrose and hydroxymethylfurfural is possible within the same

NMR-experiment.

Figure 10: Overall 1H-NMR 95% confidence spectral envelope of the set of spectra from 26 BIPEA

Quality Control honey analyses performed over more than one month. In blue: 2.5% quantile, in red:

97.5% quantile, in green: median. The zooms are focused on spectral regions with smaller signals and

more discriminant information.

Cheese: FT-Raman spectroscopy was explored to evaluate spreadable cheese samples. A partial least

squares discriminant analysis was employed to identify the spreadable cheese samples containing starch.

To build the models, two types of samples were used: commercial samples and samples manufactured in

local industries. The method of supervised classification PLS-DA was employed to classify the samples

as adulterated or without starch. Multivariate regression was performed using the partial least squares

method to quantify the starch in the spreadable cheese. The limit of detection obtained for the model was

0.34% (w/w) and the limit of quantification was 1.14% (w/w). The reliability of the models was evaluated

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by determining the confidence interval, which was calculated using the bootstrap re-sampling technique

(de Sá Oliveira et al., 2016).

Figure 11: FT-Raman spectra of: (a) skimmed and (b) whole spreadable cheese

Figure 12: FT-Raman spectra of: (a) standard spreadable cheese, (b) 2% (w/w) starch, (c) 6% (w/w)

starch, (d) 10% (w/w) starch and (e) pure starch.

1.6. SUSTAINABLE DEVELOPMENT GOALS (SDGS): AN OVERVIEW

Historically, the idea of sustainable development (SD) was introduced in a paper called “Our Common

Future” by the UN Commission on Environment and Development (Brundtland Commission) report.

This definition promotes the need for growth to meet the needs of the present generation without

undermining the capacity of the future generation to meet their own needs (Brundtland et al., 1987).

Nevertheless, one of the key sustainability issues, according to Govindan et al., (2013) is to operationalize

the Brundtland Commission recommendations to guide organizational decisions. Sustainable

Development's new principles are becoming more and more relevant than they were two decades ago

because it goes beyond purely environmental, economic and social development issues and affects the

very life of people (Kumi et al., 2014). There is a need for science to support politics in this sense, as well

as coping with demands from the government and various shareholders when they are faced with the task

of achieving sustainable development (Aricò, 2014). The idea of creating the SDGs originated at the 2012

Rio+20 United Nations Summit in which Member States decided to adopt a set of guidelines for global

development with a view to growing the benchmark for developing countries and disadvantaged

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communities (Gupta and Vegelin, 2016), as well as building a stronger commitment to human-centred

growth, human rights and environmental sustainability. The Sustainable Development Goals were set

through a series of measurable goals and required a great deal of global cooperation and commitment at

several levels when it came to monitoring, which is sadly seldom even feasible (Giupponi and Gain, 2016).

The Rio+20 Conference endorsed a mechanism in its final document, “The Future We Want”, while

rejecting several others, in order to negotiate a consensus on the Sustainable Development Goals (UN,

2012). Consequently, the outcome of Rio+20 was structured in many respects to be qualitatively different

from the Millennium Development Goals (MDGs) and the Sustainable Development Goals (SDGs) aimed

at being more responsive to a variety of stakeholders at multiple levels of governance (Gellers, 2016).

Following “The Future We Want”, the UN document “Transforming Our World: The Sustainable

Development Agenda 2030” contains a declaration of the 17 SDGs and 169 targets, as well as monitoring

and assessment mechanisms (Gupta and Vegelin, 2016). The Sustainable Development Goals were

developed through a comprehensive participatory mechanism and progressed through high-level

committees such as “Open Working Groups” (OWG) along with various inquiries until the Heads of

State finally approved a negotiated agreement. Five key areas have been identified by the Heads of State

or the Five Ps of the 2030 SDG Agenda, which are people, planet, prosperity, peace, and partnerships

(Jayasooria, 2016). As Aitsi-Selmi et al., (2016) reports, 193 countries agreed on the Sustainable

Development Goals, predecessors of the Millennium Development Goals, in September 2015 in New

York, USA, focusing on an extremely comprehensive set of development goals. The Sustainable

Development Goals outlined sensitivities to weaknesses created by gender, age, and disabilities when it

comes to losses and disasters. Nevertheless, like the MDGs, the SDGs do not include, in an ecological

sense, a particular and consistent goal relevant to world population growth and the new targets for 2030

(Bergaglio, 2016). Subsequently, the SDGs have the ability to mobilize academic groups and social

movements around them to seek structural reform and responsibility for those who carry out the objectives.

Therefore, they may be reinforced by the commitment to equitable standards of growth towards all

stakeholders concerned (Gupta and Vegelin, 2016). To this end, it is the primary responsibility of each

government, state or country to mobilize and collect financial resources, which in turn would promote new

partnerships between the private sector and civil society (Jayasooria, 2016). According to Stafford-Smith

et al., (2016), the SDGs’ objectives established an agenda for the sustainable development of all nations

that adhered to economic growth, social inclusion and protection of the environment and includes:

• Goal 1: No poverty

• Goal 2: Zero hunger

• Goal 3: Good health and well being

• Goal 4: Quality education

• Goal 5: Gender equality

• Goal 6: Clean water and sanitation

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• Goal 7: Affordable and clean energy

• Goal 8: Decent work and economic growth

• Goal 9: Industry, innovation and infrastructure

• Goal 10: Reduced inequalities

• Goal 11: Sustainable cities and communities

• Goal 12: Responsible consumption and production

• Goal 13: Climate action

• Goal 14: Life below water

• Goal 15: Life on land

• Goal 16: Peace, justice and strong institutions

• Goal 17: Partnerships for the goals

1.7. NIGERIA: AN OVERVIEW

Nigeria, officially the Federal Republic of Nigeria, is a country in West Africa, bordering Niger in the

north, Chad in the northeast, Cameroon in the east and Benin in the west. Its coast in the south is located

on the Gulf of Guinea in the Atlantic Ocean. It comprises of 36 states and 1 Federal Capital Territory,

where the capital Abuja, is located and 774 local government areas. The states are grouped into six distinct

geopolitical zones – North Central, North East, North West, South East, South South and South West

(Figure 1). Nigeria is often referred to as the ‘Giant of Africa’, owing to its large population and economy.

The current population of Nigeria is 202 million based on the latest United Nations data (Worldometers,

2019), ranking Nigeria as the most populous country in Africa and the seventh most populous country in

the World. Nigeria has a total area of 923,768 km2 (356,669 sq. mi), making it the world’s 32nd largest

country. It is comparable in size to Venezuela, and is about twice the size of the US state of California. Its

borders span 4,047 kilometres (2,515 mi), and it shares borders with Benin (773 km or 480 mi), Niger (1,

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497 km or 930 mi), Chad (87 km or 54 mi) and Cameroon (1,690 km or 1,050 mi). Its coastline is least

853 km (530mi).

Figure 14: Map of Nigeria showing the six geopolitical zones

Nigeria has been a developing economy with her economic growth being unstable, unpredictable and

unsatisfactorily low in recent years especially when compared with some other nations of the world

(Machi, 2011). As the largest exporter of oil in Africa and an oil dependent economy, the country has

witnessed many oil prices shocks and disturbances over the years due to oil price volatility in the

international market. The oil price has been fluctuating since the 1980s and the 1990s due to activities of

the world powers in the global market. Apart from the incessant drop in the price of oil in the past, the

recent notable one was the drastic fall of the oil price from $112 per barrel in 2014 to almost $38 per barrel

as at the end of 2015 due to the incessant and massive supply of Shale oil by the United States to the global

market (British Petroleum Statistical Review of World Energy, 2017). In 2014, according to International

Energy Agency (IEA, 2015), Nigeria earned $77 billion from oil export. However, with the fall in oil price

in 2015, Nigeria’s oil revenue fell to $41.33 billion (OPEC Annual Statistical Bulletin, 2016). By

implication, the fall in oil price in the global market implies fall in the revenue accruing to the Nigerian

economy and difficulties in achieving a sustainable level of growth. The reason being that over 80 percent

of the government revenue comes from oil export. In addition, the monolithic nature of the Nigerian

economy since the start of oil exploration in the 1970s has been persistently threatened by the fluctuation

in oil prices. This has made the government to come to terms with the growing need for economic

diversification from oil to non-oil economy. In the 1960s, prior to the discovery of oil, more than 70% of

the rural population of Nigeria engaged in one type of agricultural activity or the other and between 1963

and 1964, the non-oil sector contributed as much as 65% to the Nation’s Gross Domestic Product (GDP)

(Yesufu, 1996). However, the oil boom of 1973/74 changed the economic environment drastically as the

windfall from oil boom around this time had a pervasive effect on the Nigerian economy even till the early

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1980s. The shocks nevertheless, slowed-down the economic activity and as a result caused severe fiscal

imbalances for Nigeria and oil revenues decreased drastically (Audu, 2012). The over reliance on the

exogenous and volatile nature of oil revenue led the Nigeria government to make structural changes in

order to look into alternative means of financing the economy by reconsidering the non-oil sector that had

been neglected in the past due to oil exploration (Edame and Efefiom, 2013). After decades of neglect, the

Federal Government of Nigeria began to reform the agricultural sector in 2011 following strategic

direction laid out in the Agricultural Transformation Agenda (ATA) of the Federal Ministry of Agriculture

and Rural Development (FMARD) (FMARD, 2016). The ATA’s core purpose was to help Nigeria to

refocus federal government policymaker attention to agriculture, and the strategy’s main goal was to

rebuild the agricultural sector (FMARD, 2016). The current development strategy of the agricultural

sector – denoted the Agriculture Promotion Policy (APP) – builds on and refines the strategic direction of

the ATA. The APP was launched in 2016 and applies for the five-year period lasting until 2020. It aims at

addressing two key challenges of Nigeria’s agriculture: (1) to meet the food needs of a rapidly growing

population with domestically produced food; and (2) to transform the agricultural sector so that Nigeria

becomes a successful exporter of agricultural products complying with international quality standards

(FMARD, 2016). Thus, agricultural transformation has been at the centre of Nigeria’s agricultural

development policy plan since the beginning of the 2010s. Yet, despite its vast agricultural potential,

Nigeria imports food – mostly staple foods – worth billions of dollars annually. Many Nigerians and even

a large proportion among the farming population lack adequate food for a healthy diet and suffer from

malnutrition.

1.8. AIMS AND OBJECTIVES

The aims and objectives of this research project is to carry out an investigative study on the challenges of

food fraud in Nigeria, identifying the risks and proposing solutions. At the end, this research project will

seek to determine the following key areas:

• To address the level of food fraud and its impact in attaining sustainable economic growth in

Nigeria.

• To identify lack of food policies and national control systems that will enforce regulations in

tackling food fraud in Nigeria.

• To identify how regulatory and government agencies can promote food safety that will enhance

good health and wellbeing among consumers in Nigeria.

• To propose measures that regulatory and government agencies in Nigeria can adopt in preventing

food fraud.

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2. METHODOLOGY

2.1. Data Collection

An internet search was conducted using food fraud and Nigeria as key words. Data sources including

online newspapers, ScienceDirect, Google Scholar, Google Books as well as other scholarly articles and

journals were used to gather data from scientific studies. However, there was very limited quantity of data

available on food fraud cases in Nigeria though cases of food fraud has been reported on various Nigerian

online newspapers and from the recall and alert notifications of the National Agency for Food and Drug

Administration and Control (NAFDAC) which is the leading agency in food safety and regulation in

Nigeria. After an initial comprehensive review of publicly available data, gaps of data were identified.

From the identification of the data gaps, non-formal interviews were undertaken with key regulatory

officials in an attempt to fill these gaps. Therefore, this project relies on data that is publicly available and

interview accounts to provide a detailed overview of food fraud in Nigeria. Given the commercial

sensitivity issues surrounding data collection, interviewee identities were kept anonymous throughout this

report.

2.2. Interview Questions

• What are the food commodities that are commonly adulterated in Nigeria?

• Why are food laws in Nigeria poorly implemented and why are food commodities still adulterated

in the Nigerian markets?

• Are there publications, published research articles or a food database where cases of food fraud

have been documented in Nigeria for the last 10 years?

• What are the processes for recalling adulterated food commodities and issuing food safety alerts?

• How does the regulatory processes in NAFDAC work and who develops the regulations?

• What are the roles of the risk assessors and risk managers in food safety management?

• What has NAFDAC done in tackling cases of food fraud in Nigeria?

• What is the relevance of NAFDAC and other agencies, both locally and internationally in tackling

food fraud?

• What has NAFDAC done in promoting food safety in Nigeria and its relevance with the UN

Sustainable Development Goals (SDGs)?

2.3. Survey Questionnaire Design

An online survey questionnaire was designed using SurveyMonkey containing 13 questions, some of

which were multiple choice and the remaining being open-ended questions. The survey was distributed

via social media such as Facebook, WhatsApp and LinkedIn. Subsequently, a paper-based survey

questionnaire alongside an informed consent form and information sheet, was sent to participants via

email.

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2.4. Data Analysis

The results from the survey was analysed on SurveyMonkey by creating custom charts and data tables,

filtering and comparing results and exporting results in various formats. The results from the interviews

were analysed in order to identify common themes among the responses of the interviewees and

consumers.

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3. FOOD FRAUD – CURRENT STATUS IN NIGERIA

3.1. Food Smuggling and Trafficking

Smuggling is the illicit cross-border trade of goods (Joosen and Raw, 2012); the importation of contraband

goods (Ferrier, 2009) or the movement of goods into or out of a country or trading area often to avoid

tariffs or legal obligations. Smuggling is an ancient practice and is one part of a wider set of informal,

illicit or illegal economic activities that are not effectively controlled by government (Hartnett and Dawdy,

2013). Illicit trade is “any statute prohibited action or conduct relating to production, shipping,

acquisition, storage, delivery, sale or purchase, including any practice or conduct intended to

encourage such activity” (WHO, 2003). Illicit trading is defined by the quality of the goods (Bevan et

al., 1988), for example, “black goods” are illegal, whereas “black parallel markets” describe legal goods

that are exchanged illegally at the supply chain level rather than individual actors operating in a supply

chain that is otherwise legitimate. Terms used to describe illegal goods include black, dark, second,

parallel, secret, shadow, underground, unreported, unrecorded, covert or illegal goods (Feige, 1990).

Consequently, illicitness is not an intrinsic property of commodities or of particular economic actors, but

rather a temporary quality attribute that is often related to the distribution or circulation mechanisms of a

food item (Gregson and Crang, 2016). The Global Food Safety Initiative Position Paper on Food Fraud

(GFSI, 2014) states that “food fraud, including economically motivated adulteration subcategory, is of

increasing concern. Consumers are misled by the use of food products, ingredients and labelling for

economic gain and include substitution, unapproved modifications, misbranding, counterfeiting, stolen or

other goods”. The definition does not include trafficking and smuggling of food directly. Spink et al.,

(2016) however, found smuggling to be a form of food trafficking. Translating concepts of human

smuggling and trafficking, food smuggling can be defined as when all parties involved, except regulatory

and enforcement agencies, completely agree to illegal behaviour, while food trafficking requires violence

against one or more parties, but sometimes the fine line between smuggling and trafficking is ambiguous

(Butterly, 2014). Díaz (2015) distinguishes between small, petty smuggling (for personal use) and skilled

smuggling or profit trafficking where a large volume of goods is transported via international shipping

channels (Ferrier, 2009). Many food products are subject to additional import tariffs to protect national

farmers (Lotta and Bogue, 2015). It illustrates the economic driver to participate in such activity for

individuals and organizations. Joossens and Raw (2012) distinguished between tax avoidance, legal and

legitimate activity, as well as tax evasion, illegal activity, conducted to pay less or no tax. Smuggling to

achieve economic advantage is global. The cross-border smuggling of food and other goods is troublesome

and has a direct impact on the economic growth of affected countries (Chen-Charpentier et al., 2015). The

economic incentive for smuggling is the size of the difference between the price of a food in the country

of origin and the price in the country of destination (Ferrier, 2009), citing examples of sugar, wheat and

rice (Golub and Mbaye, 2007). Factors that may result in “black” economic activity include high taxes or

complex tax structures, low tax morale, low Gross Domestic Product, poor institutions and corruption

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(Snowdon, 2012). Differences in recorded prevalence rates of smuggling between countries are due to the

types of goods affected by any trade prohibitions, the degree of non-transparency of smuggled goods, the

ease of putting improperly classified materials on manifest papers, and the targeting of any enforcement

resources including purposive sampling (Ferrier, 2009).

For example, rice (Oryza sativa L) is a major dietary component in most countries, providing around 20%

of the world's dietary energy supply (Deepak and Prem, 2017; FAO, 2006; Vlachos and Arvanitoyannis,

2008). Rice is consumed when boiled or fried in Nigeria, and previous reports suggest that an average

Nigerian consumes about 21 kg of rice per year (Odenigbo et al., 2014). While rice is primarily used as a

staple food due to its high carbohydrate content, it also contains significant amounts of proteins, lipids,

minerals, and water-soluble vitamins such as thiamine, riboflavin, and niacin (Fresco, 2005; Mohammad

et al., 2012). Despite Nigeria’s rise in rice production, consumer demand for it far exceeds supply.

Therefore, Nigeria’s increase in rice import exceeds over the past decade. Recently, developing countries’

declining economies have forced the Nigerian government to implement policies such as massive rice

production programs that promote increased local rice production. Despite these measures, some

businesses are still engaging in rice imports, possibly due to some individuals and others’ preference for

foreign rice. The preferences of consumers between local rice, imported rice and other staple foods are not

influenced by relative price changes alone. The recent history of rice growth in West Africa indicates that

there is a peaceful coexistence between local rice production and rice imports, following radical changes

in trade policy and changes in the macroeconomic environment at the local and international level. This

Western African business structure was not significantly affected by changes in tariff policy or the rise in

international prices. Due to the different quality attributes of local and imported rices, this led to

segmentation of the West African market. Meanwhile, importers in charge of logistical functions

(treatment, storage, conditioning) and supply networks of retailers are driving the value chain for imported

rice, primarily in urban areas but increasingly also in rural areas. Imported rice is often sold in near-market

grocery stores in combination with other basic goods (e.g. oil, sugar, flour). Such retailer categories sell

local rice very rarely, although they do so in countries where local rice production is sufficiently large and

can be regularly supplied. On the other hand, local rice retailers add imported rice to their list of staple

foods.

Paradoxically, the rice trade liberalization proponents and their critics supporting higher tariff regulation

and control of rice imports follow the same concept of how the rice market works. Both assume that West

Africa rice markets are efficient and capable of delivering price opportunities that will cause a shift in the

actions of rice market players. Such two trade policy choices are expected to be optimal replacements for

local and imported rice, but this theory is not routinely confirmed. Consumers in Guinea, for example,

have a strong preference for local rice, which is usually sold at a higher price than imported rice, whereas

consumers in Nigeria and Ghana, who do not have the same rice eating culture, prefer imported parboiled

rice, even when the tariff makes its price much higher than the local one. A survey of the preferences of

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West African consumers found that even when they value the organoleptic properties of local rice, they

give greater consideration to quality attributes related to marketing and processing (Chohin-Kuper et al.,

1999; Demont et al., 2013; Demont and Ndour, 2015). Therefore, a large proportion of urban customers

put more value on the market quality attributes than the organoleptic ones. Many consumers buy imported

rice rather than local rice because their quality is more homogeneous, they are cleaner and packaged better,

and they are available throughout the year.

In addition, imported rice retailers that profit from credit provided by their wholesaler are able to provide

credit to their customers, while local rice retailers are not; this strengthens the market position of imported

rice over local rice. Nigerian borders are notoriously porous and several reports have established how

numerous goods including rice, find their way into the country through the borders, especially the ones

adjoining Benin Republic (Premium Times, 2019). According to a news report by the Comptroller-General

of the Nigerian Customs Service, 99 percent of rice smuggled through the land borders are unfit for

consumption. He further revealed that rice is mixed with other grain bags or stuffed inside any available

crevice and compartments of vehicles, including the engine area to deceive custom service officials. The

concealed rice is thereafter re-bagged half cooked and presented in the markets for sale as imported rice.

Often times, importers in the borders re-bagged expired rice to prolong their shelf life and as a result, rice

being a perishable product, loses valuable shelf life in non-conducive storage conditions (Premium Times,

2016). In late August 2019, Nigerian President Muhammadu Buhari ordered the partial closure of its

boundary with Benin to curb rice smuggling. His administration further banned trading across all land

borders to force neighbours Benin and Niger to halt food smuggling into the country (Bloomberg, 2019).

3.2. Street Food Practices

Safe food supply is a fundamental human right, leading to sound health, prosperity, and a platform for

sustainable development and poverty alleviation. Street foods are enjoying increasing patronage due to

industrialization, which causes many urban residents to eat their daily meals out of their homes (Alimi et

al., 2014). Street food vending is a common feature of most cities and towns in developing countries

(Ekanem, 1998). Street food is ready-to-eat food and beverage prepared and sold for immediate

consumption by vendors and hawkers, especially in the streets and other public places (WHO, 1996; WHO

/ FAO, 2015). Street food safety depends on the quality of raw materials, food preparation, handling and

storage practices. Therefore, any person who handles food, irrespective of whether they prepare or serve

it, is a food vendor (Isara and Isah, 2009). Street food vendors (SFVs) are divided into two groups: mobile

vendors; moving from place to place with prepared and packaged food intended for sale on their heads,

carts, bicycles, motorcycles or tricycles (Abdalla et al., 2009) and stationery vendors; having developed

stalls where food is prepared, processed and served to consumers (Almeida et al., 1996). Mobile and

stationery food vendors work day and night in parking lots, warehouses, markets and schools to name a

few, where multiple customers are present. Due to increased tourism, the street food vending of the

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economy has extended to low and middle-income countries and provided access to a range of affordable

food to a variety of consumers (Chukuezi, 2010). Apart from delivering ready-made meals at relatively

low prices, teeming urban dwellers are addicted to street foods due to their gustatory attributes. Such

qualities are associated with the vendors’ culinary prowess (Choudhury et al., 2011; Alimi et al., 2016).

Akinyele (1998) reported that millions of practitioners along the chain have made a significant

contribution of street foods to nutrition and food security. They were also described by Draper (1996) as

possible vehicles for fortification of micronutrients. Street food vendors have been an integral part of the

supply chain in many developing countries, including Nigeria, particularly after the advent of urbanization

(Akintaro, 2012). The street food industry has made a significant contribution to human and economic

development, as studies in some African countries such as Nigeria, Morocco and Kenya have shown that

major street food vendors usually earn more than the minimum wage of these countries (Omemu and

Aderoju, 2008; Ifenkwe, 2012; Mwangi, 2002). It has been reported that the street food sector has a socio-

economic role in terms of its job creation potential, yielding income especially for women, and providing

food at affordable cost to lower city income groups (Tavonga, 2014). Across Nigeria, inhabitants of urban

cities spend as much as half of their street food budget (Cohen and Garnet, 2002). In most developing

countries, street food vending are largely outside of government regulation and security. Due to the

informal nature of the organization and the lack of official data on the volume of trade involved, the

economic value of the operations is not well understood (Alimi and Workneh, 2016). The sector, however,

is full of unhealthy activities that have been reported to raise serious concerns about the safety of

practitioners, especially consumer health (Muyanja et al., 2011). Such unhealthy practices spanned the

entire street food business chain from agricultural raw materials to the final street food retail and were

fingered in the outbreaks of illnesses and diseases (Akinbode et al., 2011). It has been stated that the

prevention, conservation and treatment of diseases from street food borne illnesses has resulted in the

heavy drain on individuals and governments’ purses in developing countries due to huge expenditure

(Ekanem, 1998). The street food market in Nigeria, as in other developing countries, is facing challenges.

The risk factors, also known as danger points, permeate the entire street food business chain and are listed

below:

3.2.1. Sources and quality of raw foods and ingredients

The vendors’ desire for profit maximization or the need to make street foods accessible to customers make

certain vendors patronize cheap and unhealthy ingredients that can threaten consumers’ health. Results of

survey conducted by Omemu and Aderoju (2008) showed that vendors of street foods in Nigeria

considered the volume (94%) and the price (93%) than the freshness and cleanliness when buying raw

foods to be cooked or vended. In a study conducted in India, Choudhury et al., (2011) observed that

procurement habits of food items by street vendors differ according to the size of the establishments and

was significantly (p < 0.05) influenced by the type of vendors, ownership and average monthly income.

The study reported that from grocery stores, both mobile vendors and small restaurant owners procure

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unlabeled and unpacked food grains and semi-processed ingredients. While the majority (87%) of small

restaurant owners procure branded and packaged condiments, dry fruits and spices from grocery stores,

most (44%) of mobile food vendors buy condiments and spices, nuts and dry fruits from traditional weekly

or daily markets with 37% of them being cooked, dried and powdered at home. Nearly 56 percent of

mobile vendors used spices and condiments unlabeled and unpacked. Studies have shown that home-made

cereal flour and condiments used in street food preparations are contaminated with Bacillus cereus (Umoh

and Odoba, 1999; Obuekwe and Ogbimi, 1989; Yusuf et al., (1992)) which was allegedly responsible for

food-borne disease outbreaks (Gilbert, 1979). The highest frequency of Bacillus cereus recorded by Umoh

and Odoba (1999) observed for “kunu”, a fermented cereal product in West Africa was the result of local

spices and raw materials used as condiments in their survey of microbial quality of street foods sold in the

streets of Zaria, Nigeria.

3.2.2. Food preparation, handling and vending

The temperatures used in cooking and frying during street food preparations are high enough to destroy

the vegetative cells, but microorganisms’ resistant spores can survive (Bryan et al., 1988). Nevertheless,

street foods are being cooked, treated and marketed in ways and habits that predispose them to

recontamination, cross contamination and transmission of pathogens and food-borne diseases. Some street

foods are usually prepared in bulk ahead of sale at different times (Umoh and Odoba, 1999). The long

holding period of more than 6 h, sometimes at ambient temperature (Muyanja et al., 2011), was reported

to be a common factor contributing to food-borne disease through multiplication of microorganisms

favored by holding temperatures between 5 and 60 ° C (described as a danger zone). Mosupye and von

Holy (2000) proposed that the high load of Bacillus spp. may be responsible for holding conditions that

favored the survival and germination of Bacillus spores isolated in ready-to-eat food on the street. The

mode of transportation plays a significant role in street food contamination. Transportation and display of

meat has been reported to play an important role in accelerating their spoilage and zoonotic disease

transmission (Okoli et al., 2005). The manner in which animal carcasses are transported from slaughter

points to distribution points in crude structures such as wooden carts, open plastic or aluminum trays on

heads or “off-road” vehicles has increased the likelihood of cross contamination. Okoli et al., (2005) stated

that vehicles not equipped for meat transport such as taxis and buses without cooling facilities and even

motorcycles carrying meat products from slaughter points to retail outlets are a common site in Nigeria.

Okoli et al., (2005) maintained that it is not unusual to see butchers and retailers turning carcass meat for

human consumption into sitting or resting platforms in the vehicles during the cause of transportation.

Meats are retailed in open wooden trays in the markets and streets of Africa, which are typically difficult

to wash thoroughly, thereby harboring niches for meat contamination by microorganisms and deposition

of airborne pollutants. In the streets of Johannesburg, South Africa, Mosupye and von Holy (2000)

recorded high aerobic plate and spore counts of 7.6 and 2.2 log cfu/g in raw beef/chicken for retail. Some

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studies reported high loads of microorganisms, despite high processing temperatures, exceeding

acceptable tolerable amounts from some processed meats for street vending.

In processed beef and chicken sold in the streets of Zambia and Nigeria, Bryan et al., (1997) and Ekanem

(1998) recorded high levels of coliforms greater than 105 cfu/g. Lues et al., (2006) attributed high levels

of microorganisms extracted from processed meats to re-contamination by vendors’ hands, utensils, and

vending environment. Non-regulation of time and holding temperature are recognized as major risk factors

in street foods that lead to the outbreak of diseases (Muyanja et al., 2011). The majority of vendors in

Abeokuta, Nigeria (90%) and Ozamiz, Philippines (55%) prepared their goods on the morning of sale

(Omemu and Aderoju, 2008; Canini et al., 2013), while the majority of vendors in Kampala, Uganda

cooked on-site food (75%) and well ahead of consumption (77%) (Muyanja et al., 2011). Certain risk

factors found in the preparation and handling of street foods include: widespread use of stove charcoal for

food storage and heating over a long period of time, which may not provide adequate temperature to

prevent the spread of pathogenic microorganisms (Lues et al., 2006; Bryan et al., 1996)) as heating of food

at temperatures below 40℃ could increase Salmonella contamination (Cardinale et al., 2005), overheating

at higher temperatures may lead to the loss of essential nutrients and flavours in the food; the retention of

food at ground level and the incessant uncovering of foods for dispensing of exposed street foods to dust

contamination and flies associated with food-borne diseases such as cholera and diarrhoeal (Sukontason

et al., 2000). Mosupye and von Holy (2000) found that when vendors were serving customers, ready-to-

eat food could be left uncovered for up to 10 minutes. Umoh and Odoba (1999) confirmed that more than

13 percent of street foods surveyed in Zaria, Nigeria were contaminated with Salmonella aureus of which

43.8% were haemolytic strains and 18% enterotoxigenic. The study described post-processing handling

as the major cause of contamination as the high processing temperature and low water activity of most

foods surveyed were enough to prevent the proliferation of microorganisms and the production of toxins

that are harmful to human health.

3.2.3. Vending environments

Reports also raised serious concerns about the vulnerability and exposure of street foods in the vending

environments. Street food vendors tend to target high-traffic areas for showcasing their goods to boost

sales. Street food vending are common in areas such as major street corners, industrial/building sites,

bus/train terminals, public places and school compounds (Akinbode et al., 2011). The vending units are

either mobile or stationary with open or covered crude structures such as push carts, wooden tables,

aluminum trays, bowls or chop bars (Canini et al., 2013). Retailing of a street food along a major street in

a developing country is shown in Fig. 15.

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Figure 15: Street food retailing on major street.

The conditions in which street foods are cooked, sold and eaten have predisposed them to recontamination

and cross-contamination from contaminants of the environment, such as airborne chemicals in dust,

exhaust discharges from moving vehicles and industrial engines, burning fumes and offensive smell from

accumulated waste and industrial discharges, insects and rodents (Proietti et al., 2014; Mensah, 2002).

Airborne pathogens and microbes that can be pathogenic if allowed to settle on the prepared food surfaces

abound in dust (Muyanja et al., 2011). Bryan et al., (1997) observed large heaps of garbage accumulated

around street food vending sites in Zambia that harboured insects and rodents (known as disease vectors).

It has also been stated that littering is common practice at Uganda’s vending sites (Muyanja et al., 2011).

Since consumer proximity is the primary goal of street food suppliers, vending sites usually lack basic

facilities such as toilets, hand washing facilities, drinking water, adequate drainage and waste disposal

system (Idowu and Roland, 2006). Where some of these facilities are established, large concentrations of

vendors in congested human areas tend to place severe strain on them, resulting in conflict with city plans

and adverse effects on daily life (Muyanja et al., 2011). All of these factors increase the incidence of food

borne illnesses and disease transmission among vast street food consumers (Ekanem, 1998).

3.2.4. Hygiene practices

Several studies of street food hygienic practices verified by WHO (1984) suggest that most street food

vendors have knowledge of hygienic practices, but concluded that most of them do not put the knowledge

into practice (Muyanja et al., 2011; Lues et al., 2006; Omemu and Aderoju, 2008). While street vendors

were stated to have good personal cares, they were lax at the preparation and vending sites to comply with

correct hygienic practices. This was mostly due to non-compliance with basic hygiene standards,

insufficiency or near absence of basic facilities at the vending sites. Benny-Olivierra and Badrie (2007)

analysis of hygienic practices by street food vendors inTrinidad, West Indies recorded that most of the

sites surveyed did not have pipe-borne water, 97.5 percent did not have drain to channel waste water and

toilet facilities. Regarding street food vending sites in Kingston, Jamaica (Powell et al., 1990), Lima, Peru

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(Bhat and Waghray, 2000), Philippines (Azanza et al., 2000) and Uganda (Muyanja et al., 2011), the result

was no different The shortage of toilet and washing facilities at the vending sites forced most street food

hawkers to check for secluded areas in the vicinity such as bushes and abandoned buildings for excretion.

Idowu and Rowland (2006) reported that most street food vendors in Abeokuta, Nigeria used dung hills

and nearby bushes instead of toilets and cleaned up with paper sheets. Open bins have been commonly

used to collect garbage. Muyanja et al., (2011), however, reported that 92.8 percent of vendors in Kampala,

Uganda used gunny bags for waste collection. Several studies have documented that the overflowing of

garbage bins was a common site at most vending points, whereas the final disposal of garbage is normally

far from vending sites. Heaps of garbage around the vending sites may serve as breeding grounds for rats,

insects, and flies that encourage microorganism proliferation and increase the risk of food contamination

and disease transmission (Umoh and Odoba, 1999; Mensah et al., 2002).

3.2.5. Agricultural practices

The growing world population is placing enormous pressure on the production of food. The corresponding

effect is the increasing need to optimize available resources to feed the growing population for improved

farm yield. Farmers use inorganic agrochemicals and organic manure to increase farm yields, avoid weed

competition and maintain quality by preventing insect infestation and microorganism spoilage on the field

and during storage. In developed countries, the use of these chemicals is well regulated by the enactment

and implementation of acts and laws that govern and restrict their use for agricultural practices. Such laws

are intended to avoid the residual effect on users of these chemicals (Harris, 2002). Among developing

countries, however, where farmers use excessive pesticides to produce bumper yields, the opposite is the

case. Farmers also patronize easily synthesized, inexpensive and expired chemicals in developing

countries (Carvalho, 2006). Residues from excessive chemical applications to improve farming operations

have been identified at high levels in soil, livestock and aquatic animals (Carvalho, 2006; Taylor et al.,

2003). A significant relationship between residual chemical accumulation in soil and absorption by crops,

livestock and aquatic animals has been identified (Carvalho, 2006; Wang et al., 2006). Scientific research

has shown that residual agrochemicals in foods are harmful to human health. In the human system, the

accumulation of foreign chemicals such as lead (Pb), arsenic (As), cadmium (Cd), copper (Cu) and

mercury (Hg) was linked to immune suppression, hypersensitivity to chemical agents, breast cancer,

decreased sperm count and infertility (Uri, 1997; Sharpe, 1999).

3.3. Nigerian Food Fraud Incidents/fraudulent commodities

Food fraud is a prevalent problem in Nigeria. On the 28th of November 2019, the management of the

National Agency for Food and Drug Administration and Control (NAFDAC) issued an alert on the

unscrupulous activities of business men and traders who revalidate expired rice and also repackage local

rice as foreign rice. The Ogun State office of the agency received the report from the Department of State

Services (DSS) in the state, of ongoing food fraud at Oke-Aje market in Ijebu Ode. On the 14th of

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November 2019, Officers of the state office in company of officers of the Nigerian Police Force proceeded

to the scene of the illegal activity. On arrival, the suspected perpetrators of the food fraud instigated

unnamed persons to unleash mayhem on the team of investigators. However, enforcement officers of the

agency and its federal task force team stormed the market in company of Department of State Service

officials. They sited the perpetrators at the market who took to their heels and discovered expired rice,

caked rice, bags of local rice, bags of popular foreign rice and sealing machines at the shops. The

NAFDAC enforcement team gained access into the shops and sealed three shops during the operation. The

management of the agency noted that expired and caked rice are unwholesome as they contain moulds and

microorganisms that cause diseases which are of immense public health concern (NAFDAC, 2019a).

Similarly, on the 11th of November 2019, the agency issued an alert to the public on frozen raspberries

contaminated with norovirus from China. The contamination of the frozen raspberries with norovirus was

detected in Germany with some of the contaminated products being exported to Nigeria from Germany.

The agency warned members of the public not to consume the contaminated frozen raspberries as

norovirus is a highly infectious virus that causes vomiting and diarrhoea, and implored importers to desist

from importing the contaminated product to Nigeria (NAFDAC, 2019b). Major convictions of Nigerian

importers and business traders took place between 2017-2019. For example, Mrs Esther Akinsanya, a

business woman and her company in a popular market in Lagos, was convicted on the 30th of November,

2018 by the Federal High Court in Lagos for rebagging smuggled, adulterated and misbranded sugar. She

was fined the sum of ₦1,300,000.00 ($3,611.00) and ordered by the court to bear the cost of destruction.

On the 5th of December, 2018, operatives of the agency in Katsina State arrested three suspects for the

sale and distribution of banned and rebagged suagr. The suspects were convicted by the Federal High

Court in Katsina and fined the sum of ₦100,050.00 ($277,91.00) each. The court ordered the forfeiture of

the products to NAFDAC for destruction and the cost to be borne by the convicts. Okey Joseph Okeke, a

business man was arraigned at the Federal High Court, Akwa, Anambra State on 29th April, 2018 for the

sale of unwholesome processed foods including vegetable cooking oil, extra virgin cooking oil, alcoholic

whisky and vodka. Also, Mrs Nkiru Okoro of Ezedams Enterprises Nigeria Ltd. was investigated for

illegal production of counterfeit alcoholic beverages and obstruction of NAFDAC officers in the course

of their operation. She was arraigned at the Federal High Court, Lagos on 27th June, 2019 (NAFDAC,

2019c).

3.4. Food control systems

Food control systems were identified by the Food and Agricultural Organization (FAO)/World Health

Organization (WHO) and subsequently by numerous researchers (Anyanwu and Jukes, 1990; Neeliah and

Goburdhun, 2007, Nguz, 2007, Whitehead, 1995) many of whom also reported food control systems in

their countries or other countries. Nonetheless, a reasonable description of food control systems must be

given before the goals and components of such a system are defined. In accordance with the FAO/WHO

authority on food control systems, the term that defines such systems as “the mandatory regulatory activity

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by national or local authorities to implement food laws and regulations” (FAO/WHO, 2003) is recognized

and used here. According to this definition, the food control system depends on food-related legislation

and proper implementation of these regulations, the former of which is enacted as a result of pressure from

the system’s specific objectives. Such objectives have been described as the need to protect consumers by

ensuring that food produced during the stages of handling, storage, processing and distribution is safe for

consumption (FAO/WHO, 2003). The aim is to facilitate trade in foodstuffs for economic development

(FAO/WHO, 2003), a goal that was later emphasized due to the global increase in food trade. The goals

of a food control system are accomplished through the roles of different components of the food control

system that operate together. Food law enforcement (inspection and analytical services); information,

education, communication and training (IECT) as well as food management and administration

(FAO/WHO, 2003) are included in the FAO/WHO (2003) documents. Food laws provide the

government’s mandate to carry out food control activities while inspection and analytical services are

necessary to assess compliance with published laws by manufacturers, producers or importers. IECT refers

to the training of system personnel, communication of government decisions and contact between various

system agencies/components and system stakeholders (FAO/WHO, 2003). IECT also refers to the duty of

the government to adequately educate consumers and other stakeholders (including manufacturers) on the

functions of the food control system and the need for food safety and quality within the country.

Food control systems may vary in structure and the FAO/WHO (2003) has identified three types of these

systems where the first category is distinguished by the structure and functions of the food control system

being divided, typically into different government departments or levels of government (FAO/WHO,

2003). This is referred to as multiple agency food control system and division can be horizontal as well as

vertical where food law drafting, inspection and analytical services and IECT are physically and

functionally separated into different departments of the same government. An example of this type of food

control system is the United States of America (USA) where the Department of Health and Human

Services, the U.S. Department of Agriculture (USDA) and the Department of the Treasury’s Custom

Services are all involved in aspects of food control. Through the Food and Drug Administration (FDA),

and especially via the Center for Food Safety and Applied Nutrition (CFSAN), the Department of Health

and Human Services performs food safety activities. Consequently, CFSAN is the competent authority to

enforce legislation that protects against unhealthy and impure food as well as fraudulently branded food

(FDA/USDA, 2000). The USDA includes the Food Safety and Inspection Services (FSIS) and the Animal

and Plant Health Inspection Services (APHIS) and the Environmental Protection Agency (EPA)

(FDA/USDA, 2000), the first two of which are responsible for ensuring safety and proper labelling of

meat, poultry and egg products, while the EPA is responsible for protecting the public from pesticide-

related hazards and for advising on adequate pest management systems (FDA/USDA, 2000). Additionally,

the Treasury Customs Service Department offers compliance assistance by supporting the various

departments involved in the monitoring and detention of food imports (FDA/USDA, 2000). Unlike the

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above, some food control systems have their functions integrated under a single authority, not necessarily

within a single department of government, but may include a parastatal body that responds to one

department of government (FAO/WHO, 2003b). Therefore, a single food control system, food law

drafting, inspection, analytical and IECT functions are combined under one body with the same aim and

mandate in this type of system. Examples include the Spanish Food Control Agency, a recently developed

agency led by the Ministry of Health and Consumer Affairs of Spain (Garcia and Jukes, 2004). This body

consolidates past food control operations of a multiple agency food control system consisting of the

Ministries of Health and Consumer Affairs, the Ministry of Agriculture, Fisheries and Food and the

Ministry of Economic Affairs and Housing, as well as individual control systems of “autonomous

communities” (Garcia and Jukes, 2004). Greece has also created the Hellenic Food Safety Authority,

which consolidates the functions of five national ministries, namely the Ministry of Agricultural

Development and Nutrition, the Ministry of Health and Social Welfare, the Ministry of Economy and

Finance, the Ministry of Development and the Ministry of Public Order (Varzkas et al., 2006) and now

reports to the Ministry of Development.

The third type of food control system, an integrated agency food control system, is distinguished by the

coordination of different system activities by different agencies or departments, such as the independent

coordination of food law drafting, inspection, analytical and IECT. The monitoring of the system could

also be coordinated by a separate section (FAO/WHO, 2003b). The Korean Food and Drug Administration

(KFDA), headquartered in Seoul with regional offices in numerous other cities, is an example of an

integrated agency (Kwak et al., 1999). This agency is the head of food safety issues and is responsible for

enforcing food laws and performing risk analysis in food (Kwak et al., 1999). Some agencies involved in

monitoring and field operations and/or toxicological assessment and analysis are the Food Safety Bureau,

the Office of Health Assessment and the National Institute of Toxicological Analysis (Kwak et al., 1999).

It should also be noted that the Codex Alimentarius Commission (CAC), a joint body commissioned by

both the FAO and the United Nations (UN) WHO is the most notable of international food standard-setting

bodies on an international level, although not a food control system. Developed to provide food safety

standards and recommendations, it also plays an enhanced role in foods moving in international trade

through the World Trade Organization (WTO) Sanitary and Phyto-Sanitary (SPS) Agreement, which has

designated Codex Standards as the international benchmark for food in trade (FAO/WHO, 2005;

FAO/WHO, 2003b). While Codex standards do not infer changes in national legislation, many countries,

especially developing countries, are using Codex standards and guidelines to establish their own national

legislation. Therefore, although this body is not a food control system, it has various features of an

international food control system. Most food safety regulations need to be enforced at national level, for

example in Nigeria, the Federal Ministry of Health formulates and monitors policies and regulations on

food hygiene and safety, the Standards Organization of Nigeria (SON) formulates and enforces standards

for the composition of imported and locally produced foods and the National Agency for Food and Drug

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Administration and Control (NAFDAC) is responsible for the control of imported and locally processed

food at national and state levels (FAO, 2005). Food laws in Nigeria exist, but many are poorly enforced:

• Public Health laws (1917), now known as Public Health Ordinance cap 165 of 1958.

• The Standards Organization of Nigeria Decree No. 56 of 1971.

• The Food and Drug Act No. 35 of 1974 (now Food and Drug Act Cap F32 Laws of the Federal

Republic of Nigeria, 2004).

• The Animal Disease Control Decree No. 10 of 1988.

• The Marketing of Breast Milk Substitute Decree No. 41 of 1990 now Marketing (Breast Milk) Act

Cap M5 LFN 2004.

• The National Agency for Food and Drug Administration and Control Decree No. 15 of 1993 (now

NAFDAC Act Cap N1 Laws of the Federal Republic of Nigeria, 2004).

Among the various institutions concerned with food safety problems, there is a lack of coordination and

conflicting or overlapping roles at administrative level. It is important to identify roles in order to avoid

discrepancies and to facilitate the smooth running of control activities. There is a very clear need for better

coordination of the institutions that have overlapping authority. At national and local levels, the

responsibility for administrative, food safety regulation and import certification is shared between

different ministries. This condition causes other issues, such as duplication of regulatory operations,

increased bureaucracy and fragmentation of operations, as well as lack of coordination between the various

bodies, leading to trade disputes in import cases (Nguz, 2007). Food safety systems are generally weak,

fragmented and poorly coordinated in most African countries, and are therefore unsuccessful in protecting

consumer health adequately (FAO, 2005; FAO/WHO, 2005b, Majdi, 2002; Nguz, 2007). Problems arise

as a result of poor handling, processing and storage of food after harvest and also as a result of insufficient

facilities and services such as the absence or lack of safe water supply, power, storage facilities like cold

stores, transport facilities and networks, etc. (FAO, 2003).

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4. FOOD SAFETY LEGISLATION IN NIGERIA

The key determinants of food safety and safety of those producing and processing food are “the

procedures, standards and regulations (or lack of) for food production, manufacturing and packaging”

(Ericksen, 2008). Therefore, controlling food safety is an important component of urban food system

governance. Like many other developed countries, Nigeria is facing the challenges of supplying its affluent

population with adequate food supplies. To this end, there is successful promotion of policies and

programs aimed at boosting agricultural and food production. The food safety problem, however, presents

a more daunting challenge. Like several other nations, Nigeria has to deal with the issue of foodborne

diseases with the related social, economic and health costs. The lack of or insufficient use of Good

Agricultural Practices (GAP) and the exploitation or misuse by farmers of agrochemicals and during

storage in developing countries had serious health effects on the population. Certain unsafe practices

include the use of pesticides for farming, improper application of pesticides to stored goods such as beans

and grains to avoid infestation by insects, inappropriate use of chemicals to ripen fruits such as bananas

or vegetables such as carrots and cabbages for insect infestation control (Omojokun, 2013). Similarly,

improper use of food additives such as artificial sweeteners, butylated hydroxyl anisole (BHA), nitrates,

nitrites, food colours, etc. may contribute to various conditions ranging from gastrointestinal disorders to

cancer and death. Many packaging materials are still used in rural Africa with toxic degradable products

that are no longer in use in developed countries. Another issue of concern during food processing is the

partial or complete loss or elimination of nutrients. Another cause of health concern is the inadequate

digestibility or use of nutrients and the development of new potentially harmful chemicals resulting from

poor processing and handling practices (Omojokun, 2013). Therefore, to ensure food safety and quality

for domestic consumption and export, necessary and proactive steps must be taken. This is because food

was recognized internationally not only as a biological necessity, but also as an economic and political

necessity. In cultures and countries, it is always a potential source of socio-political problems.

Consequently, an effective national food safety policy would ensure that the food supplied to consumers

is sufficient, nutritious, of good quality and balanced (Omotayo and Denloye, 2002). The Federal

Government of Nigeria initiated the National Policy on Food Hygiene and Safety in 2000 as an integral

part of the Nigerian National Health Policy in recognition of the value of food safety as an important factor

in achieving a high level of health for all Nigerians. The overall objective of this policy is to achieve high-

level food hygiene and safety practices that promote health, control food borne diseases, reduce and

eliminate the risk of illnesses associated with poor food hygiene and safety. The policy aims at stimulating

and encouraging food laws in the areas of production, storage, handling, manufacturing, preservation,

transportation, transport and marketing. It also seeks to improve the quality of healthcare by ensuring that

all food consumed in Nigeria, whether imported or exported, is wholesome, safe, contaminant-free and

affordable to consumers. The implementation of the policy is aimed at addressing the unsatisfactory level

of food hygiene and safety practices that are largely responsible for the prevalence of foodborne diseases

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in Nigeria (Omotayo and Denloye, 2002). The National Food Safety Policy provides for the establishment

of a National Committee on Food Safety that draws its membership from the public and private sectors

related to the production, storage, processing/preparation, distribution, transportation and sale of food

intended for consumption.

I. The Public Sector includes:

a. Federal Government Ministries

b. Federal Government Food Control Agencies

c. State Government Ministries of Health

d. State Government Ministries of Agriculture

e. Local Government Departments of Health

f. Local Government Departments of Agriculture

II. The Private Sector includes:

a. Industries

b. Non-Governmental Organizations (NGOs)

c. International Development Partners

d. Universities and Research Institutes

e. Professional Bodies/Associations

f. Consumer Associations

4.1. REGULATORY AND LEGISLATIVE FRAMEWORK

Over the years, numerous laws and regulations have been implemented to ensure the safety and

wholesomeness of the food supply in Nigeria. Such legislations include the following:

a. The Public Health Laws (1917) now known as Public Health Ordinance Cap 165 of 1958.

b. The Standards Organization of Nigeria Decree No. 56 of 1971.

c. The Food and Drug Act No. 35 of 1974 (now Food and Drug Act Cap F.32 LFN 2004).

d. The Animal Disease Control Decree No. 10 of 1988.

e. The Marketing of Breast Milk Substitute Decree No. 41 of 1990 (now Marketing of Breast Milk

Substitute Act Cap M.5 LFN 2004).

f. The National Agency of Food and Drug Administration and Control Decree No. 15 of 1993 (now

NAFDAC Act Cap N.1 LFN 2004).

g. The Food, Drug and Related Products (Registration) Decree No. 19 of 1993 (now Food, Drug and

Related Products (Registration) Act Cap F.33 LFN 2004).

h. The Counterfeit and Fake Drugs and Unwholesome Processed Foods Act No. 25 of 1999 (now

Counterfeit and Fake Drugs and Unwholesome Processed Foods (Miscellaneous Provisions) Act

Cap C.34 LFN 2004).

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i. Various bye-laws enacted by various LGAs in Nigeria.

4.2. KEY ACTORS IN REGULATING AND MONITORING OF FOOD SAFETY

STANDARDS AND PRACTICES

The following bodies develop and influence food safety standards in Nigeria:

a. The Federal Ministry of Health (FMH)

b. The National Agency for Food and Drug Administration and Control (NAFDAC)

c. Standards Organization of Nigeria (SON)

d. The Federal Ministry of Agriculture and Rural Development (FMARD)

e. Nigerian Agricultural Quarantine Service (NAQS)

f. Federal Competition and Consumer Protection Commission (FCCPC)

g. The Federal Ministry of Environment

h. Local Government

4.2.1. The Federal Ministry of Health (FMH)

The Federal Ministry of Health is one of the Federal Ministries of Nigeria concerned with the formulation

and implementation of policies related to health. It has the responsibility of formulating national policies,

guidelines and regulations on food hygiene and safety as well as the monitoring of their implementation.

It is also responsible for establishing guidelines for the requirements and assessment of the nutritive value

of food and monitoring of environmental sanitation, food environment and handlers, control of food-borne

diseases, quality of public water from taps, as well as national and international matters relating to food.

4.2.2. The National Agency for Food and Drug Administration and Control (NAFDAC)

The National Agency for Food and Drug Administration and Control (NAFDAC) is a federal agency under

the Federal Ministry of Health that is responsible for regulating and controlling the manufacture,

importation, exportation, advertisement, distribution, sale and use of food, drugs, cosmetics, medical

devices, chemicals and packaged water at Federal and State levels in Nigeria. Appropriate tests are

conducted and compliance with standard specifications for the effective control of the quality of food,

bottled water and the raw materials as well as their production processes in factories and other

establishments is ensured. The agency undertakes appropriate investigations into production premises and

raw materials for food, drugs, cosmetics, medical devices, bottled water and chemicals and establishes

relevant quality assurance systems including certification of the production sites and of the regulated

products. The role of the agency also includes the inspection of imported foods, drugs, cosmetics, medical

devices, bottled water and chemicals and establishes relevant quality assurance systems necessary for

certification of the production sites and of the regulated products.

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4.2.3. Standards Organization of Nigeria (SON)

The Standards Organization of Nigeria (SON) is the apex standardization body in Nigeria and is

responsible for the formulation and enforcement of set standards on the composition of imported and

locally manufactured foods. Over 100 standards on food and food products as well as a good number of

codes of hygienic practices for food and food products have been established. These standards and codes

are reviewed periodically to reflect current trends in technological and industrial development.

4.2.4. The Federal Ministry of Agriculture and Rural Development (FMARD)

The Federal Ministry of Agriculture and Rural Development (FMARD) is a ministry of the Nigerian

government that regulates agricultural research, agriculture and natural resources, forestry and veterinary

research throughout Nigeria. It is responsible for developing the agricultural sector of the Nigerian

economy, with a view to growing the sector, driving income growth, accelerate food and nutrition security,

generating employment and transforming Nigeria into a leading global food market, through the

commodity value chain concept of the Agricultural Transformation Agenda (ATA). The Ministry

promotes agri-business, encourages rural development, supports private sector institutions and broadens

stakeholders’ partnership to facilitate raw materials for agro-based industries, diversify agricultural

products along commodity value chains and generate foreign exchange earnings for the country.

The Ministry fulfils its responsibilities through its departments and parastatals, and also supervises and

provides funding for research institutes such as the National Root Crops Research Institute and colleges

of agriculture and forestry.

4.2.5. Nigerian Agricultural Quarantine Service (NAQS)

The Nigerian Agricultural Quarantine Service (NAQS) is a regulatory agency under the Federal Ministry

of Agricultural and Rural Development (FMARD). It was created for the harmonization of plants,

veterinary and aquatic resources (fisheries) quarantine in Nigeria to promote and regulate sanitary (animal

and fisheries health) and phytosanitary (plant health) measures in connection with the import and export

of agricultural products with a view to minimizing the risk to agricultural economy, food safety and the

environment. The main objective of NAQS is to prevent the introduction, establishment and spread of

animal and zoonotic diseases as well as pests of plants and fisheries including their products. NAQS also

undertakes emergency protocol to control or manage new pest incursion or disease outbreak in

collaboration with key stakeholders. It ensures that agricultural exports meet with international standards

in line with International Plant Protection Convention (IPPC) Office, International des Epizootics (OIE)

representing the World Organization for Animal Health, WTO/Sanitary and International Trade of

Endangered Species (SITES) and SPS conditions of importing countries. Its operations are guided by the

enabling legislation enacted by the National Assembly and SPS regulations and schedules.

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4.2.6. Federal Competition and Consumer Protection Commission (FCCPC)

The Federal Competition and Consumer Protection Commission (FCCPC) is the apex of the Consumer

Protection Agency in Nigeria. The overall mandate of the Commission is to protect consumers by taking

both preventive and remedial measures. It is committed to nationwide quality assessment of products and

services, through inputs into national and international standards, sampling, analysis, investigation,

process auditing, developing and issuing of guidelines/standard operating procedures (SOPs) in order to

ensure that products, services and processes are of good quality, safe and meet consumers’ expectation,

while giving value for money. It is also responsible for market surveillance and enforcement where

violations occur, engaging in routine and periodic consumer education to inform consumers of their rights,

available enforcement mechanisms and how to use the processes as well as providing information about

key market developments such as advisories, warnings, recalls and similar interventions, and conducts

numerous specific and general awareness campaigns.

The Commission engages in domestic and global research about products and services, as well as changing

or evolving market trends and consumer behaviour.

4.2.7. The Federal Ministry of Environment

The Federal Ministry of Environment was established to ensure effective coordination of all environmental

matters and to ensure that environmental matters are adequately mainstreamed into all developmental

activities. It has focused on involving innovative strategies that emphasize the use of environmental re-

engineering as a veritable tool for job creation, poverty eradication, ensuring food security, encouraging

sustainable economic development and general improvement in the livelihood of the Nigerian populace.

It also has a role to play in the control of environmental food contaminants, persistent organic pollutants,

environmental pollution, waste disposal, etc.

4.2.8. Local Government

The Local Government is responsible for the control and regulation of out-door advertising, and regulating

and monitoring of street food vending, catering establishments, bukaterias, local abattoirs and the

traditional markets.

4.3. NATIONAL FOOD CONTROL SYSTEMS

Food control includes a number of programs aimed at providing consumer protection and ensuring that all

products supplied for human consumption are nutritious, wholesome, comply with safety and quality

standards and are labelled honestly and accurately as prescribed by law. To achieve this goal, most

countries have some sort of food control system in place. Typically, these programs include various

components that may include food policies and legislation, food safety management, testing and analytical

laboratories, food inspection, compliance and certification, emergency preparedness and response, food-

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borne disease surveillance, and public information, education and information. The efficiency of a national

food control system is linked to its ability to effectively, efficiently and sustainably execute adequate

functions to provide healthy and quality food for domestic consumption and export. Achieving food safety

is a shared responsibility, and various types of stakeholders–including government, food industry,

consumers and their organizations, academic and scientific institutions, etc. – are contributing to this

capacity. Particularly:

• Government agencies (at central and lower levels) are responsible for establishing and managing

an enabling institutional, policy and regulatory framework for food safety, and carrying out food

control activities that protect consumers from risks arising from unsafe food and fraudulent

practices.

• Food producers, processors, handlers, manufacturers, traders, retailers and caterers (hereafter

referred to as the food industry) have the primary responsibility for delivering safe food to

consumers. This includes responsibility for developing and managing systems that ensure that the

food supplied and/or served is safe and complies with official food safety requirements.

• Consumers and their organizations are responsible for ensuring that food is handled, stored and

prepared in accordance with good hygienic practices (GHPs) and for requesting appropriate

standards of food safety.

While these stakeholders each have distinct responsibilities and accountabilities, their functions are highly

intertwined and interdependent due to the multidimensional complexity of food safety and quality.

Therefore, active cooperation between the stakeholders involved in the food chain from farm to table is

essential to ensure that the outcomes obtained are successful and sustainable (FAO, 2007).

The principal objectives of national food control systems are:

• Protecting public health by reducing the risk of foodborne illness.

• Protecting consumers from unsanitary, unwholesome, mislabelled or adulterated food.

• Contributing to economic development by maintaining consumer confidence in the food system

and providing a sound regulatory foundation for domestic and international trade in food.

Food control systems should cover all food, including imported food, produced, processed and marketed

within the country. These systems should have a legal basis and should be mandatory in nature. While a

food control system's components and objectives will vary from country to country, most systems will

usually include the following components:

a. Food laws and Regulations

An essential component of a modern food control system is establishing applicable and enforceable food

laws and regulations. Most countries have weak food laws, which will impact the efficacy of all food

safety programs in different countries. Traditionally, food law has consisted of legal definitions of unsafe

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food and the provision of compliance methods to exclude unsafe food from trade and prosecute responsible

parties after the fact. It has usually not provided a clear policy and authority for food protection authorities

to avoid food safety issues. The result was food safety systems that are reactive and enforcement-oriented

in their approach to reducing the risk of foodborne disease, rather than comprehensive and holistic. Modern

food laws, to the extent possible, not only provide the necessary legal powers and regulations to ensure

food safety, but also require the competent food authorities to integrate preventive approaches into the

framework. Governments need to amend food standards in addition to regulations. In recent years,

horizontal standards have replaced other overly prescriptive requirements that tackle the specific issues

involved in achieving food safety goals. Although horizontal standards are a viable approach to achieving

food safety goals, they involve a highly controlled food chain with good data on food safety threats and

risk management approaches, and as such may not be feasible for many developing countries. Likewise,

several food quality guidelines have been scrapped and replaced by criteria for labelling. Countries should

take full advantage of the Codex guidelines and lessons learned in other countries in the preparation of

food laws and standards. Understanding the experiences in other countries while tailoring knowledge,

principles and requirements to the national context is the only sure way to develop a modern regulatory

framework that will satisfy both national needs and the requirements of the Sanitary and Phytosanitary

(SPS) Agreement and trading partners. Food legislation should cover the following aspects:

• It must provide a high level of health protection.

• It should include clear definitions to increase consistency and legal security.

• It should be based on high quality, transparent and independent scientific advice following risk

assessment, risk management and risk communication.

• It should include provision for the use of precaution and the adoption of provisional measures

where an acceptable level of risk to health has been identified and full risk assessment could not

be performed.

• It should include provisions for the right of consumers to have access to accurate and sufficient

information.

• It should include provision for the use of precaution and the adoption of provisional measures

where an unacceptable level of risk to health has been identified and where full risk assessment

could not be performed.

• It should include provisions for the right to consumers to have access to accurate and sufficient

information.

• It should provide for tracing of food products and for their recall in case of problems.

• It should include clear provisions indicating that primary responsibility for food safety and quality

rests with producers and processors.

• It should include obligation to ensure that only safe and fairly presented food is placed on the

market.

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• It should also recognise the country’s international obligations particularly in relation to trade.

• It should ensure transparency in the development of food law and access to information.

a. Food Control Management

Effective systems of food control require national policy and organizational coordination. While the

specifics of these roles will be decided by national legislation, they would include the creation of a

leadership role and administrative frameworks with specific accountability for issues such as the

development and implementation of an integrated national food control strategy, the execution of a

national food control programme, the procurement of funds and resource allocation. Main tasks include

developing regulatory measures, tracking the performance of the program, promoting continuous

improvement and providing overall policy guidance.

b. Inspection Services

A professional, educated, effective and honest food inspection service is required for the administration

and implementation of food laws. The food inspector is the main functionary who has daily contact with

the food industry, business, and often with the public. The food control system’s credibility and legitimacy

depend to a very large extent on its honesty and capacity. The inspection services’ roles include:

• Inspecting premises and processes for compliance with hygienic and other requirements of

standards and regulations.

• Evaluating HACCP plans and their implementation.

• Sampling food during harvest, processing, storage, transport, or sale to establish compliance, to

contribute data for risk assessments and to identify offenders.

• Recognizing different forms of food decomposition by organoleptic assessment, identifying food

which is unfit for consumption or food which is otherwise deceptively sold to the consumer and

taking the necessary remedial action.

• Recognizing, collecting and transmitting evidence when breaches of law occur, and appearing in

court to assist prosecution.

• Encouraging voluntary compliance in particular by means of quality assurance procedures.

• Carrying out inspection, sampling and certification of food for import/export inspection purposes

when so required.

• In establishments working under safety assurance programmes such as HACCP, conduct risk-

based audits.

For an efficient food control system, proper training of food inspectors is a prerequisite. Given the

complexity of current food systems, the food inspector must be qualified in food science and technology

to understand industrial processes, identify potential safety and quality problems, and have the skills and

experience to inspect the premises, collect food samples, and perform an overall assessment. The inspector

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must have a good understanding of the applicable food laws and regulations, their competencies under

those laws, and the duties placed on the food industry by such laws. They should also be familiar with

procedures to gather evidence, write inspection reports, collect samples and send them for review to a

laboratory. The inspector should be trained to handle HACCP audit duties with the gradual introduction

of HACCP systems in the food industry. Obviously, there is a growing need to train and upgrade existing

inspection staff's skills and have a human resource growth strategy, in particular the recruitment of

inspection specialists in specific technical areas. Considering that human resources may be scarce in some

food safety agencies in developing countries, environmental health inspectors are also often asked to work

as food inspectors. This is not the ideal situation because they may lack the skills and experience to assess

and inspect food operations effectively. If it is appropriate to use environmental health inspectors, they

should be specifically supervised and provided on-the-job training.

c. Laboratory Services: Food Monitoring and Epidemiological Data

Laboratories are a key component of a food control system. Laboratory establishment requires significant

capital investment and is expensive to maintain and run. Careful planning is therefore necessary in order

to achieve optimum results. The number and location of the laboratories should be determined in relation

to the system's priorities and work duration. If more than one laboratory is needed, consideration should

be given to allocating the analytical work to achieve the most effective coverage of the food analyses to

be performed and also to having a central research laboratory equipped for sophisticated and reference

analyses. All laboratories for food analysis may not be under the authority of one department or

government, and a number may be under the jurisdiction of states, regions, and local authorities.

Nevertheless, the Food Control Management will set the food control laboratory standards and track their

performance. The laboratories should have ample equipment for physical, microbiological and chemical

research. In addition to simple routine research, laboratories can be fitted as needed with more

sophisticated instruments, equipment and library facilities. It is not just the type of equipment that decides

the accuracy and reliability of the analytical tests, but also the analyst's knowledge and skill and the

method's reliability. A food safety laboratory’s test finding is often used as evidence in a court of law to

determine the country's compliance with legislation or standards. Therefore, it is necessary to take the

utmost care to ensure the laboratory's efficient and effective results.

The implementation of scientific quality assurance systems and laboratory accreditation by an acceptable

accreditation body inside or outside the country allows the laboratory to enhance its performance and

ensure the tests are reliable, accurate and repeatable. Thus, promoting this initiative is the provision of

official sampling and analysis methods. An important element of a national food control system is its

incorporation into a national food safety system so that it is possible to establish and evaluate connections

between food contamination and foodborne diseases. It is important to have access to reliable and current

information on the incidence of foodborne disease. The laboratory facilities are generally located outside

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the food control agencies for this type of activity. Strong ties between food control agencies and the public

health system, including epidemiologists and microbiologists, are important, however. In this way,

foodborne disease information can be related to data on food safety and contribute to appropriate food

control policies based on risk. Such information includes annual patterns in occurrence, identifying

vulnerable population groups, identifying dangerous foods, identifying and monitoring the causes of

foodborne diseases, and providing early warning signs for outbreaks and contamination of foods.

d. Information, Education, Communication and Training

The provision of information, education and advice to stakeholders across the farm-to-table spectrum is

an increasingly important task for food control systems. Such initiatives include delivering accurate factual

information to customers, providing knowledge packages and educational programs for key officials and

staff in the food industry, designing train-the-trainer programs and providing reference literature to

agricultural and health sector extension employees. The special training needs of their food inspectors and

laboratory analysts should be discussed as a high priority by food safety agencies. Such activities provide

an effective means to build knowledge and skills in food safety in all stakeholders and thus serve an

essential preventive role (FAO, 2003).

4.4. NATIONAL AGENCY FOR FOOD AND DRUG ADMINISTRATION AND CONTROL

(NAFDAC)

The National Agency for Food and Drug Administration and Control (NAFDAC) was established by

Decree No. 15 of 1993 as amended by Decree No. 19 of 1999 and now the National Agency for Food and

Drug Administration and Control Act Cap N1 Laws of the Federal Republic of Nigeria (LFN) 2004 to

regulate and control the manufacture, importation, exportation, distribution, advertisement, sale and use

of food, drugs, cosmetics, medical devices, packaged water, chemicals and detergents (collectively known

as regulated products). The agency was officially established in October 1992 and is the lead agency for

food quality and safety. The NAFDAC’s organization consists of the Director General’s Office and

fourteen (14) directorates overseeing the functions of the agency and they include:

• Registration and Regulatory Affairs (R & R)

• Food Safety and Applied Nutrition (FSAN)

• Drug Evaluation and Research (DER) Directorate

• Chemical Evaluation and Research (CER) Directorate

• Veterinary Medicine and Allied Products (VMAP)

• Ports Inspection Directorate (PID)

• Laboratory Services Directorate

• Narcotics and Controlled Substances (NCS) Directorate

• Admin and Human Resource Management Directorate

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• Pharmacovigilance and Post Market Surveillance (PV/PMS)

• Investigation and Enforcement Directorate

• Planning Research and Statistics Directorate

• Finance and Accounts Directorate

• Legal Services Directorate

4.4.1. FUNCTIONS OF NAFDAC

The functions of NAFDAC as provided in the enabling law that establishes it are to:

• Regulate and control the importation, exportation, manufacture, advertisement, distribution, sale

and use of food, drugs, cosmetics, medical devices, bottled water, chemicals and detergents

(regulated products).

• Conduct appropriate tests and ensure compliance with standard specifications designated and

approved by the Council for effective control of quality of regulated products and their raw

materials as well as their production processes in factories and other establishments.

• Undertake appropriate investigation into the production premises and raw materials for regulated

products and establish relevant quality assurance systems, including certification of the production

sites of the regulated products.

• Undertake inspection of imported regulated products and establish relevant quality assurance

systems, including certification of production sites.

• Compile standard specifications, regulations and guidelines for the production, importation, sales,

distribution and registration of regulated products.

• Undertake the registration of foods, drugs, cosmetics, medical devices, bottled water, chemicals

and detergents.

• Control the exportation and issue quality certification of products intended for export.

• Establish and maintain relevant laboratories or other institutions in strategic areas of Nigeria as

may be necessary for the performance of its functions.

• Pronounce on the quality and safety of products after appropriate analysis.

• Take measures to ensure that the use of narcotic drugs and psychotropic substances are limited to

only medical and scientific purposes.

• Grant authorization for the import and export of narcotic drugs and psychotropic substances as

well as other controlled substances.

• Collaborate with the National Drug Law Enforcement Agency (NDLEA) in the bid to eradicate

drug abuse in Nigeria.

• Advice governments, the private sector and other interested bodies regarding the quality, safety

and regulatory provisions on regulated products.

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• Issue guidelines, grant approvals and monitor the advertisement of food, drugs, cosmetics, medical

services, bottled water, chemicals and detergents.

• Compile and publish relevant data resulting from the performance of the functions of the agency

or from other sources.

• Sponsor such national and international conferences as may be considered appropriate.

• Liaise with relevant establishments within and outside Nigeria in pursuance of its functions.

• Carry out such activities as are necessary or expedient for the performance of its functions.

4.4.2. REGULATORY STRATEGIES OF NAFDAC

a. Product Registration

The product registration process is one of the regulatory strategies of NAFDAC. The agency uses product

registration to establish and monitor the ownership and/or distributorship of the products it regulates,

generally known as regulated products (i.e. food, drugs, cosmetics, medical devices, chemicals, bottled

water and detergents), their safety, quality, labelling, claims, etc. NAFDAC employs a structured and

systematic procedure for product registration at the end of which the product is assigned a NAFDAC

Registration Number which is an attestation to the safety, quality and appropriateness of its intended use.

The registration process involves the following:

• Documentation: Documents are required such as Power of Attorney from the manufacturer

authorising an applicant to speak for his principal on all matters relating to the latter’s specialties,

Certificate of Manufacture and Free Sale which is an evidence that the product is manufactured

and freely sold in the country of origin, Certificate of Incorporation of the representative company

in Nigeria, Evidence of Trade Mark registration, Comprehensive Certificate of Analysis of the

batch of product to be registered. The permit to import samples for registration purposes is issued

if documentation is satisfactory.

• Labelling: Labels must be informative, clear and accurate, indicate the name of product, name and

address of the manufacturer, packer, distributor, importer, exporter or vendor, make provision for

NAFDAC registration number, batch number, manufacturing date and expiry or best before date,

net content, ingredients list in metric weight in case of solids, semi solids and aerosols and metric

volume in case of liquids.

• Inspection: Good Manufacturing Practice (GMP) inspection of production facility is carried out

prior to registration of the product.

• Product Approval Committee Meetings: A three (3) tier product approval meeting is held to

consider the documentation, laboratory reports, GMP inspection reports, product labels, etc. of a

product prior to its registration.

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Once a product is satisfactory, it is assigned NAFDAC registration numbers and can be freely sold or

marketed within the country.

b. Consultative Meetings

NAFDAC encourages sectoral groups, small and medium scale entrepreneurs, etc. to form umbrella

associations (e.g. Association of Food, Beverage and Tobacco Employers (AFBE), National Association

of Small-Scale Industrialists (NASSI), Association of Table Water Producers (ATWAP), Association of

Fast Foods and Confectionaries Operators of Nigeria (AFFCON), All Farmers Association, etc). These

associations are encouraged to self-regulate their practices and can easily arrange for consultative meetings

with the agency where their views and concerns are addressed and taken into account when making

regulatory decisions that concern them. Such an arrangement also enables NAFDAC to organize targeted

and focused capacity building training programmes for the various groups. Consultative meetings could

also be at the instance of the agency to give information and enlighten the public on NAFDAC

requirements, discuss perceived regulatory challenges, inform on international best practices and

regulatory trends.

c. Public Enlightenment Campaigns

The agency organizes public enlightenment campaigns on topical and emerging issues using the electronic

media, print media and physical presence at campaigns held at grassroot levels where the rural dwellers

are invited with the cooperation and involvement of their local chiefs to inform and educate the populace.

Programmes such as ‘NAFDAC and Your Health’ are popular television and radio programmes where

regulatory officers are invited to speak on issues such as food safety, Codex activities, food supplements,

how to check food products for important information on the labels such as date markings, NAFDAC

registration number, etc. Some of the programmes are phone-in programmes where the public has the

opportunity to ask questions and be enlightened. The agency also uses television advertisements and radio

jingles to inform and educate the public.

d. Trainings and Publications

NAFDAC organizes international, national and in-house capacity building training programmes

consistently for staff, the industry and the general public. There are also collaborations and exchange

programmes with credible regulatory authorities and international bodies such as the United States Food

and Drug Administration (USFDA), US Department of Agriculture (USDA), International Atomic Energy

Agency (IAEA), World Health Organization (WHO), Directorate General for Health and Consumers (DG

SANCO) of the European Commission, African Union/Inter-African Bureau for Animal Resources

(AU/IBAR) etc. (Omojokun, 2013).

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e. NAFDAC Consumer Safety Club (NCSC)

The NAFDAC Consumer Safety Club (NCSC) is a public enlightenment and sensitization platform of the

Agency used in the fight against fake/substandard regulated products, and to promote the ‘quality culture’

in Nigerian youth. The objectives of NCSC are to:

• Reorient the youth and redirect their energy away from social vices and anti-social behaviour

towards healthy habits and meaningful development.

• Serve as a platform for the promotion of NAFDAC’s fight against fake drugs and other substandard

products.

• Use members as foot soldiers for the reinvigoration of NAFDAC’s anti-drug abuse and misuse

campaign.

• Assist with information flow on NAFDAC’s regulatory activities.

To achieve the afore-mentioned objectives, annual NCSC competitions are organized for member schools

at the State, Zonal and National levels in both junior secondary and senior secondary categories, and

winners are awarded prizes. State level examinations are conducted to identify both state level and zonal

level winners. First place winners from the zonal examinations in both categories are invited to the

headquarters in Abuja to participate in a grand finale which is in the form of a quiz competition. The grand

winners are recognized and honoured at a National Award Ceremony (NAFDAC, 2019).

f. Recalls and Alerts Procedure

Public Alerts and Dear Healthcare Provider Letters: The PV/PMS Directorate receives and sources

alert notifications on recalls and safety information on regulated products. The information from a

notification may be disseminated to the Nigerian public in an Alert Notice and /or Dear Healthcare

Provider Letter (DHPL). On review of the safety information received, timely alert notices and safety

communication (Dear Healthcare Provider Letter) are provided to the general public and healthcare

providers respectively. The alert notices and safety communication contain safety measures to be taken

and information that may impact both treatment and diagnostic choices for healthcare providers and

patients. Regular visit to the NAFDAC website guarantees access to current alert notices and new

safety information on regulated products.

Rapid Alert System for food and Feeds (RASFF): RASFF is a rapid alert system for food and feeds.

It is a key tool to ensure the cross-border flow of information to swiftly react when risks to public

health are detected in the food chain. Border rejections are received from European Commission

Authentication Service and notifications are disseminated to the relevant Ministries, Department and

Agencies, Nigeria Custom Service, Nigerian Agricultural Quarantine Service (NAQS), Nigeria Export

Promotion Council (NEPC), Ministry of Trade and Investment, The Central Bank of Nigeria, and other

stakeholders in the food safety supply chain. Nigerian food commodities are being rejected in the

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European boarders due to pesticides residues contaminant, spoilage, poor handling, packaging and

illegal importation etc. Investors and exporters are encouraged to visit the One Shop Investment Centre

(OSIC) domiciled at Nigerian Investment Promotion Commission. OSIC is an initiative of the

government to enhance the ease of doing business and facilitate investment and export by bringing the

relevant government Agencies and regulators (CAC, CBN, NIPC, FIRS, NIS,NAQS and NAFDAC)

to one location where all statutory approvals and document required to set up investment in the Nigeria

economy can be processed and obtained. Adequate information is provided by the NAFDAC desk and

other competent authorities on permitted level of pesticide residues in food commodities, approved

food additives and preservatives proper packaging materials suitable for various food grade, storage

conditions, Good manufacturing, Distribution and handling practices and so on. This is to ensure that

food export meet the required regulatory standards (NAFDAC, 2019).

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5. RESULTS

The following chapter presents the results from the interviews carried out with key food regulatory officers

in NAFDAC and also the results from surveys carried out on the wider community in Nigeria.

5.1. Interviews with Regulatory Officers of NAFDAC

Results from the interviews conducted with key regulatory officers at NAFDAC revealed that almost all

food commodities are commonly adulterated in Nigeria, with food commodities such as honey, vegetable

oil, palm oil, alcoholic and non-alcoholic beverages, flour and sugar being the most commonly adulterated

food commodities. Reasons for poor implementation of food laws in Nigeria include inadequate funding

and other logistics, gaps as a result of overlapping of functions of the government agencies that regulate

food activities, ununified regulation and enforcement, unrealistic policies and lack of compromise by law

enforcement agencies. Regarding publications, published articles or a food database where food fraud

cases have been documented in Nigeria, the food agency publishes cases of food fraud on its website (i.e.

through the recall and alert system) and through annual reports and NAFDAC Consumer Safety

publications. It has a functional food database which has registered food products only. One of the

regulatory officer stated that food products from supermarkets are registered with a global listing and the

agency ensures that any food product that is imported is registered on the global listing. Regarding reasons

food commodities are still adulterated in Nigeria, the following factors include poverty and economic gain,

ignorance and lack of awareness, porous borders, over regulation and non-seriousness in accepting laid

down laws and lack of stiff penalties for offenders. Like one of the regulatory officer quoted “Because

people are terrible people; We arrest them, keep them in the cell till Monday, release them on Monday

after they have paid the fine and after two weeks, we discover they are still doing the same thing; just

wickedness and poverty and because people are only interested in making money”. The processes for

recalling adulterated food commodities as explained by the officers are through the following ways:

• Notification of the product and product batch is received from government, individual

establishments or stakeholders.

• Authentication of source of consumers’ complaint will be done.

• Investigation and surveillance will take place to authenticate the problem.

• The manufacturer or importer will be notified.

• A public alert notice will be issued.

• A surveillance team will be constituted.

• Product mop-up accompanied by forfeiture form.

• Laboratory analysis.

• Destruction exercise will then take place.

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The regulatory processes in NAFDAC are carried out by employed regulators and they include the

following:

For imported products:

• Collection and vetting of documents.

• Payment of relevant fees.

• Issuance of import permit for samples submission for laboratory analysis.

• Inspecting the facility abroad and collection of on the spot relevant documents.

For products meant for export and local use: Inspection of facility where products for export will be

manufactured and domiciled. Types of inspection includes:

• Initial (Advisory)

• Production

• Routine

• Investigation

• Surveillance

• Mop-Up

• Renewal

• Good Manufacturing Practice (GMP) Reassessment

• Advocacy

• Enlightenment

When asked about the development of the regulations, they stated that the standard regulations committee

under the Registration and Regulatory Directorate is responsible for developing the regulations. The roles

of the risk assessors (i.e. the stakeholders) and the risk managers (i.e. the manufacturers) in food safety

management as stated by the regulatory officers are (1) To evaluate the risks associated with the products

they produce (2) To produce and provide food in the safest manner (3) To analyse the risk using HACCP.

Regarding measures NAFDAC has taken in tackling cases of food fraud in Nigeria, the answers given

varied from each of the officers but not limited to the following:

• Routine monitoring of all food establishments.

• Public enlightenment campaign.

• Effective collaboration with related bodies and agencies.

• For frequently committed food fraud, application of stiffer penalties for offenders.

• Sustenance of effective regulation.

• Capacity building and post market surveillance of all retail shops, markets and supermarkets.

• Deregistration of offenders if registered with NAFDAC and stiff sanctioning if not registered.

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• Institution of functional food database for all registered food commodities.

• Imported food products are certified before entering into the market. They undergo proper

documentaion (certificate of analysis of the product from the country of manufacture) and the

product is analysed in the laboratory.

The relevance of NAFDAC and other agencies in tackling food fraud as well as promoting food safety in

Nigeria and its relevance with the UN Sustainable Development Goals (SDGs) will be covered in

subsequent chapters.

5.2. Consumer Survey Questionnaire

The participants’ profiles with regards to gender and age are provided in Table 2. The majority of the

participants are aged between 25 and 54 years. According to the results, 38 (55.88%) are male while the

remaining 30 (44.12%) are female.

Table 2: Participants’ profile (n = 68)

Age Frequency %

Under 18 0 0

18-24 5 7.35

25-34 34 50.00

35-44 11 16.18

45-54 10 14.71

55-64 8 11.76

65-74 0 0

Above 75 0 0

Total 68 100

Gender Frequency %

Male 38 55.88

Female 30 44.12

Total 68 100

Of the food commodities that are commonly adulterated in Nigeria, results showed that fats and oil (n =

36) were the most commonly adulterated, followed by alcoholic and non-alcoholic drinks (n = 17) and

honey (n = 4) respectively as shown in Table 3.

Food category Frequency %

Herbs and Spices 1 1.47

Fats and oils 37 54.41

Dairy products 2 2.94

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Cereals 1 1.47

Alcoholic and non-alcoholic

drinks

17 25.00

Baked goods and

confectionery

2 2.94

Meat and meat products 2 2.94

Fish and fish products 0 0

Honey 4 5.88

Fruits and vegetables 2 2.94

A bar graph showing the overall percentage ratio of food commodities commonly adulterated in Nigeria

is shown in Figure 5.1.

Figure 5.1: Bar graph showing the overall ratio of commonly adulterated food commodities in percentage.

91.18% (n = 62) of participants agree that food laws in Nigeria are poorly implemented while 8.82% (n =

6) do not agree as shown in Figure 5.2.

Figure 5.2: Bar graph showing the percentage of participants that agree/disagree on poor implementation

of food laws in Nigeria.

However, 70.59% (n = 48) of participants agree that NAFADAC are making efforts in tackling food fraud

while 29.41% (n = 20) disagree as shown in Figure 5.3.

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Figure 5.3: Pie chart showing the percentage of participants that agree/disagree on the efforts of NAFDAC

in tackling food fraud.

Regarding the UN Sustainable Development Goals (SDGs), 64.18% (n = 43) of the participants are fully

aware of the 2030 Global Goals while the remaining 35.82% (n = 24) are neither aware or have never

heard of the 2030 Global Goals as shown in Figure 5.4.

Figure 5.4: Bar graph showing the percentage of participants that are aware/unaware of the UN

Sustainable Goals (SDGs).

Majority of participants with 77.27% (n = 52) agree that food smuggling is a problem in Nigeria while the

remaining 22.73% (n = 15) do not agree as shown in Figure 5.5.

Figure 5.5: Bar graph showing percentage of participants that agree/diagree on the problem of food

smuggling in Nigeria.

43.94% (n = 29) of participants agree that consumers are partly responsible for food adulteration in Nigeria

while the remaining 56.06% (n = 37) disagree as shown in figure 5.6.

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Figure 5.6: Bar graph showing the percentage of participants that agree/disagree that consumers are partly

responsible for food adulteration in Nigeria.

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6. DISCUSSION, RECOMMENDATION AND LIMITATION

Food safety is an essential element of food security. Some types of food fraud decrease food safety and

therefore directly threaten food security. Based on their potential health hazard, Everstine et al., (2018)

developed a scheme to classify adulterants related to food fraud. The three categories were: (1) potentially

hazardous adulterants (2) non-hazardous adulterants and (3) non-hazardous adulterants. When this

categorization was applied to over 1000 food fraud incidents reported to the U.S pharmacopeial

Convention (USP), nearly half were category one, suggesting many incidents of food fraud pose a risk to

human health. The economic costs of both direct and indirect food fraud can be significant. These

economic effects can also threaten food and nutrition security, particularly in low-and middle-income

countries (LMICs). Detected food fraud in high-income countries (HICs) leads to recalls, resulting in food

waste. Companies typically suffer a decline in sales as well as the associated costs. More indirectly, bribery

leads to unfair competition with legitimate food businesses around the world, distorting markets and

increasing food costs, reducing accessibility to households with income constraints. Since fraud

undermines trust in the food system, if customers avoid suspect foods, it can also reduce food and nutrition

security. The results from this study probes into the views of the public and regulators on food fraud in

the Nigerian context.

Following a series of interviews with key regulators and a survey of public consumers in Nigeria, the

results from the research revealed that majority of participants attributed corruption, lack of enforcement,

poor implementation, bribery, lack of awareness, poor sensitisation and education as well as poor

preservation methods and hygiene as reasons for poor implementation of food laws in Nigeria. They stated

also that profit making is one of the major reason for people adulterating food commodities; other reasons

included hunger, poverty and greed. Most participants believe that creating awareness and educating the

consumers especially in the rural areas on the dangers of food fraud and detecting fake products is one

way of promoting food safety in Nigeria. Others attributed other reasons such as effective policies,

implementation and enforcement, stiffer penalties to offenders, training and employment of more

regulatory officers, frequent monitoring to track offenders as well as strict compliance with the rule of

law, public feedback and whistlebowing. Regarding the issues surrounding food smuggling, they revealed

that effective measures which the regulatory bodies can adopt includes closing of the land borders,

supporting local farmers in producing home-based food commodities, effective border control, partnership

with other government agencies to tighten security at borders and monitoring the point of sales in the

country as well as total ban of foreign and imported food products into Nigeria. However, some

participants disagreed that consumers are partly responsible for adulterating food commodities, stating it

is the wholesalers and retailers that are responsible and should be held accountable. Three (3) key themes

emerged from the interviews and survey conducted in this research and they include the following:

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Poverty: Nigeria has the highest number of people living in poverty across the world, with an estimated

95.02 million nigerians in extreme poverty (World Poverty Clock, 2019). Poverty in Nigeria is caused by

political instability, income elasticity and ethnic conflict. This has led to hunger and malnutrition among

women and children, being the most affected, unemployment and corruption.

Corruption: Corruption is a major factor aggravating the level of hunger and poverty in many developing

countries. Corruption and poverty in Nigeria are interrelated and encourages each other. Resources that

could potentially ameliorate poverty and hunger are often misused (Gelb and Decker, 2012; Shuaib,

2015).

Food safety legislations and control systems: Food safety systems in developing countries are weak,

fragmented, and not effective to protect consumers’ health. In Nigeria, this is undermined by lack of Good

Agricultural Practices (GAP), inadequate enforcement of available legislations, ignorance and lack of

technical expertise.

Food is a fundamental human need and a fundamental right, which plays a key role in a country's economic

growth. Yet there is still no daily access to food for a large proportion of the world population. Today,

food systems are facing the immense task of feeding a rising increasingly urbanized population and are

currently falling short of fulfilling nutritional requirements and ensuring long-term health for nearly half

of the world's population (Global Nutrition Report, 2017). As the world's population continues to grow,

much more effort and creativity is required to sustainably increase agricultural production, strengthen the

global supply chain, reduce food loss and waste, and ensure access to nutritious food for people suffering

from hunger and malnutrition (UN, 2019). The 17 Sustainable Development Goals (SDGs) adopted in

2015 by world leaders give a global agenda to 2030. SDG 2 (Zero Hunger) seeks to "end hunger, achieve

food security and enhance nutrition, and encourage sustainable farming" (UN, 2015). About 821 million

people are undernourished (FAO, 2019), 2 billion people lack essential micronutrients like vitamin A and

iron, and 2 billion people are overweight or obese (Development Initiatives, 2017). In addition to the SDG

2 "Zero Hunger," a number of SDGs are related to global hunger issues and include the following:

SDG 1 - No poverty: Millions of people today are struggling to meet their most fundamental needs.

Poverty and other socio-economic inequities in low, middle and high-income countries are associated with

poor nutrition, including among certain population subgroups in nations. Addressing hunger would boost

nutritional outcomes, as it is important to improve nutrition in the fight against poverty (Global Nutrition

Report, 2017; Perez-Escamilla et al., 2018).

SDG 2 – Zero Hunger: “End hunger, achieve food security and improved nutrition and promote

sustainable agriculture” emphasizes the importance of hunger as a barrier to sustainable development and

creates a trap from which people can not escape easily. A world with zero hunger can have a positive

impact on our economies, health, education, equality and social development and is a prerequisite for

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achieving the other goals of sustainable development such as education, health and gender equality (UN,

2015).

SDG 3 – Good Health and Well-being: “Ensure good health and well-being for all at all ages” addresses

all major health priorities including communicable diseases (NCDs) (UN, 2015). Overnutrition is one of

the major risk factors that drives the rise of NCDs, including heart disease, stroke, cancer and diabetes,

and chronic lung disease, collectively responsible for nearly 70% of all deaths worldwide (WHO, 2018c).

Not only do NCDs threaten development, they are also a cause and consequence of poverty, and tackling

the NCDs needs to addressing social inequity (UN, 2011). Nonetheless, the NCD agenda is at real risk of

becoming intangible and not being discussed due to the very large number of targets and measures

explicitly in SDG 3 and the SDG in general (Ordunez and Campbell, 2016).

SDG 4 – Quality Education: Education is related to better nutritional outcomes. Mothers with high-

quality secondary school education are likely to have much better nourished babies. Better nutrition also

means improved results in education, jobs and empowerment of women, as well as reduced poverty and

inequality (Global Nutrition Report, 2017).

SDG 5 – Gender Equality: Ensuring equal access to and control of assets increases agricultural output,

increases investment in child education and increases food security for households. The empowerment of

women within the food system, from food production to food preparation, is a fundamental prerequisite

for social and economic development of communities, but malnutrition hampers efforts in this direction

(Oniang'o and Mukudi, 2002).

SDG 6 – Clean Water and Sanitation: Billions of people lack access to safe drinking water and adequate

hygiene and sanitation services, living at risk of avoidable infecions and disease that have a negative effect

on nutritional status and health. Addressing water variability, scarcity and competing uses is beneficial for

food security and nutrition (Ringler et al., 2018).

SDG 10 – Reduced Inequalities: There are important synergies between food security and social

protection. Effective social assistance programs may reduce persistent food insecurity, whereas demand-

driven or elastic social insurance and safety net systems may tackle intermittent food insecurity induced

by seasonality or exposure to shocks in living conditions (HLPE, 2012).

SDG 12 – Responsible Consumption and Production: “Ensure sustainable consumption and production

patterns” implies that meeting an increasing population's nutritional needs allows consumers to choose

and food systems to provide a healthy and healthier diet with a lower environmental footprint. SDG 12

provides specific opportunities to reduce the burden of NCDs and create a global network that is

sustainable and balanced.

SDG 13 – Life on Land: The diminishing diversity of worldwide agricultural production and food

supplies may have significant implications for global diets. Agricultural diversification can contribute

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through both subsistence and income-generating pathways to diversified diets and can be an important

strategy for improving diets and nutritional outcomes in low-and middle-income countries. More work is

also needed to understand the potential impacts on overweight and obesity of agricultural diversification

(Jones, 2017).

SDG 14 – Life Below Water: Healthy water-related ecosystems provide a series of ecosystem services,

many of which in turn support nutrition and health outcomes (Ringler et al., 2018).

SDG 16 – Peace, Justice and Strong Institutions: Food security and nutrition can contribute to conflict

prevention and mitigation by building and enhancing social cohesion, addressing root causes or drivers of

conflicts, and by contributing to the legitimacy of, and trust in governments. Food security can support

peace-building efforts and peace-building can reinforce food security (FAO, 2016).

SDG 17 – Partnerships for the Goals: The complexity and the relations between all of the SDGs call

require a paradigm shift, calling all stakeholders of the food system to engage and share knowledge in

supporting communities and countries in achieving the SDGs.

The idea of food security originated in the 1940s and is now widely used in the design, implementation

and evaluation of programs and policies for humanitarian emergencies and development. Food security is

every government's central concern–in the developed and developing world. In addition, due to the nature

of our globalized world, a single country or region's actions (such as Europe, Africa, South Asia, etc.)

affect people's food security in other countries, regions, or the world. Disasters in one area have an impact

on food supply and demand elsewhere. Food security is defined as the situation where “all people, at all

times, have physical and economic access to sufficient, safe and nutritious food to meet their dietary

needs and preferences for an active healthy life” (FAO, 1996). Food security includes four elements

namely: availability, access, utilization and stability of supply. The foundational definition from the 1996

World Food Summit encompasses four dimensions:

• Availability of sufficient quantities of food of appropriate quality, supplied through domestic

production or imports (including food aid).

• Access by individuals to adequate resources (also called entitlements) for acquiring appropriate

foods for a nutritious diet.

• Utilization of food through an adequate diet, clean water, sanitation and health care to reach a state

of nutritional well-being where all physiological needs are met.

• Stability in the availability of and access to food, regardless of sudden shocks (e.g. an economic

or climatic crisis) or cyclical events (e.g. seasonal food scarcity).

The foods that are commonly involved in food fraud tend to be the most nutritious, aggravating the

problem. Several case studies have been documented that involve food fraud and its consequences for

food and nutrition security. In 2003 and 2004, over 200 ‘big-headed babies’ in Anhui Province were found

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to have suffered from severe malnutrition as a result of consuming substandard baby milk with inadequate

levels of protein (Tam and Yang, 2005). In the aftermath, regulators implemented more stringent testing

requirements for milk and baby formula. However, the tests used for protein levels were unable to

distinguish between milk protein and other nitrogen containing substances. In September 2008, milk

deliberately adulterated with melamine to disguise its protein content was detected by the Chinese

Department of Health. This led to the death of six babies and more than 290,000 people (most of them

infants) poisoned, and the subsequent banning of imported chinese milk products by the international

community (Xiu and Klein, 2010). While the food and nutrition impacts were not fully accessed, these

may have been significant. Qiao et al., (2012) found that during the melanine scare, 63% of households

with children under the age of 6 reduced consumption of all diary products; 39% cut milk consumption

completely; 18% were reported to cutting consumption by more than half and 43% by at least one-third.

This study indicates a significant drop in milk consumption by households with young children.

The time between 6 and 23 months is a vulnerable time for young children as it is a time of rapid growth

when children are susceptible to growth stunting. Food fraud results where opportunities are present, there

is motivation to cheat and control systems are absent or insufficient to deter (Ruth et al., 2017). Underlying

motivations include economic, cultural and psycho social drivers. Several authors have identified profit as

the key motivator (Lipp, 2012). For example, fraud is more likely for high value products than for low

value products. Also, firms with a strong reputation (and hence more to lose) are less likely to commit

fraud than those without. Fraud which can be easily and/or cheaply detected would likewise be expected

to be less common. Cultural factors can also influence propensity to commit fraud. In countries with a

high level of corruption, firms have been shown to be more likely to use illegal methods. Countries with

collectivist cultures have been shown to be more corrupt than countries with individualistic cultures.

Poverty and lack of social security support is also associated with high levels of corruption. Individual

characteristics and experiences can influence propensity to commit fraud. These include environmental

pressures (poverty, lack of alternatives) as well as behavioural risk factors. Illicit trade in food and

agricultural products has “many” important and negative consequences throughout the SDGs. Smuggling

is usually driven by the price disparity between the place of origin and the destination of the smuggled

goods. The key risks associated with smuggled agri-food include tax and tariff losses, as well as “severe”

knock-on effects on the economy as a whole, causing unfair competition and limiting local producers.

There is also a risk that smuggled products can introduce invasive species, disease-carrying pathogens or

pollutants threatening both human health and the agricultural economy (FoodNavigator, 2019). Fraud and

smuggling have an effect on many different foods, including beef, dairy products, fish and seafood, fruit

juices, oils, honey, spices and wine. Food fraud, commodity smuggling and illegal agrochemicals are

undermining sustainable farming, limiting crop yields, and jeopardizing the provision of fair, safe and

sustainable food supplies, slowing progress towards zero hunger. Illicit trade in agri-foods undermines the

SDGs as follows:

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• Reduces competitive and stable agricultural markets that foster economic development and poverty

reduction, hitting SDG 1 “no hunger”

• Destabilises food security and undermines sustainable food production and access to food,

undermining SDG 2 on “zero hunger”.

• Exposes consumers to harmful ingredients or deprive them of active beneficial ingredients,

threatening SDG 3 “good health and wellbeing”.

• Siphons Gross Domestic Product (GDP), jobs and tax revenues from national economies and

introduces health risks that can jeopardise corporate brands and economic sustainability, which

can be linked to SDG 8 “decent work and economic growth”.

• Deprives consumers of choice and ability to make educated and eco-friendly decisions, dampening

SDG 12 “responsible production and consumption”.

• Illegal profits underwrite smugglers, breeds corruption, subsidise wider criminal activity and

threaten political and economic stability, undermining SDG 16 on “peace, justice and strong

institutions” (FoodNavigator, 2019).

6.1. RECOMMENDATIONS

Increased public awareness and consumer education about the dangers of food fraud are key factors to

successful food legislation in Nigeria. There should be better coordination among the bodies charged with

responsibilities for food safety; capacity building by training of personnel, producers and regulators is

vital towards achieving success in implementation of food safety legislation, and the small and medium-

sized enterprises (SMEs) should be urged to form associations for ease of government support through

training and awareness creation (Omojokun, 2013). Industry, government and enforcement agencies

should always put the needs of consumers above all other considerations; this means giving food safety

and crime prevention absolute priority over other objectives. There must be clear leadership and

coordination of investigations and prosecutions, and the public interest is recognized in active enforcement

and significant penalties for significant food crimes (Brooks et al., 2017). Safe food supply also depends

on both sound science and equitable law enforcement. Periodically, new laws and regulations must be

enacted to further protect a continuing supply of food products that are safe and wholesome for the health

and wellness of people. Once laws are enacted, they must be enforced to ensure compliance by the entire

food industry including industries directly or indirectly connected with the food source, labelling,

packaging, transportation, distribution down to retail sales. All governmental agencies involved in

potential food supply chain must be given resources and authorities to discharge the 3-fold duty of (1)

informing citizens of nutrition and components of important food products; (2) enforcing existing laws

and regulations on food industry to ensure supply of safe food products and (3) investigating and

eliminating potential toxic contaminants and prosecute economic fraud via regular monitoring and

surveillance on food supply chain (Fung et al., 2018). To equitably enforce food safety laws, sound science

must be the basis of setting the regulations and protocols to inform, enforce and eliminate unsafe foods.

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Risk assessment is a scientific process that puts the concern about food contaminations in proper

perspective as the purpose of scientific risk calculation is to get the best estimate of the true risk using

available and current information (Fung et al., 2018).

6.2. LIMITATIONS

This research thesis has several limitations and they have been identified as follows: Firstly, there were

time restrains due to the submission of thesis. Secondly, the sample size of participants, especially from

the regulatory agency was insufficient. This was attributed to the fact that getting information from civil

servants from government agencies or parastatals in Nigeria is difficult and as a result, majority of them

were unwilling to share information during the collection of data. In this case, the regulatory officers who

were interviewed and the people who responded to the survey questions may not truly be a random sample.

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7. CONCLUSION

Food safety is a shared responsibility of the government, producers, processors, suppliers, retailers, and

consumers, with everyone in the food supply chain, as key players with a role to play from the farm to the

table to ensure food is safe for human consumption. Based on this study, The Nigerian government and

other stakeholders should give utmost priority to the following:

• The fight against corruption.

• Policies that will lift people out of poverty and unemployment.

• Quick resolution of ethnic conflicts and terrorism.

• Agricultural production and nutrition-related interventions to effectively tackle hunger. and

malnutrition among vulnerable groups, especially children.

The Food Safety and Quality Bill as approved by the Federal Executive Council (FEC), will help to prevent

fraudulent or deceptive practices that may affect the health of consumers and also provide a framework

for NAFDAC and other regulatory agencies to enforce stricter punishments and persecute offenders caught

in food fraud. Policy makers should build and maintain adequate food systems and infrastructures to

respond to and manage food safety risks along the entire food chain as well as integrate food safety into

broader food policies and programmes such as nutrition and food security, in order to ensure that

domestically produced food is safe internationally. Assessing the safety of new and emerging technologies

such as nanotechnology, next generation sequencing, omics technologies (genomics, proteomics and

metabolomics) and bioinformatics would greatly improve national food safety systems and legal

frameworks, and implement adequate infrastuctures to manage food fraud.

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9. JOURNAL ARTICLE

FOOD FRAUD IN NIGERIA: CHALLENGES, RISKS AND SOLUTIONS

Joy Ewomazino Opia

Technological University Dublin, School of Food Science and Environmental Health, Cathal Brugha

Street, Dublin1, Ireland.

Abstract

Food fraud is one of the most urgent and active food research and regulatory areas. It is an evolving

problem in Nigeria that has led to the deaths of many people especially the vunerable groups that includes

mostly children, the elderly and immunocomprised persons. Therefore the aim of this study is to

investigate the current challenges of food fraud in Nigeria, identify the risks it poses on the health and

wellbeing of Nigerians and propose measures to tackle food fraud at local and international levels by

regulatory and government agencies. This study explored the relationship between food fraud, food

security and the UN Sustainable Development Goals. This study is relatively new as it has never been

carried out before so it relied on information from previous research articles, journals and publications. A

total of 68 participants from the general public took part in this study and some key officers from the

National Agency for Food and Drug Administration and Control (NAFDAC) were interviewed to obtain

their opinions on the current state of food fraud in Nigeria.The findings revealed common foods being

adulterated in Nigeria are mostly fats and oils, alcoholic and non-alcoholic drinks and honey. Poverty,

corruption and poor food safety and control systems were identified throughout this study. The study

concluded by reviewing several policy framework and actions taken by the Nigerian government to proffer

solutions that can actualise the goals of the Sustainable Development Goals by 2030.

Keywords

Food Fraud; Food Security; Food Safety; Sustainable Development Goals; Nigeria

1.1. Introduction

Fraud can be defined as an intentional misrepresentation of fact by one person alone or acting on behalf

of an organization in order to deceive another person to part with something of intrinsic value. Food fraud

is a collective term used to include intentional and deliberate substitution, diversion, exploitation or

misrepresentation of food, food ingredients or food packaging, or a misleading or false assertion about an

economic benefit commodity (Spink and Moyer, 2011a). Food fraud forms include adulteration, bribery,

overrun, stealing, diversion, simulation, and falsification (Spink and Moyer, 2011b). Fraud in connection

with food is not recent. For economic gain, most early food laws and codes concentrated on adulterants.

Philosophers have raised doubts since the 4th century B.C and the penalty of Roman law for food

adulteration included servitude or exile (Fortin, 2009). Food fraud's effects are catastrophic. Food

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companies and their image are harmed, reports go viral, entire supply chains are painted with the same

brush, erodes consumer confidence, failure of markets and management and/or staff are fired, charged and

locked up. The overall effects are comparable to other corporate fraud (Kuang and Lee, 2017). Losses for

individual businesses may include social losses and sanctions, losses from third parties (e.g. additional

tests), losses of confidence, losses of sales and overpayment, as well as losses from recall (Bindt, 2016).

There is some popular belief that food theft is primarily an external threat from organized crime groups

who aim to permeate the food supply chain. While politically convenient, in fact, actors in the food supply

chain who make the most of the criminal opportunities that emerge are more often a problem (Lord et al.,

2017). Fraud is the product of the relationship between motivated criminals and the opportunities offered

by victims and those responsible for controlling risks according to Levi (2012). While food fraud is not

really a new phenomenon, food authentication and the truthfulness of food labels are currently a major

concern for many different groups of people, including the food industry, regulators, customers, etc.

(Charlebois et al., 2016).

With the increasingly poor food safety and security practices in Nigeria, there is a tendency to suffer severe

health consequences and to report massive death rates from pollutants every day. Sadly, there are poor

food safety practices and standards in Nigeria which, according to the National Agency for Food and Drug

Administration and Control (NAFDAC), has resulted in enormous economic losses, as can be seen in the

myriad of rejections of some Nigerian food exports at international borders as a result of contamination,

inadequate storage methods and adulteration of food products. A 2015 internal memo issued to Sahara

Reporters from the National Agency for Food and Drug Administration and Control (NAFDAC) Nigeria's

Food Safety and Applied Nutrition (FSAN) office disclosed that tomato paste imported from China and

sold in Nigeria fell well below national food safety standards. This was discovered by the FSAN after

conducting a study in which 314 tomato paste packets purchased in Lagos were tested in a laboratory to

determine if they had a tomato content of at least 28 percent, the minimum requirement stated by Codex

Alimentarius Standards and Nigerian Industrial Standards. The study results showed that 286 samples, or

91.1% of the samples analysed, had tomato content below the minimum of 28%. In the internal FSAN

report obtained by Sahara Reporters, the FSAN considered the consequences of the test results to be very

alarming and concluded that tomato paste product companies were working with Chinese tomato paste

manufacturers to sell to unsuspecting Nigerian consumers because Nigeria consumes approximately

300,000 tons of tomato paste imported from China annually. As a result, the FSAN recommended that

retailers refrain from selling imported tomato paste from China until further notice and released a national

recall of imported tomato paste brands from China (Sahara Reporters 2016). A dietary study conducted at

Lagos and Kano revealed at the point of consumption, an alarming amount of contaminated food. The

food was allegedly contaminated with chemicals, metals and traces of pesticides (Premium Times, 2019).

In 2018, a warning was issued by the Ghanaian Health Authority against the consumption of puffer fish

which resulted in the death of two family members while four others were hospitalized after eating the

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fish for dinner. They revealed that the puffer fish contains tetrodotoxin, a neurotoxin that makes the fish

lethal and is stated to be 1000 times more toxic than cyanide, and that it does not have an antidote and

kills by suffocating the diaphragm (NAFDAC, 2018). There has been a range of different detection

methods developed and used in the determination of the authenticity of food. In a review by Reid et al.,

(2006), many methods of detections were scrutinised including spectroscopy (UV, NIR, MIR, Raman),

isotopic analysis, chromatography, electronic nose, polymerase chain reaction, enzyme-linked

immunosorbent assay and thermal analysis – all of which are techniques that have been applied to food

authentication since 2001.

Historically, the idea of sustainable development (SD) was introduced in a paper called “Our Common

Future” by the UN Commission on Environment and Development (Brundtland Commission) report.

This definition promotes the need for growth to meet the needs of the present generation without

undermining the capacity of the future generation to meet their own needs (Brundtland et al., 1987).

Nevertheless, one of the key sustainability issues, according to Govindan et al., (2013) is to operationalize

the Brundtland Commission recommendations to guide organizational decisions. Sustainable

Development's new principles are becoming more and more relevant than they were two decades ago

because it goes beyond purely environmental, economic and social development issues and affects the

very life of people (Kumi et al., 2014). There is a need for science to support politics in this sense, as well

as coping with demands from the government and various shareholders when they are faced with the task

of achieving sustainable development (Aricò, 2014). The idea of creating the SDGs originated at the 2012

Rio+20 United Nations Summit in which Member States decided to adopt a set of guidelines for global

development with a view to growing the benchmark for developing countries and disadvantaged

communities (Gupta and Vegelin, 2016), as well as building a stronger commitment to human-centred

growth, human rights and environmental sustainability. The Sustainable Development Goals were set

through a series of measurable goals and required a great deal of global cooperation and commitment at

several levels when it came to monitoring, which is sadly seldom even feasible (Giupponi and Gain, 2016).

The Rio+20 Conference endorsed a mechanism in its final document, “The Future We Want”, while

rejecting several others, in order to negotiate a consensus on the Sustainable Development Goals (UN,

2012). Consequently, the outcome of Rio+20 was structured in many respects to be qualitatively different

from the Millennium Development Goals (MDGs) and the Sustainable Development Goals (SDGs) aimed

at being more responsive to a variety of stakeholders at multiple levels of governance (Gellers, 2016).

Following “The Future We Want”, the UN document “Transforming Our World: The Sustainable

Development Agenda 2030” contains a declaration of the 17 SDGs and 169 targets, as well as monitoring

and assessment mechanisms (Gupta and Vegelin, 2016). The Sustainable Development Goals were

developed through a comprehensive participatory mechanism and progressed through high-level

committees such as “Open Working Groups” (OWG) along with various inquiries until the Heads of State

finally approved a negotiated agreement. Five key areas have been identified by the Heads of State or the

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Five Ps of the 2030 SDG Agenda, which are people, planet, prosperity, peace, and partnerships

(Jayasooria, 2016). As Aitsi-Selmi et al., (2016) reports, 193 countries agreed on the Sustainable

Development Goals, predecessors of the Millennium Development Goals, in September 2015 in New

York, USA, focusing on an extremely comprehensive set of development goals. The Sustainable

Development Goals outlined sensitivities to weaknesses created by gender, age, and disabilities when it

comes to losses and disasters. Nevertheless, like the MDGs, the SDGs do not include, in an ecological

sense, a particular and consistent goal relevant to world population growth and the new targets for 2030

(Bergaglio, 2016). Subsequently, the SDGs have the ability to mobilize academic groups and social

movements around them to seek structural reform and responsibility for those who carry out the objectives.

Therefore, they may be reinforced by the commitment to equitable standards of growth towards all

stakeholders concerned (Gupta and Vegelin, 2016). To this end, it is the primary responsibility of each

government, state or country to mobilize and collect financial resources, which in turn would promote new

partnerships between the private sector and civil society (Jayasooria, 2016). According to Stafford-Smith

et al., (2016), the SDGs’ objectives established an agenda for the sustainable development of all nations

that adhered to economic growth, social inclusion and protection of the environment and includes:

• Goal 1: No poverty

• Goal 2: Zero hunger

• Goal 3: Good health and well being

• Goal 4: Quality education

• Goal 5: Gender equality

• Goal 6: Clean water and sanitation

• Goal 7: Affordable and clean energy

• Goal 8: Decent work and economic growth

• Goal 9: Industry, innovation and infrastructure

• Goal 10: Reduced inequalities

• Goal 11: Sustainable cities and communities

• Goal 12: Responsible consumption and production

• Goal 13: Climate action

• Goal 14: Life below water

• Goal 15: Life on land

• Goal 16: Peace, justice and strong institutions

• Goal 17: Partnerships for the goals

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Figure 1: The Global Goals 2030

1.2. NIGERIA: AN OVERVIEW

Nigeria, officially the Federal Republic of Nigeria, is a country in West Africa, bordering Niger in the

north, Chad in the northeast, Cameroon in the east and Benin in the west. Its coast in the south is located

on the Gulf of Guinea in the Atlantic Ocean. It comprises of 36 states and 1 Federal Capital Territory,

where the capital Abuja, is located and 774 local government areas. The states are grouped into six distinct

geopolitical zones – North Central, North East, North West, South East, South South and South West

(Figure 1). Nigeria is often referred to as the ‘Giant of Africa’, owing to its large population and economy.

The current population of Nigeria is 202 million based on the latest United Nations data (Worldometers,

2019), ranking Nigeria as the most populous country in Africa and the seventh most populous country in

the World. Nigeria has a total area of 923,768 km2 (356,669 sq. mi), making it the world’s 32nd largest

country. It is comparable in size to Venezuela, and is about twice the size of the US state of California. Its

borders span 4,047 kilometres (2,515 mi), and it shares borders with Benin (773 km or 480 mi), Niger (1,

497 km or 930 mi), Chad (87 km or 54 mi) and Cameroon (1,690 km or 1,050 mi). Its coastline is least

853 km (530mi).

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Figure 2: Map of Nigeria showing the six geopolitical zones

Nigeria has been a developing economy with her economic growth being unstable, unpredictable and

unsatisfactorily low in recent years especially when compared with some other nations of the world

(Machi, 2011). As the largest exporter of oil in Africa and an oil dependent economy, the country has

witnessed many oil prices shocks and disturbances over the years due to oil price volatility in the

international market. The oil price has been fluctuating since the 1980s and the 1990s due to activities of

the world powers in the global market. Apart from the incessant drop in the price of oil in the past, the

recent notable one was the drastic fall of the oil price from $112 per barrel in 2014 to almost $38 per barrel

as at the end of 2015 due to the incessant and massive supply of Shale oil by the United States to the global

market (British Petroleum Statistical Review of World Energy, 2017). In 2014, according to International

Energy Agency (IEA, 2015), Nigeria earned $77 billion from oil export. However, with the fall in oil price

in 2015, Nigeria’s oil revenue fell to $41.33 billion (OPEC Annual Statistical Bulletin, 2016). By

implication, the fall in oil price in the global market implies fall in the revenue accruing to the Nigerian

economy and difficulties in achieving a sustainable level of growth. The reason being that over 80 percent

of the government revenue comes from oil export. In addition, the monolithic nature of the Nigerian

economy since the start of oil exploration in the 1970s has been persistently threatened by the fluctuation

in oil prices. This has made the government to come to terms with the growing need for economic

diversification from oil to non-oil economy. In the 1960s, prior to the discovery of oil, more than 70% of

the rural population of Nigeria engaged in one type of agricultural activity or the other and between 1963

and 1964, the non-oil sector contributed as much as 65% to the Nation’s Gross Domestic Product (GDP)

(Yesufu, 1996). However, the oil boom of 1973/74 changed the economic environment drastically as the

windfall from oil boom around this time had a pervasive effect on the Nigerian economy even till the early

1980s. The shocks nevertheless, slowed-down the economic activity and as a result caused severe fiscal

imbalances for Nigeria and oil revenues decreased drastically (Audu, 2012). The over reliance on the

exogenous and volatile nature of oil revenue led the Nigeria government to make structural changes in

order to look into alternative means of financing the economy by reconsidering the non-oil sector that had

been neglected in the past due to oil exploration (Edame and Efefiom, 2013). After decades of neglect, the

Federal Government of Nigeria began to reform the agricultural sector in 2011 following strategic

direction laid out in the Agricultural Transformation Agenda (ATA) of the Federal Ministry of Agriculture

and Rural Development (FMARD) (FMARD, 2016). The ATA’s core purpose was to help Nigeria to

refocus federal government policymaker attention to agriculture, and the strategy’s main goal was to

rebuild the agricultural sector (FMARD, 2016). The current development strategy of the agricultural

sector – denoted the Agriculture Promotion Policy (APP) – builds on and refines the strategic direction of

the ATA. The APP was launched in 2016 and applies for the five-year period lasting until 2020. It aims at

addressing two key challenges of Nigeria’s agriculture: (1) to meet the food needs of a rapidly growing

population with domestically produced food; and (2) to transform the agricultural sector so that Nigeria

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becomes a successful exporter of agricultural products complying with international quality standards

(FMARD, 2016). Thus, agricultural transformation has been at the centre of Nigeria’s agricultural

development policy plan since the beginning of the 2010s. Yet, despite its vast agricultural potential,

Nigeria imports food – mostly staple foods – worth billions of dollars annually. Many Nigerians and even

a large proportion among the farming population lack adequate food for a healthy diet and suffer from

malnutrition. The aims and objectives of this research project is to carry out an investigative study on the

challenges of food fraud in Nigeria, identifying the risks and proposing solutions. At the end, this research

project will seek to determine the following key areas:

1. To address the level of food fraud and its impact in attaining sustainable economic growth in

Nigeria.

2. To identify lack of food policies and national control systems that will enforce regulations in

tackling food fraud in Nigeria.

3. To identify how regulatory and government agencies can promote food safety that will enhance

good health and wellbeing among consumers in Nigeria.

4. To propose measures that regulatory and government agencies in Nigeria can adopt in preventing

food fraud.

2. METHODOLOGY

Data Collection

An internet search was conducted using food fraud and Nigeria as key words. Data sources including

online newspapers, ScienceDirect, Google Scholar, Google Books as well as other scholarly articles and

journals were used to gather data from scientific studies. However, there was very limited quantity of data

available on food fraud cases in Nigeria though cases of food fraud has been reported on various Nigerian

online newspapers and from the recall and alert notifications of the National Agency for Food and Drug

Administration and Control (NAFDAC) which is the leading agency in food safety and regulation in

Nigeria. After an initial comprehensive review of publicly available data, gaps of data were identified.

From the identification of the data gaps, non-formal interviews were undertaken with key regulatory

officials in an attempt to fill these gaps. Therefore, this project relies on data that is publicly available and

interview accounts to provide a detailed overview of food fraud in Nigeria. Given the commercial

sensitivity issues surrounding data collection, interviewee identities were kept anonymous throughout this

report.

Interview Questions

• What are the food commodities that are commonly adulterated in Nigeria?

• Why are food laws in Nigeria poorly implemented and why are food commodities still adulterated

in the Nigerian markets?

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• Are there publications, published research articles or a food database where cases of food fraud

have been documented in Nigeria for the last 10 years?

• What are the processes for recalling adulterated food commodities and issuing food safety alerts?

• How does the regulatory processes in NAFDAC work and who develops the regulations?

• What are the roles of the risk assessors and risk managers in food safety management?

• What has NAFDAC done in tackling cases of food fraud in Nigeria?

• What is the relevance of NAFDAC and other agencies, both locally and internationally in tackling

food fraud?

• What has NAFDAC done in promoting food safety in Nigeria and its relevance with the UN

Sustainable Development Goals (SDGs)?

Survey Questionnaire

An online survey questionnaire was designed using SurveyMonkey containing 13 questions, some of

which were multiple choice and the remaining being open-ended questions. The survey was distributed

via social media such as Facebook, WhatsApp and LinkedIn. Subsequently, a paper-based survey

questionnaire alongside an informed consent form and information sheet, was sent to participants via

email.

Data Analysis

The results from the survey was analysed on SurveyMonkey by creating custom charts and data tables,

filtering and comparing results and exporting results in various formats. The results from the interviews

were analysed in order to identify common themes among the responses of the interviewees and

consumers.

3. Food Fraud – Current Status in Nigeria

Food Smuggling and Trafficking

Smuggling is the illicit cross-border trade of goods (Joosen and Raw, 2012); the importation of contraband

goods (Ferrier, 2009) or the movement of goods into or out of a country or trading area often to avoid

tariffs or legal obligations. Smuggling is an ancient practice and is one part of a wider set of informal,

illicit or illegal economic activities that are not effectively controlled by government (Hartnett and Dawdy,

2013). Illicit trade is “any statute prohibited action or conduct relating to production, shipping, acquisition,

storage, delivery, sale or purchase, including any practice or conduct intended to encourage such activity”

(WHO, 2003). Illicit trading is defined by the quality of the goods (Bevan et al., 1988), for example, “black

goods” are illegal, whereas “black parallel markets” describe legal goods that are exchanged illegally at

the supply chain level rather than individual actors operating in a supply chain that is otherwise legitimate.

Terms used to describe illegal goods include black, dark, second, parallel, secret, shadow, underground,

unreported, unrecorded, covert or illegal goods (Feige, 1990). Consequently, illicitness is not an intrinsic

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property of commodities or of particular economic actors, but rather a temporary quality attribute that is

often related to the distribution or circulation mechanisms of a food item (Gregson and Crang, 2016). The

Global Food Safety Initiative Position Paper on Food Fraud (GFSI, 2014) states that “food fraud, including

economically motivated adulteration subcategory, is of increasing concern. Consumers are misled by the

use of food products, ingredients and labelling for economic gain and include substitution, unapproved

modifications, misbranding, counterfeiting, stolen or other goods”. The definition does not include

trafficking and smuggling of food directly. Spink et al., (2016) however, found smuggling to be a form of

food trafficking. Translating concepts of human smuggling and trafficking, food smuggling can be defined

as when all parties involved, except regulatory and enforcement agencies, completely agree to illegal

behaviour, while food trafficking requires violence against one or more parties, but sometimes the fine

line between smuggling and trafficking is ambiguous (Butterly, 2014). Díaz (2015) distinguishes between

small, petty smuggling (for personal use) and skilled smuggling or profit trafficking where a large volume

of goods is transported via international shipping channels (Ferrier, 2009). Many food products are subject

to additional import tariffs to protect national farmers (Lotta and Bogue, 2015). It illustrates the economic

driver to participate in such activity for individuals and organizations. Joossens and Raw (2012)

distinguished between tax avoidance, legal and legitimate activity, as well as tax evasion, illegal activity,

conducted to pay less or no tax. Smuggling to achieve economic advantage is global. The cross-border

smuggling of food and other goods is troublesome and has a direct impact on the economic growth of

affected countries (Chen-Charpentier et al., 2015). The economic incentive for smuggling is the size of

the difference between the price of a food in the country of origin and the price in the country of destination

(Ferrier, 2009), citing examples of sugar, wheat and rice (Golub and Mbaye, 2007). Factors that may result

in “black” economic activity include high taxes or complex tax structures, low tax morale, low Gross

Domestic Product, poor institutions and corruption (Snowdon, 2012). Differences in recorded prevalence

rates of smuggling between countries are due to the types of goods affected by any trade prohibitions, the

degree of non-transparency of smuggled goods, the ease of putting improperly classified materials on

manifest papers, and the targeting of any enforcement resources including purposive sampling (Ferrier,

2009).

Nigerian borders are notoriously porous and several reports have established how numerous goods

including rice, find their way into the country through the borders, especially the ones adjoining Benin

Republic (Premium Times, 2019). According to a news report by the Comptroller-General of the Nigerian

Customs Service, 99 percent of rice smuggled through the land borders are unfit for consumption. He

further revealed that rice is mixed with other grain bags or stuffed inside any available crevice and

compartments of vehicles, including the engine area to deceive custom service officials. The concealed

rice is thereafter re-bagged half cooked and presented in the markets for sale as imported rice. Often times,

importers in the borders re-bagged expired rice to prolong their shelf life and as a result, rice being a

perishable product, loses valuable shelf life in non-conducive storage conditions (Premium Times, 2016).

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In late August 2019, Nigerian President Muhammadu Buhari ordered the partial closure of its boundary

with Benin to curb rice smuggling. His administration further banned trading across all land borders to

force neighbours Benin and Niger to halt food smuggling into the country (Bloomberg, 2019).

Street Food Practices

Safe food supply is a fundamental human right, leading to sound health, prosperity, and a platform for

sustainable development and poverty alleviation. Street foods are enjoying increasing patronage due to

industrialization, which causes many urban residents to eat their daily meals out of their homes (Alimi et

al., 2014). Street food vending is a common feature of most cities and towns in developing countries

(Ekanem, 1998). Street food is ready-to-eat food and beverage prepared and sold for immediate

consumption by vendors and hawkers, especially in the streets and other public places (WHO, 1996; WHO

/ FAO, 2015). Street food safety depends on the quality of raw materials, food preparation, handling and

storage practices. The sector, however, is full of unhealthy activities that have been reported to raise

serious concerns about the safety of practitioners, especially consumer health (Muyanja et al., 2011). Such

unhealthy practices spanned the entire street food business chain from agricultural raw materials to the

final street food retail and were fingered in the outbreaks of illnesses and diseases (Akinbode et al., 2011).

It has been stated that the prevention, conservation and treatment of diseases from street food borne

illnesses has resulted in the heavy drain on individuals and governments’ purses in developing countries

due to huge expenditure (Ekanem, 1998). The street food market in Nigeria, as in other developing

countries, is facing challenges. Studies have shown that home-made cereal flour and condiments used in

street food preparations are contaminated with Bacillus cereus (Umoh and Odoba, 1999; Obuekwe and

Ogbimi, 1989; Yusuf et al., (1992)) which was allegedly responsible for food-borne disease outbreaks

(Gilbert, 1979). The highest frequency of Bacillus cereus recorded by Umoh and Odoba (1999) observed

for “kunu”, a fermented cereal product in West Africa was the result of local spices and raw materials

used as condiments in their survey of microbial quality of street foods sold in the streets of Zaria, Nigeria.

The mode of transportation plays a significant role in street food contamination. Transportation and

display of meat has been reported to play an important role in accelerating their spoilage and zoonotic

disease transmission (Okoli et al., 2005). The manner in which animal carcasses are transported from

slaughter points to distribution points in crude structures such as wooden carts, open plastic or aluminum

trays on heads or “off-road” vehicles has increased the likelihood of cross contamination. Okoli et al.,

(2005) stated that vehicles not equipped for meat transport such as taxis and buses without cooling

facilities and even motorcycles carrying meat products from slaughter points to retail outlets are a common

site in Nigeria. Okoli et al., (2005) maintained that it is not unusual to see butchers and retailers turning

carcass meat for human consumption into sitting or resting platforms in the vehicles during the cause of

transportation. Meats are retailed in open wooden trays in the markets and streets of Africa, which are

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typically difficult to wash thoroughly, thereby harboring niches for meat contamination by

microorganisms and deposition of airborne pollutants.

Nigerian Food Fraud Incident/Fraudulent Commodities

Food fraud is a prevalent problem in Nigeria. On the 28th of November 2019, the management of the

National Agency for Food and Drug Administration and Control (NAFDAC) issued an alert on the

unscrupulous activities of business men and traders who revalidate expired rice and also repackage local

rice as foreign rice. The Ogun State office of the agency received the report from the Department of State

Services (DSS) in the state, of ongoing food fraud at Oke-Aje market in Ijebu Ode. On the 14th of

November 2019, Officers of the state office in company of officers of the Nigerian Police Force proceeded

to the scene of the illegal activity. On arrival, the suspected perpetrators of the food fraud instigated

unnamed persons to unleash mayhem on the team of investigators. However, enforcement officers of the

agency and its federal task force team stormed the market in company of Department of State Service

officials. They sited the perpetrators at the market who took to their heels and discovered expired rice,

caked rice, bags of local rice, bags of popular foreign rice and sealing machines at the shops. The

NAFDAC enforcement team gained access into the shops and sealed three shops during the operation. The

management of the agency noted that expired and caked rice are unwholesome as they contain moulds and

microorganisms that cause diseases which are of immense public health concern (NAFDAC, 2019a).

Similarly, on the 11th of November 2019, the agency issued an alert to the public on frozen raspberries

contaminated with norovirus from China. The contamination of the frozen raspberries with norovirus was

detected in Germany with some of the contaminated products being exported to Nigeria from Germany.

The agency warned members of the public not to consume the contaminated frozen raspberries as

norovirus is a highly infectious virus that causes vomiting and diarrhoea, and implored importers to desist

from importing the contaminated product to Nigeria (NAFDAC, 2019b). Major convictions of Nigerian

importers and business traders took place between 2017-2019. For example, Mrs Esther Akinsanya, a

business woman and her company in a popular market in Lagos, was convicted on the 30th of November,

2018 by the Federal High Court in Lagos for rebagging smuggled, adulterated and misbranded sugar. She

was fined the sum of ₦1,300,000.00 ($3,611.00) and ordered by the court to bear the cost of destruction.

On the 5th of December, 2018, operatives of the agency in Katsina State arrested three suspects for the

sale and distribution of banned and rebagged suagr. The suspects were convicted by the Federal High

Court in Katsina and fined the sum of ₦100,050.00 ($277,91.00) each. The court ordered the forfeiture of

the products to NAFDAC for destruction and the cost to be borne by the convicts. Okey Joseph Okeke, a

business man was arraigned at the Federal High Court, Akwa, Anambra State on 29th April, 2018 for the

sale of unwholesome processed foods including vegetable cooking oil, extra virgin cooking oil, alcoholic

whisky and vodka. Also, Mrs Nkiru Okoro of Ezedams Enterprises Nigeria Ltd. was investigated for

illegal production of counterfeit alcoholic beverages and obstruction of NAFDAC officers in the course

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of their operation. She was arraigned at the Federal High Court, Lagos on 27th June, 2019 (NAFDAC,

2019c).

Food Control Systems

Most food safety regulations need to be enforced at national level, for example in Nigeria, the Federal

Ministry of Health formulates and monitors policies and regulations on food hygiene and safety, the

Standards Organization of Nigeria (SON) formulates and enforces standards for the composition of

imported and locally produced foods and the National Agency for Food and Drug Administration and

Control (NAFDAC) is responsible for the control of imported and locally processed food at national and

state levels (FAO, 2005).

Food laws in Nigeria exist, but many are poorly enforced:

• Public Health laws (1917), now known as Public Health Ordinance cap 165 of 1958.

• The Standards Organization of Nigeria Decree No. 56 of 1971.

• The Food and Drug Act No. 35 of 1974 (now Food and Drug Act Cap F32 Laws of the Federal

Republic of Nigeria, 2004).

• The Animal Disease Control Decree No. 10 of 1988.

• The Marketing of Breast Milk Substitute Decree No. 41 of 1990 now Marketing (Breast Milk) Act

Cap M5 LFN 2004.

• The National Agency for Food and Drug Administration and Control Decree No. 15 of 1993 (now

NAFDAC Act Cap N1 Laws of the Federal Republic of Nigeria, 2004).

Among the various institutions concerned with food safety problems, there is a lack of coordination and

conflicting or overlapping roles at administrative level. It is important to identify roles in order to avoid

discrepancies and to facilitate the smooth running of control activities. There is a very clear need for better

coordination of the institutions that have overlapping authority. At national and local levels, the

responsibility for administrative, food safety regulation and import certification is shared between

different ministries. This condition causes other issues, such as duplication of regulatory operations,

increased bureaucracy and fragmentation of operations, as well as lack of coordination between the various

bodies, leading to trade disputes in import cases (Nguz, 2007). Food safety systems are generally weak,

fragmented and poorly coordinated in most African countries, and are therefore unsuccessful in protecting

consumer health adequately (FAO, 2005; FAO/WHO, 2005b; Majdi, 2002; Nguz, 2007). Problems arise

as a result of poor handling, processing and storage of food after harvest and also as a result of insufficient

facilities and services such as the absence or lack of safe water supply, power, storage facilities like cold

stores, transport facilities and networks, etc. (FAO, 2003).

4. Food Safety Legislation in Nigeria

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Like many other developed countries, Nigeria is facing the challenges of supplying its affluent population

with adequate food supplies. To this end, there is successful promotion of policies and programs aimed at

boosting agricultural and food production. The food safety problem, however, presents a more daunting

challenge. Like several other nations, Nigeria has to deal with the issue of foodborne diseases with the

related social, economic and health costs. The lack of or insufficient use of Good Agricultural Practices

(GAP) and the exploitation or misuse by farmers of agrochemicals and during storage in developing

countries had serious health effects on the population. Certain unsafe practices include the use of pesticides

for farming, improper application of pesticides to stored goods such as beans and grains to avoid

infestation by insects, inappropriate use of chemicals to ripen fruits such as bananas or vegetables such as

carrots and cabbages for insect infestation control (Omojokun, 2013). Similarly, improper use of food

additives such as artificial sweeteners, butylated hydroxyl anisole (BHA), nitrates, nitrites, food colours,

etc. may contribute to various conditions ranging from gastrointestinal disorders to cancer and death. Many

packaging materials are still used in rural Africa with toxic degradable products that are no longer in use

in developed countries. Another issue of concern during food processing is the partial or complete loss or

elimination of nutrients. Another cause of health concern is the inadequate digestibility or use of nutrients

and the development of new potentially harmful chemicals resulting from poor processing and handling

practices (Omojokun, 2013). Therefore, to ensure food safety and quality for domestic consumption and

export, necessary and proactive steps must be taken. This is because food was recognized internationally

not only as a biological necessity, but also as an economic and political necessity. In cultures and countries,

it is always a potential source of socio-political problems. Consequently, an effective national food safety

policy would ensure that the food supplied to consumers is sufficient, nutritious, of good quality and

balanced (Omotayo and Denloye, 2002). The Federal Government of Nigeria initiated the National Policy

on Food Hygiene and Safety in 2000 as an integral part of the Nigerian National Health Policy in

recognition of the value of food safety as an important factor in achieving a high level of health for all

Nigerians.

The overall objective of this policy is to achieve high-level food hygiene and safety practices that promote

health, control food borne diseases, reduce and eliminate the risk of illnesses associated with poor food

hygiene and safety. The policy aims at stimulating and encouraging food laws in the areas of production,

storage, handling, manufacturing, preservation, transportation, transport and marketing. It also seeks to

improve the quality of healthcare by ensuring that all food consumed in Nigeria, whether imported or

exported, is wholesome, safe, contaminant-free and affordable to consumers. The implementation of the

policy is aimed at addressing the unsatisfactory level of food hygiene and safety practices that are largely

responsible for the prevalence of foodborne diseases in Nigeria (Omotayo and Denloye, 2002). The

National Food Safety Policy provides for the establishment of a National Committee on Food Safety that

draws its membership from the public and private sectors related to the production, storage,

processing/preparation, distribution, transportation and sale of food intended for consumption.

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Regulatory and Legislative Framework

Over the years, numerous laws and regulations have been implemented to ensure the safety and

wholesomeness of the food supply in Nigeria. Such legislations include the following:

• The Public Health Laws (1917) now known as Public Health Ordinance Cap 165 of 1958.

• The Standards Organization of Nigeria Decree No. 56 of 1971.

• The Food and Drug Act No. 35 of 1974 (now Food and Drug Act Cap F.32 LFN 2004).

• The Animal Disease Control Decree No. 10 of 1988.

• The Marketing of Breast Milk Substitute Decree No. 41 of 1990 (now Marketing of Breast Milk

Substitute Act Cap M.5 LFN 2004).

• The National Agency of Food and Drug Administration and Control Decree No. 15 of 1993 (now

NAFDAC Act Cap N.1 LFN 2004).

• The Food, Drug and Related Products (Registration) Decree No. 19 of 1993 (now Food, Drug and

Related Products (Registration) Act Cap F.33 LFN 2004).

• The Counterfeit and Fake Drugs and Unwholesome Processed Foods Act No. 25 of 1999 (now

Counterfeit and Fake Drugs and Unwholesome Processed Foods (Miscellaneous Provisions) Act

Cap C.34 LFN 2004).

• Various bye-laws enacted by various LGAs in Nigeria

5. Results

Interview with Regulatory Officers at NAFDAC

Results from the interviews conducted with key regulatory officers at NAFDAC revealed that almost all

food commodities are commonly adulterated in Nigeria, with food commodities such as honey, vegetable

oil, palm oil, alcoholic and non-alcoholic beverages, flour and sugar being the most commonly adulterated

food commodities. Reasons for poor implementation of food laws in Nigeria include inadequate funding

and other logistics, gaps as a result of overlapping of functions of the government agencies that regulate

food activities, ununified regulation and enforcement, unrealistic policies and lack of compromise by law

enforcement agencies. Regarding publications, published articles or a food database where food fraud

cases have been documented in Nigeria, the food agency publishes cases of food fraud on its website (i.e.

through the recall and alert system) and through annual reports and NAFDAC Consumer Safety

publications. It has a functional food database which has registered food products only. One of the

regulatory officer stated that food products from supermarkets are registered with a global listing and the

agency ensures that any food product that is imported is registered on the global listing. Regarding reasons

food commodities are still adulterated in Nigeria, the following factors include poverty and economic gain,

ignorance and lack of awareness, porous borders, over regulation and non-seriousness in accepting laid

down laws and lack of stiff penalties for offenders. Like one of the regulatory officer quoted “Because

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people are terrible people; We arrest them, keep them in the cell till Monday, release them on Monday

after they have paid the fine and after two weeks, we discover they are still doing the same thing; just

wickedness and poverty and because people are only interested in making money”.

The processes for recalling adulterated food commodities as explained by the officers are through the

following ways:

• Notification of the product and product batch is received from government, individual

establishments or stakeholders.

• Authentication of source of consumers’ complaint will be done.

• Investigation and surveillance will take place to authenticate the problem.

• The manufacturer or importer will be notified.

• A public alert notice will be issued.

• A surveillance team will be constituted.

• Product mop-up accompanied by forfeiture form.

• Laboratory analysis.

• Destruction exercise will then take place.

The regulatory processes in NAFDAC are carried out by employed regulators and they include the

following:

For imported products:

• Collection and vetting of documents.

• Payment of relevant fees.

• Issuance of import permit for samples submission for laboratory analysis.

• Inspecting the facility abroad and collection of on the spot relevant documents.

For products meant for export and local use: Inspection of facility where products for export will be

manufactured and domiciled. Types of inspection includes:

• Initial (Advisory)

• Production

• Routine

• Investigation

• Surveillance

• Mop-Up

• Renewal

• Good Manufacturing Practice (GMP) Reassessment

• Advocacy

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• Enlightenment

When asked about the development of the regulations, they stated that the standard regulations committee

under the Registration and Regulatory Directorate is responsible for developing the regulations. The roles

of the risk assessors (i.e. the stakeholders) and the risk managers (i.e. the manufacturers) in food safety

management as stated by the regulatory officers are (1) To evaluate the risks associated with the products

they produce (2) To produce and provide food in the safest manner (3) To analyse the risk using HACCP.

Regarding measures NAFDAC has taken in tackling cases of food fraud in Nigeria, the answers given

varied from each of the officers but not limited to the following:

• Routine monitoring of all food establishments.

• Public enlightenment campaign.

• Effective collaboration with related bodies and agencies.

• For frequently committed food fraud, application of stiffer penalties for offenders.

• Sustenance of effective regulation.

• Capacity building and post market surveillance of all retail shops, markets and supermarkets.

• Deregistration of offenders if registered with NAFDAC and stiff sanctioning if not registered.

• Institution of functional food database for all registered food commodities.

• Imported food products are certified before entering into the market. They undergo proper

documentaion (certificate of analysis of the product from the country of manufacture) and the

product is analysed in the laboratory.

The relevance of NAFDAC and other agencies in tackling food fraud as well as promoting food safety in

Nigeria and its relevance with the UN Sustainable Development Goals (SDGs) will be covered in the next

sections.

Consumer Survey Questionnaire

The participants’ profiles with regards to gender and age are provided in Table 2. The majority of the

participants are aged between 25 and 54 years. According to the results, 38 (55.88%) are male while the

remaining 30 (44.12%) are female.

Age Frequency %

Under 18 0 0

18-24 5 7.35

25-34 34 50.00

35-44 11 16.18

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45-54 10 14.71

55-64 8 11.76

65-74 0 0

Above 75 0 0

Total 68 100

Gender Frequency %

Male 38 55.88

Female 30 44.12

Total 68 100

Table 2: Participants’ profile (n = 68)

Of the food commodities that are commonly adulterated in Nigeria, results showed that fats and oil (n =

36) were the most commonly adulterated, followed by alcoholic and non-alcoholic drinks (n = 17) and

honey (n = 4) respectively as shown in Table 3.

Food category Frequency %

Herbs and Spices 1 1.47

Fats and oils 37 54.41

Dairy products 2 2.94

Cereals 1 1.47

Alcoholic and non-alcoholic

drinks

17 25.00

Baked goods and

confectionery

2 2.94

Meat and meat products 2 2.94

Fish and fish products 0 0

Honey 4 5.88

Fruits and vegetables 2 2.94

Table 3: Food commodities commonly adulterated in Nigeria.

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Figure 3: Bar graph showing the overall ratio of commonly adulterated food commodities in percentage.

91.18% (n = 62) of participants agree that food laws in Nigeria are poorly implemented while 8.82% (n =

6) do not agree as shown below:

Figure 4: Bar graph showing the percentage of participants that agree/disagree on poor implementation

of food laws in Nigeria.

However, 70.59% (n = 48) of participants agree that NAFADAC are making efforts in tackling food fraud

while 29.41% (n = 20) disagree as shown below:

Figure 5: Pie chart showing the percentage of participants that agree/disagree on the efforts of NAFDAC

in tackling food fraud.

Regarding the UN Sustainable Development Goals (SDGs), 64.18% (n = 43) of the participants are fully

aware of the 2030 Global Goals while the remaining 35.82% (n = 24) are neither aware or have never

heard of the 2030 Global Goals as shown below:

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Figure 6: Bar graph showing the percentage of participants that are aware/unaware of the UN Sustainable

Goals (SDGs).

Majority of participants with 77.27% (n = 52) agree that food smuggling is a problem in Nigeria while the

remaining 22.73% (n = 15) do not agree as shown below:

Figure 7: Bar graph showing percentage of participants that agree/diagree on the problem of food

smuggling in Nigeria.

43.94% (n = 29) of participants agree that consumers are partly responsible for food adulteration in Nigeria

while the remaining 56.06% (n = 37) disagree as shown below:

Figure 8: Bar graph showing the percentage of participants that agree/disagree that consumers are partly

responsible for food adulteration in Nigeria.

6. Discussion, Recommendation and Limitation

The results from this study probes into the views of the public and regulators on food fraud in the Nigerian

context. Following a series of interviews with key regulators and a survey of public consumers in Nigeria,

the results from the research revealed that majority of participants attributed corruption, lack of

enforcement, poor implementation, bribery, lack of awareness, poor sensitisation and education as well as

poor preservation methods and hygiene as reasons for poor implementation of food laws in Nigeria. They

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stated also that profit making is one of the major reason for people adulterating food commodities; other

reasons included hunger, poverty and greed. Most participants believe that creating awareness and

educating the consumers especially in the rural areas on the dangers of food fraud and detecting fake

products is one way of promoting food safety in Nigeria. Others attributed other reasons such as effective

policies, implementation and enforcement, stiffer penalties to offenders, training and employment of more

regulatory officers, frequent monitoring to track offenders as well as strict compliance with the rule of

law, public feedback and whistlebowing. Regarding the issues surrounding food smuggling, they revealed

that effective measures which the regulatory bodies can adopt includes closing of the land borders,

supporting local farmers in producing home-based food commodities, effective border control, partnership

with other government agencies to tighten security at borders and monitoring the point of sales in the

country as well as total ban of foreign and imported food products into Nigeria. However, some

participants disagreed that consumers are partly responsible for adulterating food commodities, stating it

is the wholesalers and retailers that are responsible and should be held accountable. Three (3) key themes

emerged from the interviews and survey conducted in this research and they include the following:

Poverty: Nigeria has the highest number of people living in poverty across the world, with an estimated

95.02 million nigerians in extreme poverty (World Poverty Clock, 2019). Poverty in Nigeria is caused by

political instability, income elasticity and ethnic conflict. This has led to hunger and malnutrition among

women and children, being the most affected, unemployment and corruption.

Corruption: Corruption is a major factor aggravating the level of hunger and poverty in many developing

countries. Corruption and poverty in Nigeria are interrelated and encourages each other. Resources that

could potentially ameliorate poverty and hunger are often misused (Gelb and Decker, 2012; Shuaib,

2015).

Food safety legislations and control systems: Food safety systems in developing countries are weak,

fragmented, and not effective to protect consumers’ health. In Nigeria, this is undermined by lack of Good

Agricultural Practices (GAP), inadequate enforcement of available legislations, ignorance and lack of

technical expertise.

Food is a fundamental human need and a fundamental right, which plays a key role in a country's economic

growth. Yet there is still no daily access to food for a large proportion of the world population. Today,

food systems are facing the immense task of feeding a rising increasingly urbanized population and are

currently falling short of fulfilling nutritional requirements and ensuring long-term health for nearly half

of the world's population (Global Nutrition Report, 2017). As the world's population continues to grow,

much more effort and creativity is required to sustainably increase agricultural production, strengthen the

global supply chain, reduce food loss and waste, and ensure access to nutritious food for people suffering

from hunger and malnutrition (UN, 2019). The 17 Sustainable Development Goals (SDGs) adopted in

2015 by world leaders give a global agenda to 2030. SDG 2 (Zero Hunger) seeks to "end hunger, achieve

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food security and enhance nutrition, and encourage sustainable farming" (UN, 2015). About 821 million

people are undernourished (FAO, 2019), 2 billion people lack essential micronutrients like vitamin A and

iron, and 2 billion people are overweight or obese (Development Initiatives, 2017). In addition to the SDG

2 "Zero Hunger," a number of SDGs are related to global hunger issues and include the following:

SDG 1 - No poverty: Millions of people today are struggling to meet their most fundamental needs.

Poverty and other socio-economic inequities in low, middle and high-income countries are associated with

poor nutrition, including among certain population subgroups in nations. Addressing hunger would boost

nutritional outcomes, as it is important to improve nutrition in the fight against poverty (Global Nutrition

Report, 2017; Perez-Escamilla et al., 2018).

SDG 2 – Zero Hunger: “End hunger, achieve food security and improved nutrition and promote

sustainable agriculture” emphasizes the importance of hunger as a barrier to sustainable development and

creates a trap from which people can not escape easily. A world with zero hunger can have a positive

impact on our economies, health, education, equality and social development and is a prerequisite for

achieving the other goals of sustainable development such as education, health and gender equality (UN,

2015).

SDG 3 – Good Health and Well-being: “Ensure good health and well-being for all at all ages” addresses

all major health priorities including communicable diseases (NCDs) (UN, 2015). Overnutrition is one of

the major risk factors that drives the rise of NCDs, including heart disease, stroke, cancer and diabetes,

and chronic lung disease, collectively responsible for nearly 70% of all deaths worldwide (WHO, 2018c).

Not only do NCDs threaten development, they are also a cause and consequence of poverty, and tackling

the NCDs needs to addressing social inequity (UN, 2011). Nonetheless, the NCD agenda is at real risk of

becoming intangible and not being discussed due to the very large number of targets and measures

explicitly in SDG 3 and the SDG in general (Ordunez and Campbell, 2016).

SDG 4 – Quality Education: Education is related to better nutritional outcomes. Mothers with high-

quality secondary school education are likely to have much better nourished babies. Better nutrition also

means improved results in education, jobs and empowerment of women, as well as reduced poverty and

inequality (Global Nutrition Report, 2017).

SDG 5 – Gender Equality: Ensuring equal access to and control of assets increases agricultural output,

increases investment in child education and increases food security for households. The empowerment of

women within the food system, from food production to food preparation, is a fundamental prerequisite

for social and economic development of communities, but malnutrition hampers efforts in this direction

(Oniang'o and Mukudi, 2002).

SDG 6 – Clean Water and Sanitation: Billions of people lack access to safe drinking water and adequate

hygiene and sanitation services, living at risk of avoidable infecions and disease that have a negative effect

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on nutritional status and health. Addressing water variability, scarcity and competing uses is beneficial for

food security and nutrition (Ringler et al., 2018).

SDG 10 – Reduced Inequalities: There are important synergies between food security and social

protection. Effective social assistance programs may reduce persistent food insecurity, whereas demand-

driven or elastic social insurance and safety net systems may tackle intermittent food insecurity induced

by seasonality or exposure to shocks in living conditions (HLPE, 2012).

SDG 12 – Responsible Consumption and Production: “Ensure sustainable consumption and production

patterns” implies that meeting an increasing population's nutritional needs allows consumers to choose

and food systems to provide a healthy and healthier diet with a lower environmental footprint. SDG 12

provides specific opportunities to reduce the burden of NCDs and create a global network that is

sustainable and balanced.

SDG 13 – Life on Land: The diminishing diversity of worldwide agricultural production and food

supplies may have significant implications for global diets. Agricultural diversification can contribute

through both subsistence and income-generating pathways to diversified diets and can be an important

strategy for improving diets and nutritional outcomes in low-and middle-income countries. More work is

also needed to understand the potential impacts on overweight and obesity of agricultural diversification

(Jones, 2017).

SDG 14 – Life Below Water: Healthy water-related ecosystems provide a series of ecosystem services,

many of which in turn support nutrition and health outcomes (Ringler et al., 2018).

SDG 16 – Peace, Justice and Strong Institutions: Food security and nutrition can contribute to conflict

prevention and mitigation by building and enhancing social cohesion, addressing root causes or drivers of

conflicts, and by contributing to the legitimacy of, and trust in governments. Food security can support

peace-building efforts and peace-building can reinforce food security (FAO, 2016).

SDG 17 – Partnerships for the Goals: The complexity and the relations between all of the SDGs call

require a paradigm shift, calling all stakeholders of the food system to engage and share knowledge in

supporting communities and countries in achieving the SDGs.

The idea of food security originated in the 1940s and is now widely used in the design, implementation

and evaluation of programs and policies for humanitarian emergencies and development. Food security is

every government's central concern–in the developed and developing world. In addition, due to the nature

of our globalized world, a single country or region's actions (such as Europe, Africa, South Asia, etc.)

affect people's food security in other countries, regions, or the world. Disasters in one area have an impact

on food supply and demand elsewhere. Food security is defined as the situation where “all people, at all

times, have physical and economic access to sufficient, safe and nutritious food to meet their dietary needs

and preferences for an active healthy life” (FAO, 1996). Food security includes four elements namely:

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availability, access, utilization and stability of supply. The foundational definition from the 1996 World

Food Summit encompasses four dimensions:

• Availability of sufficient quantities of food of appropriate quality, supplied through domestic

production or imports (including food aid).

• Access by individuals to adequate resources (also called entitlements) for acquiring appropriate

foods for a nutritious diet.

• Utilization of food through an adequate diet, clean water, sanitation and health care to reach a state

of nutritional well-being where all physiological needs are met.

• Stability in the availability of and access to food, regardless of sudden shocks (e.g. an economic

or climatic crisis) or cyclical events (e.g. seasonal food scarcity).

The foods that are commonly involved in food fraud tend to be the most nutritious, aggravating the

problem. Several case studies have been documented that involve food fraud and its consequences for

food and nutrition security. In 2003 and 2004, over 200 ‘big-headed babies’ in Anhui Province were found

to have suffered from severe malnutrition as a result of consuming substandard baby milk with inadequate

levels of protein (Tam and Yang, 2005). In the aftermath, regulators implemented more stringent testing

requirements for milk and baby formula. However, the tests used for protein levels were unable to

distinguish between milk protein and other nitrogen containing substances. In September 2008, milk

deliberately adulterated with melamine to disguise its protein content was detected by the Chinese

Department of Health. This led to the death of six babies and more than 290,000 people (most of them

infants) poisoned, and the subsequent banning of imported chinese milk products by the international

community (Xiu and Klein, 2010). While the food and nutrition impacts were not fully accessed, these

may have been significant. Qiao et al., (2012) found that during the melanine scare, 63% of households

with children under the age of 6 reduced consumption of all diary products; 39% cut milk consumption

completely; 18% were reported to cutting consumption by more than half and 43% by at least one-third.

This study indicates a significant drop in milk consumption by households with young children.

The time between 6 and 23 months is a vulnerable time for young children as it is a time of rapid growth

when children are susceptible to growth stunting. Food fraud results where opportunities are present, there

is motivation to cheat and control systems are absent or insufficient to deter (Ruth et al., 2017). Underlying

motivations include economic, cultural and psycho social drivers. Several authors have identified profit as

the key motivator (Lipp, 2012). For example, fraud is more likely for high value products than for low

value products. Also, firms with a strong reputation (and hence more to lose) are less likely to commit

fraud than those without. Fraud which can be easily and/or cheaply detected would likewise be expected

to be less common. Cultural factors can also influence propensity to commit fraud. In countries with a

high level of corruption, firms have been shown to be more likely to use illegal methods. Countries with

collectivist cultures have been shown to be more corrupt than countries with individualistic cultures.

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Poverty and lack of social security support is also associated with high levels of corruption. Individual

characteristics and experiences can influence propensity to commit fraud. These include environmental

pressures (poverty, lack of alternatives) as well as behavioural risk factors. Illicit trade in food and

agricultural products has “many” important and negative consequences throughout the SDGs. Smuggling

is usually driven by the price disparity between the place of origin and the destination of the smuggled

goods. The key risks associated with smuggled agri-food include tax and tariff losses, as well as “severe”

knock-on effects on the economy as a whole, causing unfair competition and limiting local producers.

There is also a risk that smuggled products can introduce invasive species, disease-carrying pathogens or

pollutants threatening both human health and the agricultural economy (FoodNavigator, 2019). Fraud and

smuggling have an effect on many different foods, including beef, dairy products, fish and seafood, fruit

juices, oils, honey, spices and wine. Food fraud, commodity smuggling and illegal agrochemicals are

undermining sustainable farming, limiting crop yields, and jeopardizing the provision of fair, safe and

sustainable food supplies, slowing progress towards zero hunger. Illicit trade in agri-foods undermines the

SDGs as follows:

• Reduces competitive and stable agricultural markets that foster economic development and poverty

reduction, hitting SDG 1 “no hunger”

• Destabilises food security and undermines sustainable food production and access to food,

undermining SDG 2 on “zero hunger”.

• Exposes consumers to harmful ingredients or deprive them of active beneficial ingredients,

threatening SDG 3 “good health and wellbeing”.

• Siphons Gross Domestic Product (GDP), jobs and tax revenues from national economies and

introduces health risks that can jeopardise corporate brands and economic sustainability, which

can be linked to SDG 8 “decent work and economic growth”.

• Deprives consumers of choice and ability to make educated and eco-friendly decisions, dampening

SDG 12 “responsible production and consumption”.

• Illegal profits underwrite smugglers, breeds corruption, subsidise wider criminal activity and

threaten political and economic stability, undermining SDG 16 on “peace, justice and strong

institutions” (FoodNavigator, 2019).

Recommendations

Increased public awareness and consumer education about the dangers of food fraud are key factors to

successful food legislation in Nigeria. There should be better coordination among the bodies charged with

responsibilities for food safety; capacity building by training of personnel, producers and regulators is

vital towards achieving success in implementation of food safety legislation, and the small and medium-

sized enterprises (SMEs) should be urged to form associations for ease of government support through

training and awareness creation (Omojokun, 2013). Industry, government and enforcement agencies

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135

should always put the needs of consumers above all other considerations; this means giving food safety

and crime prevention absolute priority over other objectives. There must be clear leadership and

coordination of investigations and prosecutions, and the public interest is recognized in active enforcement

and significant penalties for significant food crimes (Brooks et al., 2017). Safe food supply also depends

on both sound science and equitable law enforcement. Periodically, new laws and regulations must be

enacted to further protect a continuing supply of food products that are safe and wholesome for the health

and wellness of people. Once laws are enacted, they must be enforced to ensure compliance by the entire

food industry including industries directly or indirectly connected with the food source, labelling,

packaging, transportation, distribution down to retail sales. All governmental agencies involved in

potential food supply chain must be given resources and authorities to discharge the 3-fold duty of (1)

informing citizens of nutrition and components of important food products; (2) enforcing existing laws

and regulations on food industry to ensure supply of safe food products and (3) investigating and

eliminating potential toxic contaminants and prosecute economic fraud via regular monitoring and

surveillance on food supply chain (Fung et al., 2018). To equitably enforce food safety laws, sound science

must be the basis of setting the regulations and protocols to inform, enforce and eliminate unsafe foods.

Risk assessment is a scientific process that puts the concern about food contaminations in proper

perspective as the purpose of scientific risk calculation is to get the best estimate of the true risk using

available and current information (Fung et al., 2018).

Limitations

This research thesis has several limitations and they have been identified as follows: Firstly, there were

time restrains due to the submission of thesis. Secondly, the sample size of participants, especially from

the regulatory agency was insufficient. This was attributed to the fact that getting information from civil

servants from government agencies or parastatals in Nigeria is difficult and as a result, majority of them

were unwilling to share information during the collection of data. In this case, the regulatory officers who

were interviewed and the people who responded to the survey questions may not truly be a random sample.

7. Conclusion

Food safety is a shared responsibility of the government, producers, processors, suppliers, retailers, and

consumers, with everyone in the food supply chain, as key players with a role to play from the farm to the

table to ensure food is safe for human consumption. Based on this study, The Nigerian government and

other stakeholders should give utmost priority to the following:

• The fight against corruption.

• Policies that will lift people out of poverty and unemployment.

• Quick resolution of ethnic conflicts and terrorism.

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• Agricultural production and nutrition-related interventions to effectively tackle hunger. and

malnutrition among vulnerable groups, especially children.

The Food Safety and Quality Bill as approved by the Federal Executive Council (FEC), will help to prevent

fraudulent or deceptive practices that may affect the health of consumers and also provide a framework

for NAFDAC and other regulatory agencies to enforce stricter punishments and persecute offenders caught

in food fraud. Policy makers should build and maintain adequate food systems and infrastructures to

respond to and manage food safety risks along the entire food chain as well as integrate food safety into

broader food policies and programmes such as nutrition and food security, in order to ensure that

domestically produced food is safe internationally. Assessing the safety of new and emerging technologies

such as nanotechnology, next generation sequencing, omics technologies (genomics, proteomics and

metabolomics) and bioinformatics would greatly improve national food safety systems and legal

frameworks, and implement adequate infrastuctures to manage food fraud.

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Tam, W and Yang, D. (2005). Food safety and the development of regulatory institutions in China. Asian

Perspectives 29(4), pp.5-36.

Umoh, V.J and Odoba, M.B. (1999). Safety and quality evaluation of street foods sold in Zaria, Nigeria. Food

Control 10(1), pp. 9-14.

UN (2012). The future we want. Retrieved from

https://www.un.org.ga/search/view_doc.asp?symbol=A/RES/66/288&Lang=E. Accessed on 11th

September, 2019.

UN (2015). Transforming our world: The 2030 Agends for sustainable development. United Nations, New York.

UN (2019). Food Security and Nutrition and Sustainable Agriculture. Retrieved from

https://sustainabledevelopment.un.org/topics/foodagriculture. Accessed on 28th December, 2019.

WHO (2003). WHO framework convention on tobacco control. World Health Organization, Geneva.

WHO (2018c). NCDs Fact Sheet. Retrieved from http://www.who.int/en/news-room/fact-

sheets/detail/noncommunicable-diseases. Accessed on 28th December, 2019.

World Poverty Clock, (2019). Retrieved from https://worldpoverty.io/. Accessed on 6th January, 2020.

Xiu, C and Klein, K.K. (2010). Melamine in milk products in China: Examining the factors that led to deliberate

use of the contaminant. Food Policy 35, pp. 463-470.

Yusuf, I.Z., Umoh, V.J and Ahmad, A.A. (1992). Occurrence and survival of enterotoxigenic Bacillus cereus in

some Nigerian flour-based foods. Food Control 3, pp. 1491-1552.

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10. APPENDIX A

10.1. Guide for Authors for Food Control Journal

INTRODUCTION

Food Control is an international journal that provides essential information for those involved in food

safety and process control.

Food Control covers:

Microbial food safety and antimicrobial systems Mycotoxins Hazard analysis, HACCP and food safety

objectives Risk assessment, including microbial risk assessment Quality assurance and control Good

manufacturing practices Food process systems design and control Food Packaging Rapid methods of

analysis and detection, including sensor technology Environmental control and safety Codes of practice,

legislation and international harmonization Consumer issues Education, training and research needs.

The scope of Food Control is comprehensive and includes original research papers, authoritative reviews,

short communications, comment articles that report on new developments in food control, and position

papers.

The work described should be innovative either in the approach or in the methods used. The significance

of the results either for the science community or for the food industry must also be specified.

Contributions that do not fulfil these requirements will not be considered for review and publication.

Types of paper

Original high-quality research papers (preferably no more than 7000 words, including tables and

illustrations). Major review articles, up to 10,000 words Short communications of up to 3000 words (not

including references), describing work that may be of a preliminary nature but which merits immediate

publication. Short reviews on topical subjects, up to 6000 words. Comment articles not exceeding 2000

words. Authoritative position papers from expert groups are also welcome.

Food Control also publishes book reviews, Letters to the Editor, conference reports and a calendar of

forthcoming events.

The Editor-in-Chief has the right to decline formal review of a manuscript when it is deemed that the

manuscript is 1) on a topic outside the scope of the Journal; 2) lacking technical merit; 3) of insufficient

novelty for a wide international readership; 4) fragmentary and providing marginally incremental results;

or 5) is poorly written.

All contributions deemed suitable for review are read by two or more referees to ensure both accuracy and

relevance, and revisions to the script may thus be required. On acceptance, contributions are subject to

editorial amendment to suit house style. When a manuscript is returned for revision prior to final

acceptance, the revised version must be submitted as soon as possible after the author's receipt of the

referees' reports. Revised manuscripts returned after four months will be considered as new submissions

subject to full re-review.

Contact details for submission

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Submission to this journal proceeds totally online. Use the following guidelines to prepare your article.

Via the homepage of this journal http://ees.elsevier.com/foodcont you will be guided stepwise through the

creation and uploading of the various files.

Submission checklist

You can use this list to carry out a final check of your submission before you send it to the journal for

review. Please check the relevant section in this Guide for Authors for more details.

Ensure that the following items are present:

One author has been designated as the corresponding author with contact details:

• E-mail address

• Full postal address

All necessary files have been uploaded:

Manuscript:

• Include keywords

• All figures (include relevant captions)

• All tables (including titles, description, footnotes)

• Ensure all figure and table citations in the text match the files provided

• Indicate clearly if color should be used for any figures in print

Graphical Abstracts / Highlights files (where applicable)

Supplemental files (where applicable)

Further considerations

• Manuscript has been 'spell checked' and 'grammar checked'

• All references mentioned in the Reference List are cited in the text, and vice versa

• Permission has been obtained for use of copyrighted material from other sources (including the

Internet)

• A competing interest statement is provided, even if the authors have no competing interests to declare

• Journal policies detailed in this guide have been reviewed

• Referee suggestions and contact details provided, based on journal requirements

For further information, visit our Support Centre.

BEFORE YOU BEGIN

Ethics in publishing

Please see our information pages on Ethics in publishing and Ethical guidelines for journal publication.

Declaration of interest

All authors must disclose any financial and personal relationships with other people or organizations that

could inappropriately influence (bias) their work. Examples of potential competing interests include

employment, consultancies, stock ownership, honoraria, paid expert testimony, patent

applications/registrations, and grants or other funding. Authors must disclose any interests in two places:

1. A summary declaration of interest statement in the title page file (if double-blind) or the manuscript file

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(if single-blind). If there are no interests to declare then please state this: 'Declarations of interest: none'.

This summary statement will be ultimately published if the article is accepted.

2. Detailed disclosures as part of a separate Declaration of Interest form, which forms part of the journal's

official records. It is important for potential interests to be declared in both places and that the information

matches. More information.

Submission declaration and verification

Submission of an article implies that the work described has not been published previously (except in the

form of an abstract, a published lecture or academic thesis, see 'Multiple, redundant or concurrent

publication' for more information), that it is not under consideration for publication elsewhere, that its

publication is approved by all authors and tacitly or explicitly by the responsible authorities where the

work was carried out, and that, if accepted, it will not be published elsewhere in the same form, in English

or in any other language, including electronically without the written consent of the copyright-holder. To

verify originality, your article may be checked by the originality detection service Crossref Similarity

Check.

Preprints

Please note that preprints can be shared anywhere at any time, in line with Elsevier's sharing policy.

Sharing your preprints e.g. on a preprint server will not count as prior publication (see 'Multiple, redundant

or concurrent publication' for more information).

Use of inclusive language

Inclusive language acknowledges diversity, conveys respect to all people, is sensitive to differences, and

promotes equal opportunities. Articles should make no assumptions about the beliefs or commitments of

any reader, should contain nothing which might imply that one individual is superior to another on the

grounds of race, sex, culture or any other characteristic, and should use inclusive language throughout.

Authors should ensure that writing is free from bias, for instance by using 'he or she', 'his/her' instead of

'he' or 'his', and by making use of job titles that are free of stereotyping (e.g. 'chairperson' instead of

'chairman' and 'flight attendant' instead of 'stewardess').

Author contributions

For transparency, we encourage authors to submit an author statement file outlining their individual

contributions to the paper using the relevant Credit roles: Conceptualization; Data curation; Formal

analysis; Funding acquisition; Investigation; Methodology; Project administration; Resources; Software;

Supervision; Validation; Visualization; Roles/Writing - original draft; Writing - review & editing.

Authorship statements should be formatted with the names of authors first and Credit role(s) following.

More details and an example

Changes to authorship

Authors are expected to consider carefully the list and order of authors before submitting their

manuscript and provide the definitive list of authors at the time of the original submission. Any addition,

deletion or rearrangement of author names in the authorship list should be made only before the

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manuscript has been accepted and only if approved by the journal Editor. To request such a change, the

Editor must receive the following from the corresponding author: (a) the reason for the change in

author list and (b) written confirmation (e-mail, letter) from all authors that they agree with the addition,

removal or rearrangement. In the case of addition or removal of authors, this includes confirmation from

the author being added or removed.

Only in exceptional circumstances will the Editor consider the addition, deletion or rearrangement of

authors after the manuscript has been accepted. While the Editor considers the request, publication of the

manuscript will be suspended. If the manuscript has already been published in an online issue, any requests

approved by the Editor will result in a corrigendum.

Copyright

Upon acceptance of an article, authors will be asked to complete a 'Journal Publishing Agreement' (see

more information on this). An e-mail will be sent to the corresponding author confirming receipt of the

manuscript together with a 'Journal Publishing Agreement' form or a link to the online version of this

agreement.

Subscribers may reproduce tables of contents or prepare lists of articles including abstracts for internal

circulation within their institutions. Permission of the Publisher is required for resale or distribution

outside the institution and for all other derivative works, including compilations and translations. If

excerpts from other copyrighted works are included, the author(s) must obtain written permission from

the copyright owners and credit the source(s) in the article. Elsevier has pre-printed forms for use by

authors in these cases.

For gold open access articles: Upon acceptance of an article, authors will be asked to complete an

'Exclusive License Agreement' (more information). Permitted third party reuse of gold open access articles

is determined by the author's choice of user license.

Author rights

As an author you (or your employer or institution) have certain rights to reuse your work. More

information.

Elsevier supports responsible sharing

Find out how you can share your research published in Elsevier journals.

Role of the funding source

You are requested to identify who provided financial support for the conduct of the research and/or

preparation of the article and to briefly describe the role of the sponsor(s), if any, in study design; in the

collection, analysis and interpretation of data; in the writing of the report; and in the decision to submit

the article for publication. If the funding source(s) had no such involvement then this should be stated.

Open access

Please visit our Open Access page from the Journal Homepage for more information.

Elsevier Researcher Academy

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Researcher Academy is a free e-learning platform designed to support early and mid-career researchers

throughout their research journey. The "Learn" environment at Researcher Academy offers several

interactive modules, webinars, downloadable guides and resources to guide you through the process of

writing for research and going through peer review. Feel free to use these free resources to improve your

submission and navigate the publication process with ease.

Language (usage and editing services)

Please write your text in good English (American or British usage is accepted, but not a mixture of these).

Authors who feel their English language manuscript may require editing to eliminate possible grammatical

or spelling errors and to conform to correct scientific English may wish to use the English Language

Editing service available from Elsevier's Author Services.

Submission

Our online submission system guides you stepwise through the process of entering your article details and

uploading your files. The system converts your article files to a single PDF file used in the peer-review

process. Editable files (e.g., Word, LaTeX) are required to typeset your article for final publication. All

correspondence, including notification of the Editor's decision and requests for revision, is sent by e-mail.

Authors must provide and use an email address unique to themselves and not shared with another author

registered in EES, or a department.

Referees

Please submit the names and institutional e-mail addresses of several potential referees. For more details,

visit our Support site. Note that the editor retains the sole right to decide whether or not the suggested

reviewers are used.

PREPARATION

Peer review

This journal operates a single blind review process. All contributions will be initially assessed by the editor

for suitability for the journal. Papers deemed suitable are then typically sent to a minimum of two

independent expert reviewers to assess the scientific quality of the paper. The Editor is responsible for the

final decision regarding acceptance or rejection of articles. The Editor's decision is final. More information

on types of peer review.

Use of word processing software

It is important that the file be saved in the native format of the word processor used. The text should be in

single-column format. Keep the layout of the text as simple as possible. Most formatting codes will be

removed and replaced on processing the article. In particular, do not use the word processor's options to

justify text or to hyphenate words. However, do use bold face, italics, subscripts, superscripts etc. When

preparing tables, if you are using a table grid, use only one grid for each individual table and not a grid for

each row. If no grid is used, use tabs, not spaces, to align columns. The electronic text should be prepared

in a way very similar to that of conventional manuscripts (see also the Guide to Publishing with Elsevier).

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Note that source files of figures, tables and text graphics will be required whether or not you embed your

figures in the text. See also the section on Electronic artwork.

To avoid unnecessary errors, you are strongly advised to use the 'spell-check' and 'grammar-check'

functions of your word processor.

Request you to kindly submit your manuscript with continuous line numbers.

Article structure

Subdivision - numbered sections

Divide your article into clearly defined and numbered sections. Subsections should be numbered 1.1 (then

1.1.1, 1.1.2, ...), 1.2, etc. (the abstract is not included in section numbering). Use this numbering also for

internal cross-referencing: do not just refer to 'the text'. Any subsection may be given a brief heading. Each

heading should appear on its own separate line.

Introduction

State the objectives of the work and provide an adequate background, avoiding a detailed literature survey

or a summary of the results.

Materials and Methods

Provide sufficient details to allow the work to be reproduced by an independent researcher. Methods that

are already published should be summarized, and indicated by a reference. If quoting directly from a

previously published method, use quotation marks and also cite the source. Any modifications to existing

methods should also be described.

Key Resources Table

To enable reproducibility of the research, we encourage authors to submit a Key Resources Table, which

helps make the resources clear to readers. The Key Resources Table highlights the genetically modified

organisms and strains, cell lines, reagents and other resources essential to reproduce the results presented

in a paper. More information is available here https://www.elsevier.com/authors/ author-resources/key-

resources-table

Theory/calculation

A Theory section should extend, not repeat, the background to the article already dealt with in the

Introduction and lay the foundation for further work. In contrast, a Calculation section represents a

practical development from a theoretical basis.

Results

Results should be clear and concise.

Discussion

This should explore the significance of the results of the work, not repeat them. A combined Results and

Discussion section is often appropriate. Avoid extensive citations and discussion of published literature.

Conclusions

The main conclusions of the study may be presented in a short Conclusions section, which may stand

alone or form a subsection of a Discussion or Results and Discussion section.

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Appendices

If there is more than one appendix, they should be identified as A, B, etc. Formulae and equations in

appendices should be given separate numbering: Eq. (A.1), Eq. (A.2), etc.; in a subsequent appendix, Eq.

(B.1) and so on. Similarly, for tables and figures: Table A.1; Fig. A.1, etc.

Essential title page information

• Title. Concise and informative. Titles are often used in information-retrieval systems. Avoid

abbreviations and formulae where possible.

• Author names and affiliations. Please clearly indicate the given name(s) and family name(s) of

each author and check that all names are accurately spelled. You can add your name between

parentheses in your own script behind the English transliteration. Present the authors' affiliation

addresses (where the actual work was done) below the names. Indicate all affiliations with a lower-

case superscript letter immediately after the author's name and in front of the appropriate address.

Provide the full postal address of each affiliation, including the country name and, if available, the

e-mail address of each author.

• Corresponding author. Clearly indicate who will handle correspondence at all stages of refereeing

and publication, also post-publication. This responsibility includes answering any future queries

about Methodology and Materials. Ensure that the e-mail address is given and that contact

details are kept up to date by the corresponding author.

• Present/permanent address. If an author has moved since the work described in the article was

done, or was visiting at the time, a 'Present address' (or 'Permanent address') may be indicated as a

footnote to that author's name. The address at which the author actually did the work must be

retained as the main, affiliation address. Superscript Arabic numerals are used for such footnotes.

Highlights

Highlights are mandatory for this journal as they help increase the discoverability of your article via search

engines. They consist of a short collection of bullet points that capture the novel results of your research

as well as new methods that were used during the study (if any). Please have a look at the examples here:

example Highlights.

Highlights should be submitted in a separate editable file in the online submission system. Please use

'Highlights' in the file name and include 3 to 5 bullet points (maximum 85 characters, including spaces,

per bullet point).

Abstract

A concise and factual abstract is required. The abstract should state briefly the purpose of the research, the

principal results and major conclusions. An abstract is often presented separately from the article, so it

must be able to stand alone. For this reason, References should be avoided, but if essential, then cite the

author(s) and year(s). Also, non-standard or uncommon abbreviations should be avoided, but if essential

they must be defined at their first mention in the abstract itself.

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Keywords

Immediately after the abstract, provide a maximum of 6 keywords, using American spelling and avoiding

general and plural terms and multiple concepts (avoid, for example, 'and', 'of'). Be sparing with

abbreviations: only abbreviations firmly established in the field may be eligible. These keywords will be

used for indexing purposes.

Abbreviations

Define abbreviations that are not standard in this field in a footnote to be placed on the first page of the

article. Such abbreviations that are unavoidable in the abstract must be defined at their first mention there,

as well as in the footnote. Ensure consistency of abbreviations throughout the article.

Acknowledgements

Collate acknowledgements in a separate section at the end of the article before the references and do not,

therefore, include them on the title page, as a footnote to the title or otherwise. List here those individuals

who provided help during the research (e.g., providing language help, writing assistance or proof reading

the article, etc.).

Formatting of funding sources

List funding sources in this standard way to facilitate compliance to funder's requirements:

Funding: This work was supported by the National Institutes of Health [grant numbers xxxx, yyyy]; the

Bill & Melinda Gates Foundation, Seattle, WA [grant number zzzz]; and the United States Institutes of

Peace [grant number aaaa].

It is not necessary to include detailed descriptions on the program or type of grants and awards. When

funding is from a block grant or other resources available to a university, college, or other research

institution, submit the name of the institute or organization that provided the funding.

If no funding has been provided for the research, please include the following sentence:

This research did not receive any specific grant from funding agencies in the public, commercial, or not-

for-profit sectors.

Units

Follow internationally accepted rules and conventions: use the international system of units (SI). If other

units are mentioned, please give their equivalent in SI.

Math formulae

Please submit math equations as editable text and not as images. Present simple formulae in line with

normal text where possible and use the solidus (/) instead of a horizontal line for small fractional terms,

e.g., X/Y. In principle, variables are to be presented in italics. Powers of e are often more conveniently

denoted by exp. Number consecutively any equations that have to be displayed separately from the text

(if referred to explicitly in the text).

Mathematical and technical settings

Use the appropriate number of significant figures to express your data - they should be justifiable and

reflect the necessary level of accuracy of the method. A normal maximum should be 3 - e.g. 37.1, 2.53).

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Detailed mathematical discussion should be placed in an appendix. Equations and formulae should be

typewritten. Equations should be numbered consecutively with Arabic numerals in parentheses on the

right-hand side of the page. Special symbols should be identified in the margin, and the meaning of all

symbols should be explained in the text where they first occur. If you use several symbols, a list of

definitions (not necessarily for publication) will help the editor. Type mathematical equations exactly as

they should appear in print. Journal style for letter symbols is as follows: italic (indicated by underlining);

constants, roman type; matrices and vectors, bold type (indicated by wavy underlining).

Footnotes

Footnotes should be used sparingly. Number them consecutively throughout the article. Many word

processors can build footnotes into the text, and this feature may be used. Otherwise, please indicate the

position of footnotes in the text and list the footnotes themselves separately at the end of the article. Do

not include footnotes in the Reference list.

Artwork

Electronic artwork

General points

• Make sure you use uniform lettering and sizing of your original artwork.

• Embed the used fonts if the application provides that option.

• Aim to use the following fonts in your illustrations: Arial, Courier, Times New Roman, Symbol, or use

fonts that look similar.

• Number the illustrations according to their sequence in the text.

• Use a logical naming convention for your artwork files.

• Provide captions to illustrations separately.

• Size the illustrations close to the desired dimensions of the published version.

• Submit each illustration as a separate file.

• Ensure that color images are accessible to all, including those with impaired color vision.

A detailed guide on electronic artwork is available.

You are urged to visit this site; some excerpts from the detailed information are given here. Formats

If your electronic artwork is created in a Microsoft Office application (Word, PowerPoint, Excel) then

please supply 'as is' in the native document format.

Regardless of the application used other than Microsoft Office, when your electronic artwork is

finalized, please 'Save as' or convert the images to one of the following formats (note the resolution

requirements for line drawings, halftones, and line/halftone combinations given below): EPS (or PDF):

Vector drawings, embed all used fonts.

TIFF (or JPEG): Color or grayscale photographs (halftones), keep to a minimum of 300 dpi.

TIFF (or JPEG): Bitmapped (pure black & white pixels) line drawings, keep to a minimum of 1000 dpi.

TIFF (or JPEG): Combinations bitmapped line/half-tone (color or grayscale), keep to a minimum of

500 dpi.

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Please do not:

• Supply files that are optimized for screen use (e.g., GIF, BMP, PICT, WPG); these typically have a low

number of pixels and limited set of colors;

• Supply files that are too low in resolution;

• Submit graphics that are disproportionately large for the content.

Color artwork

Please make sure that artwork files are in an acceptable format (TIFF (or JPEG), EPS (or PDF), or MS

Office files) and with the correct resolution. If, together with your accepted article, you submit usable

color figures then Elsevier will ensure, at no additional charge, that these figures will appear in color online

(e.g., ScienceDirect and other sites) regardless of whether or not these illustrations are reproduced in color

in the printed version. For color reproduction in print, you will receive information regarding the

costs from Elsevier after receipt of your accepted article. Please indicate your preference for color: in

print or online only. Further information on the preparation of electronic artwork.

Figure captions

Ensure that each illustration has a caption. Supply captions separately, not attached to the figure. A caption

should comprise a brief title (not on the figure itself) and a description of the illustration. Keep text in the

illustrations themselves to a minimum but explain all symbols and abbreviations used.

Tables

Please submit tables as editable text and not as images. Tables can be placed either next to the relevant

text in the article, or on separate page(s) at the end. Number tables consecutively in accordance with their

appearance in the text and place any table notes below the table body. Be sparing in the use of tables and

ensure that the data presented in them do not duplicate results described elsewhere in the article. Please

avoid using vertical rules and shading in table cells.

References

Citation in text

Please ensure that every reference cited in the text is also present in the reference list (and vice versa). Any

references cited in the abstract must be given in full. Unpublished results and personal communications

are not recommended in the reference list, but may be mentioned in the text. If these references are

included in the reference list, they should follow the standard reference style of the journal and should

include a substitution of the publication date with either 'Unpublished results' or 'Personal communication'.

Citation of a reference as 'in press' implies that the item has been accepted for publication.

Web references

As a minimum, the full URL should be given and the date when the reference was last accessed. Any

further information, if known (DOI, author names, dates, reference to a source publication, etc.), should

also be given. Web references can be listed separately (e.g., after the reference list) under a different

heading if desired, or can be included in the reference list.

Data references

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This journal encourages you to cite underlying or relevant datasets in your manuscript by citing them in

your text and including a data reference in your Reference List. Data references should include the

following elements: author name(s), dataset title, data repository, version (where available), year, and

global persistent identifier. Add [dataset] immediately before the reference so we can properly identify it

as a data reference. The [dataset] identifier will not appear in your published article.

References in a special issue

Please ensure that the words 'this issue' are added to any references in the list (and any citations in the text)

to other articles in the same Special Issue.

Reference management software

Most Elsevier journals have their reference template available in many of the most popular reference

management software products. These include all products that support Citation Style Language styles,

such as Mendeley. Using citation plug-ins from these products, authors only need to select the appropriate

journal template when preparing their article, after which citations and bibliographies will be automatically

formatted in the journal's style. If no template is yet available for this journal, please follow the format of

the sample references and citations as shown in this Guide. If you use reference management software,

please ensure that you remove all field codes before submitting the electronic manuscript. More

information on how to remove field codes from different reference management software.

Users of Mendeley Desktop can easily install the reference style for this journal by clicking the following

link:

http://open.mendeley.com/use-citation-style/food-control

When preparing your manuscript, you will then be able to select this style using the Mendeley plug-ins

for Microsoft Word or LibreOffice.

Reference style

Text: Citations in the text should follow the referencing style used by the American Psychological

Association. You are referred to the Publication Manual of the American Psychological Association, Sixth

Edition, ISBN 978-1-4338-0561-5, copies of which may be ordered online or APA Order Dept., P.O.B.

2710, Hyattsville, MD 20784, USA or APA, 3 Henrietta Street, London, WC3E 8LU, UK.

List: references should be arranged first alphabetically and then further sorted chronologically if necessary.

More than one reference from the same author(s) in the same year must be identified by the letters 'a', 'b',

'c', etc., placed after the year of publication.

Examples:

Reference to a journal publication:

Van der Geer, J., Hanraads, J. A. J., & Lupton, R. A. (2010). The art of writing a scientific article.

Journal of Scientific Communications, 163, 51–59. https://doi.org/10.1016/j.Sc.2010.00372.

Reference to a journal publication with an article number:

Van der Geer, J., Hanraads, J. A. J., & Lupton, R. A. (2018). The art of writing a scientific article.

Heliyon, 19, e00205. https://doi.org/10.1016/j.heliyon.2018.e00205.

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Reference to a book:

Strunk, W., Jr., & White, E. B. (2000). The elements of style. (4th ed.). New York: Longman, (Chapter 4).

Reference to a chapter in an edited book:

Mettam, G. R., & Adams, L. B. (2009). How to prepare an electronic version of your article. In B. S.

Jones, & R. Z. Smith (Eds.), Introduction to the electronic age (pp. 281–304). New York: E-Publishing

Inc.

Reference to a website:

Cancer Research UK. Cancer statistics reports for the UK. (2003). http://www.cancerresearchuk.org/

aboutcancer/statistics/cancerstatsreport/ Accessed 13 March 2003.

Reference to a dataset:

[dataset] Oguro, M., Imahiro, S., Saito, S., Nakashizuka, T. (2015). Mortality data for Japanese oak wilt

disease and surrounding forest compositions. Mendeley Data, v1. https://doi.org/10.17632/ xwj98nb39r.1.

Reference to a conference paper or poster presentation:

Engle, E.K., Cash, T.F., & Jarry, J.L. (2009, November). The Body Image Behaviours Inventory-3:

Development and validation of the Body Image Compulsive Actions and Body Image Avoidance Scales.

Poster session presentation at the meeting of the Association for Behavioural and Cognitive Therapies,

New York, NY.

Journal abbreviations source

Journal names should be abbreviated according to the List of Title Word Abbreviations.

Video

Elsevier accepts video material and animation sequences to support and enhance your scientific research.

Authors who have video or animation files that they wish to submit with their article are strongly

encouraged to include links to these within the body of the article. This can be done in the same way as a

figure or table by referring to the video or animation content and noting in the body text where it should

be placed. All submitted files should be properly labelled so that they directly relate to the video file's

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10.2. APPENDIX B – Survey Questionnaire

1. What is your gender?

Male

Female

2. What is your age?

Under 18 45-54 years

18-24 years 55-64 years

25-34 years 65-74 years

35-44 years Above 75 years old

3.What are the food commodities that are commonly adulterated in Nigeria?

Herbs and Spices

Fats and Oils e.g. palm oil, vegetable oil, olive oil, etc.

Diary products e.g. milk, butter, cheese, etc.

Cereals e.g. rice, maize, wheat, etc.

Alcoholic and non-alcoholic drinks

Baked goods and confectioneries e.g. bread, pastries, cakes, chocolates, biscuits, etc.

Meat and meat products

Fish and fish products

Honey

Fruits and vegetables

4. In your opinion, do you feel that food laws in Nigeria are poorly implemented?

Yes

No

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5. If yes, state reasons and if no, state reasons.

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6. Do you feel regulatory agencies such as NAFDAC are making efforts to tackle cases of food

fraud in Nigeria?

Yes

No

7. In your opinion, state reasons why people adulterate food commodities in Nigeria?

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8. Have you heard of the UN Sustainable Development Goals?

Yes

No

9. How can NAFDAC and other government agencies promote food safety in Nigeria?

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10. In your opinion, do you think food smuggling is a major problem in Nigeria?

Yes

No

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11. What measures can be taken to tackle food smuggling in Nigeria?

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12. In your opinion, do you feel consumers are partly responsible for food fraud in Nigeria?

Yes

No

13. If yes, state reasons and if no, state reasons.

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