In 2013, the horsemeat scandal rocked the nation, forcing widespread change inside the food industry. But has it been enough to stop another incident?

It was a scandal that rocked the food industry. The discovery of horsemeat in certain beef products in January 2013 caused a national outrage and led the national news agenda for weeks. Tesco, Asda, ABP Food Group and Findus were among those implicated in an adulteration scam that cost an estimated £850m due to recalls, lost sales, and tumbling share prices (Tesco’s market value alone fell £300m). But the fallout went beyond just the financial. Perhaps the highest cost of the horsemeat scandal was the breakdown of trust between brands and shoppers.

A decade on from the horsemeat scandal and there is widespread recognition that much of this trust has been rebuilt. Yet as we move into 2023, experts warn that a new perfect storm of factors is creating an ideal set of conditions for fraudsters to exploit. “We have many more lines of defence [now],” says Emily Miles, CEO of the Food Standards Agency. “But that doesn’t mean there couldn’t be another scandal [like horsemeat].”

On the tenth anniversary of one of the industry’s darkest episodes, it’s timely to ask the question: is our food chain any safer from the risk of fraud?

In the spring of 2013, then Defra secretary Owen Paterson commissioned Professor Chris Elliott, a food science professor from Queen’s University Belfast, and expert in food safety and integrity, to carry out an independent review into the horsemeat scandal. The first thing Elliott noticed was that nobody within government was willing to take the lead on responding to the crisis. “Everybody was running for cover,” he recalls, a symptom of the confusion that reigned over whether this was a food safety issue or solely one of food authenticity.

During the review, Elliott and his team spent a year touring abattoirs, processing plants, laboratories and wood-panelled Whitehall meeting rooms, eventually delivering his proposed solution in July 2014. The answer, he said, was a national food crime prevention framework under eight pillars which, among other recommendations, called for an overhaul of audit regimes, information sharing and enforcement capability.

It also called for a change in industry culture. Back in 2013, Elliott says that above all else, “cost was king”. This created tension between technical and commercial teams in which “commercial won every argument”. Now he feels the relationship is more equal, with technical directors better represented at a board level in retail and manufacturing businesses.


The horsemeat adulteration scandal of 2013 affected the likes of Tesco, Asda, Findus and ABP Food Group, costing the industry an estimated £850m due to recalls, lost sales and tumbling share prices

British Meat Producers Association CEO Nick Allen believes horsemeat crept into the meat supply chain because “people were taking people’s word at face value” and not always asking searching questions about where raw materials came from.

Assurance systems are now much more stringent, he says, with processors required to operate on an “open book scenario” so that retailers can see “the whole picture”. He says as a result relationships between buyers and their suppliers are “less adversarial than they were”.

A concerted shift towards shorter, more consolidated supply chains has also given retailers greater visibility over the end-to-end flow of product. Co-op, for example, says that for primary protein the maximum length of a supply chain has since been restricted to no more than two changes of ownership over the product, while for processed meats like bacon, sausages and burgers the maximum is three steps.

M&S, one of the retailers not implicated in the scandal, set up a DNA and integrity programme that meant it could trace every animal back to an individual farm. The programme was initiated by M&S’s then director of food technology Paul Willgoss, who left the business in 2022 to run his own consultancy. Willgoss, along with Greencore’s Helen Sisson (now at 2 Sisters), is credited with driving the establishment of the Food Industry Intelligence Network (FIIN) – a safe haven for industry data and insight on food fraud risks that was a key recommendation made by Elliott.

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Founding members including Tesco and ABP Food Group agreed the network would have a participative membership model. “In other words, you had to put data in and you had to pay your fee,” says Willgoss. “If you didn’t put your data in, you didn’t get a (intelligence) report, so there was no free ride for anyone.”

FIIN managed to overcome business concerns over sharing sensitive information with the regulator and brokered an intelligence sharing agreement first with Food Standards Scotland and then with the FSA to ensure that information and intelligence now flows both ways. “Our relationship with the food industry is massively better [now],” says Miles. “There was a huge issue at the time about data sharing.”

Another major hole in the UK’s food fraud defences pre-horsemeat was a lack of policing power. Elliott concluded that the police investigation, led by City of London Police, was undermined because “they hadn’t a clue about the food industry and how it operates” while the FSA “hadn’t a clue about how you actually conduct a criminal investigation”. His answer was to recommend the establishment of a National Food Crime Unit (NFCU) to be hosted within the agency.

People were “very nervous about that”, Elliott recalls, partly because it effectively meant the government was acknowledging that organised criminals – as opposed to a handful of opportunists – were active within food supply chains.

The NFCU has since grown into an 86-person unit that collects intelligence on food crime risks and investigates complex frauds; however an external review published in December concluded that the unit in its current form is hamstrung by not having access to specific policing powers (see boxout). Elliott says getting these powers would be “another major step forward for the unit”., while Miles says they would be “a really big deal for us”.

So there’s been progress. But in some areas we’ve gone backwards. One area in which the UK is arguably in a worse position than during the horsemeat scandal is over the resilience of its laboratory network. In his review, Elliott identified an urgent need to improve the capacity and capability of the labs that carry out tests to support local authority enforcement of food law. That simply hasn’t happened. Back in 2013 there were nine public analyst official laboratories in England, Wales and Northern Ireland. Today there are just five.

The system has long been undermined by a funding model that makes labs heavily reliant on revenue generated from carrying out local authority testing. Swingeing cuts to council budgets have meant the number of non-microbiological samples taken by local authorities has fallen by 79.1% since 2016. Miles says the drop in sampling “is a concern”, though she suggests that better data sharing on risks between the regulator and industry “allows us to target our sampling better”, while a new FSA plan for targeted intervention to support public labs will help with capacity and capability. Elliott is more bearish: “Our public analyst system is still very much in jeopardy,” he says. “It’s holding on for now, but I think it’s got quite a bleak future.”

Where Elliott is more positive is over the step change in industry auditing. His review called for private audits to be more fraud-aware and he now feels “audits have changed dramatically and for the better”, supported by the main standards bodies. BRCGS, for example, has re-enforced the food fraud and food defence requirements within its main standards and also moved swiftly after horsemeat to develop a global standard for agents and brokers – identified by Elliott as a vulnerable link in the meat supply chain – which was updated in 2021.

There has also been a pronounced shift towards unannounced rather than planned audits, as the  industry norm. Experts say this means businesses being audited have had to adopt an ‘always on’ mentality rather than ensure their house is in order on a specific date. “You are constantly checked or challenged on the area of food fraud, so it’s now routine,” says Alec Kyriakides, who worked as Sainsbury’s head of quality, safety & supplier performance for 28 years until 2020 and is now a food safety consultant.

Government leadership and crisis management on issues of food authenticity is also much improved.Miles explains that the FSA now has a non-routine incident management plan and is “much better plugged in and aligned with the rest of government”. Defra, which leads on food authenticity policy, has an active food authenticity research programme that,  among other things, has developed new approaches to test for meat speciation. It also supported the proposal in the Elliott Review to establish a Food Authenticity Network and testing centres of excellence.

The question that remains is whether all of this adds up to a watertight food system able to repel the threat of fraudsters. Elliott is unconvinced. In particular, he feels the reduction in local authority enforcement capability “is the single biggest risk we have”, since in his view, most fraudulent products that enter the food system will enter via more complex, opaque wholesale channels that often supply independent retail and foodservice outlets rather than via the supply chains of the big supermarket, manufacturer and foodservice brands. Miles reveals that in 2012/13 there were 560 Trading Standards officers in England, Wales and Northern Ireland – now that number is just 351. “I think Trading Standards is a neglected and underfunded function in local authorities,” she says.

12. Horse meat

How much of a hindrance is Brexit?

Environmental health practitioners have also seen their numbers decline (while some have been reallocated to port health authorities in preparation for post-Brexit border checks). “When we start losing environmental health practitioners and Trading Standards officers one of the things that happens is criminals clap their hands [because] the opportunities to bypass the regulator become larger,” says Julie Barratt, president of the Chartered Institute of Environmental Health.

Since Brexit the UK has also lost access to EU-wide rapid alert and intelligence systems like RASSF and the Food Fraud Network. “We did rely on it enormously before Brexit,” says Miles of RASFF, though she claims the FSA has worked to offset the risk by joining the International Food Safety Authorities Network and by developing its own surveillance dashboards.

Nevertheless, there are experts who are clear the UK is now a specific target for fraudsters. “The two big risks to Brexit are that we are now cut off from that information and intelligence channel and that Europe does not care about what comes into the UK,” says Elliott.

To illustrate his point, an operation in October by officials from Dover Port Health Authority found a total of 2.4 tonnes of illegal pork contained within 21 of 22 lorries entering the UK from Romania, Moldova, Ukraine and Poland over a 24-hour period.

Routine physical inspections of high-risk imports like meat have consistently been delayed by the UK government since the end of the Brexit transition period. Miles says NFCU intelligence is not seeing fraudsters take advantage of limited checks at the border in a substantial or systematic way, “but of course there’s a risk that the longer we don’t have those controls the more inviting it is to exploit that”.

Others believe Brexit in isolation is less of a risk. “It’s a limited consideration compared to the fact that if food is expensive then there are opportunities for fraudsters,” says Shane Brennan, CEO of the Cold Chain Federation. “Because let’s be clear, we were in the single market when the horsemeat scandal happened.”

Instead Elliott thinks the double-digit levels of commodity price inflation are a more likely cause: a “paradise for fraudsters” as he puts it, who can artificially inflate the value of foods via crimes like dilution, adulteration and misrepresentation. Herbs and spices are near the top of his current risk list while rice is also “very high on our radar screen” because of crop failures including the devastating floods in Pakistan.

“Just because you’re big doesn’t mean you’re OK”

Shane Brennan

CEO of the Cold Chain Federation

The war in Ukraine is also creating risks around certain commodities including seafood – the most adulterated commodity over the past 10 years along with dairy, according to the Food Authenticity Network. Russia, which has been subjected to severe western sanctions, owns a huge share – around 40% – of the world’s white fish quota. “The impact in terms of incentive or opportunity for species and origin substitution driven by the change in the global white fish market is massive,” says Fair Seas founder and former Young’s Seafood executive Mike Mitchell.

There seems little doubt that fraud awareness among the big supermarkets and manufacturers is more sophisticated than it was a decade ago. “I don’t think there was very much else that would have created such a seismic shift in assurance,” says Kyriakides of the horsemeat scandal. But for smaller businesses who lack the equivalent level of resource, Willgoss believes it is ”very tricky” to do extensive due diligence. “A lot of people don’t know the right questions to ask because they haven’t got a food technologist on their side,” he says.

And even for the sector giants there is no room for complacency. “Motivated forces can infiltrate the system, so it requires strong levels of control in all parts of the supply chain,” says Brennan. “Just because you’re big doesn’t mean you’re OK.”

Fortress Britain: three key fraud-fighting institutions

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Food Industry Intelligence Network

FIIN was founded in 2015 in response to an Elliott Review recommendation to create a safe haven to collect, collate, analyse and disseminate intelligence on food integrity.

Tesco, Asda and ABP Food Group were among the founding members. It now comprises 60 organisations worth around £150bn in the UK.

Members submit data for ingredient testing and finished product testing each quarter. The data is then anonymised and consolidated by an independent third party and a report shared with members.

Food Authenticity Network


FAN was established in 2015 to standardise testing approaches and raise awareness of the most up-to-date food authenticity testing information.

These ‘centres of expertise’ were established following the Elliott Review to give “greater visibility of who the UK experts are”, according to Selvarani Elahi, executive director of FAN. It means governments can respond to an emergency situation like the horsemeat scandal “in a coherent manner rather than going to 10 different labs and getting 10 different opinions”, she says.


National Food Crime Unit

The NFCU is described by Chris Elliott as his most controversial recommendation. It was established in 2015 to sit within the FSA as a criminal intelligence unit. In May 2018, it received funding to expand its investigative capabilities including the ability to present evidence to the Crown Prosecution Service.

Recently the NFCU successfully prosecuted an individual for selling illegal weight loss supplement DNP and has also been investigating an illicit abattoir.

Last year, the NFCU received royal assent to access wider investigative powers.