Food Adulteration – Business Challenges and Legal Framework. Report from the Debate at WorldFood Poland 2025

The issue of food adulteration has been under scrutiny for years by both regulatory institutions and producers. During the WorldFood Poland 2025 exhibition, an expert debate was held on this topic, featuring Dorota Bocheńska from the Agricultural and Food Quality Inspection (IJHARS), Danuta Łukaszewicz from Lisner, and Piotr Popielarski from WKB Lawyers, moderated by Magdalena Zielińska-Kuć. The discussion addressed both the practical challenges faced by the industry and the current legislative changes aimed at clarifying the definition of adulteration and improving the effectiveness of law enforcement. What exactly was discussed?

Table of contents

🟢 Food adulteration – scale and the inspection’s perspective
🟢 Adulteration in the supply chain – the producer’s perspective
🟢 What exactly is adulteration? The problem with the definition
🟢 Administrative and criminal sanctions. A new stage of responsibility
🟢 Control of labelling and marketing – a new area of supervision
🟢 International cooperation and information exchange
🟢 Producers and allegations concerning their products – real risks
🟢 Summary
🟢 FAQ

Food adulteration – scale and the inspection’s perspective

As highlighted in the debate, the profit from food adulteration “is enormous,” which makes such practices attractive to dishonest entities. The situation is further worsened by external factors such as animal diseases, unfavourable weather conditions or fluctuations in raw material availability, which increase production costs and heighten the temptation for illegal actions.

The inspection, as emphasised, plays a special role in protecting consumers economically and “maintaining balance between enterprises”. The most frequently adulterated products are those with high commercial or premium value – the ones that “indicate quality”, such as olive oil, cocoa, alcohol or any products with a declared origin.

“It is most often not extra virgin olive oil. We also encounter oils that should never be used in the food industry,” the IJHARS representative pointed out.

Adulteration in the supply chain – the producer’s perspective

The representative of Lisner emphasized that the responsibility of producers goes far beyond their own production line. Adulteration can occur “at every stage of the supply chain”, which is why the following are so important:

• careful selection of suppliers,
• long-term cooperation based on trust,
• audits,
• regular assessment of raw material quality.

As she added: “Without assessing the quality of raw materials, it is impossible to produce good products. As large producers, we must be transparent and lead by example”.

One of the more interesting threads was the issue of labelling fish obtained from wild catches. Consumers often do not know that, for example, herring is always a wild fish, since there are no farms of this species. Nevertheless, Lisner stresses that indicating such information on the packaging may be problematic::

“We should not suggest that our herring is better than others, since all of them are obtained under natural conditions”.

What exactly is adulteration? The problem with the definition

Most of the debate focused on legal interpretation. Currently, EU regulations do not specify a single definition of food adulteration, and Member States are obliged to prosecute violations, especially those that are intentional and aimed at gaining benefits.

In Poland, a definition exists in the Food and Nutrition Safety Act, but – as the experts assessed – it focuses too strongly on safety and too weakly on the economic aspect of misleading the consumer.

IJHARS notes that the definition is ambiguous and requires clarification. Therefore, a legislative initiative has been submitted to the Ministry of Agriculture. In the draft amendment, “adulteration” is to be a broader concept, covering, among others:

• incorrect or misleading labelling,
• lack of information about ingredients or origin,
• interference with the product intended to conceal its true properties.

The problem, however, is that the draft does not always allow distinguishing an ordinary violation from adulteration of a fraudulent nature.

“There may be cases where it will be difficult to determine what constitutes adulteration and when it is a matter of improper commercial quality”.

Administrative and criminal sanctions. A new stage of responsibility

Currently, penalties for adulteration are administrative and can reach up to 10% of a company’s revenue – regardless of the industry. This creates a risk that the largest retail entities bear higher sanctions than the producers responsible for the actual violation.

The amendment additionally introduces criminal sanctions, which experts assessed as a step in the right direction:

“There was no provision that directly addressed the adulteration of an agri-food product. This is the right direction”.

However, the challenges may include:

• a complicated definition of adulteration,
• low specialization of prosecutors in food law,
• difficulty in determining who is responsible: the producer, distributor or retailer.

IJHARS notes that control authorities already approach this in a chain-based manner:

“First, we check whether the store had an influence on the irregularity. If not, we move further until we identify the actual culprit”.

Control of labelling and marketing – a new area of supervision

A large share of violations concerns labels – even a well-manufactured product may be considered adulterated if its labelling is misleading. Lisner indicated that it operates a dedicated department that verifies the compliance of label graphics and content with regulations.

A novelty in the regulations is to be the expansion of control to include advertising and marketing communications, including those on websites, in commercials or on social media. However, the IJHARS representative reassured:

“Please treat our inspections as a large dose of education. We encourage cooperation – then the inspections are pleasant”.

International cooperation and information exchange

Cross-border cooperation plays a major role in combating food fraud. For years, the European Commission has been developing rapid information-exchange networks between EU Member States, enabling action to be taken on irregularities detected in one country before the product reaches additional markets..

“We have information on what Polish entities sell in other EU countries and what the quality is. When problems arise, other states ask us to take action”.

Producers and allegations concerning their products – real risks

The representative of Lisner emphasised that it happens that entrepreneurs learn about proceedings concerning their product instantly, when… they can no longer react.

“Often the information reaches us only after 14 days, when the shop did not know what to do with it. And we could no longer defend ourselves”.

This shows how important communication is throughout the entire supply chain, as well as proper regulations regarding responsibility and document circulation.

Summary

The debate at WorldFood Poland made it clear that the problem of food adulteration remains one of the key challenges of the modern food industry. On the one hand, growing economic pressure and global disruptions in supply chains increase the risk of dishonest practices; on the other – rapid changes in legislation show that both lawmakers and control authorities strive to protect the interests of consumers and honest businesses more effectively. The most important conclusions from the debate are:

• Adulteration concerns primarily products with high added value – such as olive oil, cocoa, alcohol or food with a declared origin.
• The current definition of adulteration is imprecise, which hinders consistent rulings and increases the risk of disputes.
• The draft amendment significantly broadens the concept of adulteration while introducing criminal sanctions. This is a step towards strengthening market protection, although it may generate new interpretative challenges for prosecutors and courts.
• Producers cannot eliminate risk entirely, but they can – and should – exercise due diligence through audits, quality control and transparent operations.
• The inspection emphasizes its educational role, pointing out that the goal is not punishment but ensuring competitive balance and consumer safety.
• The new area of attention – marketing and advertising – requires even greater consistency between claims and the actual properties of products.

The shared message from all debate participants was clear: in the realities of an increasingly complex food market, transparency, responsibility and cooperation are essential. Only such an approach allows building consumer trust and at the same time protecting honest producers from the consequences of those who try to circumvent the law.

FAQ – Frequently Asked Questions