Food fraud could be flourishing in Britain’s forgotten supply chains

There are certain moments that fundamentally challenge our belief in the integrity of our food system. The UK horsemeat scandal of 2013 was undoubtedly one of them. It exposed deep vulnerabilities within increasingly complex food supply chains and demonstrated that food fraud should not be viewed as mere minor acts of deception. It was well-organised, economically motivated criminality penetrating legitimate food businesses. The independent review I led (The Elliott Review) following the scandal concluded that food crime should be treated with the same seriousness as other forms of organised crime due to its potential to undermine consumer confidence, damage legitimate businesses and, in some circumstances, threaten public health.

More than a decade later, significant progress has undoubtedly been made – and this must be recognised. The establishment of the National Food Crime Unit (NFCU) and the Food Industry Intelligence Network (fiin), working together to increase intelligence sharing, have enabled far wider adoption of food fraud vulnerability assessments, which has significantly strengthened the UK’s ability to combat food crime. Yet the recent conviction of Kismet Kebabs Ltd demonstrates that despite these advances, organised food fraud remains very much alive, well and kicking the public.

The investigation, which was skilfully led by Swansea Council Trading Standards with support from the NFCU, found that meat products marketed as containing high levels of lamb instead contained substantial quantities of lamb fat, skin, goat meat, mutton and mechanically recovered meat: a thoroughly vile recipe concocted by rogue actors. Purchasing records examined during the investigation reportedly showed very little genuine lamb entering the production facility, despite products leaving the site as premium lamb kebabs. The company pleaded guilty to fraud by false representation and was fined £500,000 together with prosecution costs of approximately £259,000. The BBC’s coverage of the case, together with Swansea Council’s own statement following the prosecution, provides a detailed account of how the investigation unfolded and the evidence presented before the court.

The Kismet case also reinforces something that those of us working in the food fraud arena have understood for many years: processed meat products remain among the commodities most vulnerable to fraud.

Once meat is minced, blended, seasoned and formed into burgers, sausages or kebabs, visual identification of its components becomes almost impossible.”

For many, especially those not partial to the occasional kebab, this may appear to be just another case of a dodgy food company getting a hefty fine. In reality, however, I believe it holds far greater significance. Fraud on this scale requires planning: purchasing strategies need to change, recipes have to be reformulated and often documentation must be manipulated. Every stage of this process – which appeared to have been happening for years – required conscious decisions designed to generate financial gain through deception.

The scale of this criminal activity must be properly understood. Potentially millions of consumers may have unknowingly purchased meat products that differed substantially from those described. Restaurants and takeaway businesses believed they were buying one product while unknowingly selling another. Honest manufacturers, which represent the vast majority, producing genuine products found themselves competing against businesses whose production costs had been artificially reduced through systematic cheating. This distortion of fair competition serves to undermine every legitimate business operating within the same marketplace.

Another aspect of the case that I believe deserves far greater attention is the sentence handed down itself. The criminal case brought by Swansea Council was based on ‘false representation’, a statutory offence under Section 2 of the Fraud Act 2006. Successful convictions can carry a maximum custodial sentence of ten years for individuals. The Sentencing Council’s Corporate Offenders Guideline for fraud, bribery and money laundering offences makes it clear that companies convicted of serious fraud face unlimited financial penalties, with fines intended to remove any financial gain and to have a significant economic impact on the offending organisation. The guideline also makes clear that, in sufficiently serious cases, putting a company out of business may be regarded as an acceptable consequence, if that is necessary to achieve justice.

Against that background, the £500,000 fine imposed on Kismet Kebabs deserves further scrutiny. Publicly available financial information indicates that the company had an annual turnover of approximately £20 million in 2025. Even after prosecution costs, the overall financial impact amounts to around 4 percent of the company’s 2025 turnover. It’s true that this is a hefty financial penalty, but it is considerably lower than the maximum penalties available under the sentencing guidelines. Indeed, reports from the court indicate that a strict application of the corporate sentencing framework could have resulted in a significantly larger fine, potentially several million pounds. However, it seems the magistrate considered the wider impact on employees and the continued viability of the business.

This to me raises an uncomfortable question: If organised food fraud affecting potentially millions of consumers and making the criminals millions of pounds attracts penalties representing only a relatively modest proportion of annual turnover, do such sanctions really provide a robust enough deterrent? There are of course arguments on both sides but for me Kismet Kebabs got off rather too lightly. While it should serve as a warning to other bad actors, will they consider the scale of the penalty versus the vast profits they are reaping sufficiently manageable to warrant the risk worthwhile?

The Kismet case also reinforces something that those of us working in the food fraud arena have understood for many years: processed meat products remain among the commodities most vulnerable to fraud. Once meat is minced, blended, seasoned and formed into burgers, sausages or kebabs, visual identification of its components becomes almost impossible. This is precisely why fraudsters often choose to operate in this sector. The horsemeat scandal demonstrated that science can expose such forms of deception – and indeed since then analytical testing capabilities have advanced dramatically. It’s very reassuring that virtually every large food business operator in the UK undertakes rigorous testing and most of these share their results through the invaluable fiin network. Unfortunately, small food business operators have neither the budget or know-how to undertake such monitoring and thus become the main target for criminal enterprises. It is clear that SMEs need other forms of support.

In my 2014 report, one of my central recommendations was greater investment in intelligence-led enforcement and stronger support for those officers working on the front line of food regulation. Regrettably, the years that followed have seen precisely the opposite. The Chartered Trading Standards Institute has repeatedly warned that Trading Standards services have experienced some of the deepest reductions of any local authority regulatory function. Budgets have fallen by around 50 percent over the past decade, while staffing levels have declined by between 30 and 50 percent since 2008 (the period of economic crisis in the UK). The Institute has repeatedly warned that these reductions are leaving consumers increasingly exposed to rogue traders and organised criminality. The situation within environmental health is equally troubling. The Chartered Institute of Environmental Health estimates that local authorities in England now employ fewer than 60 percent full-time equivalent environmental health professionals across all disciplines compared with 2008. More than half of councils report vacancies remaining unfilled for six months or longer, while around 80 percent rely on agency staff because they cannot recruit suitably qualified environmental health officers. Even more worrying is the lack of new entrants into the profession. More than half of local authorities report having no environmental health apprentices or trainees, creating a serious risk that experienced inspectors retiring over the next decade will not be replaced.

What can also be concluded from the evidence is that routine sampling has reduced, inspection frequencies have declined, and experienced investigators have become increasingly difficult to recruit and retain.”

The Local Government Association (LGA) has painted a similarly concerning picture, estimating that around 13 percent of environmental health posts across England remain vacant, with food safety specialists among the hardest positions to fill. The LGA has warned that recruitment difficulties now represent one of the most significant challenges facing local authority regulatory services.

Though it is not accurate to claim the reductions in trading standards or environmental health staffing directly caused the Kismet Kebabs fraud, it is entirely reasonable to conclude that declining enforcement capacity greatly reduces the likelihood of routine detection, increasingly having to focus on intelligence-led interventions. What can also be concluded from the evidence is that routine sampling has reduced, inspection frequencies have declined, and experienced investigators have become increasingly difficult to recruit and retain. And believe me, organised criminals understand this every bit as well as those working within the regulatory system.

Viewed in this wider context, the successful prosecution of Kismet Kebabs is both encouraging and concerning. It demonstrates what highly skilled trading standards officers, environmental health professionals, public analysts and the NFCU can achieve when they work together. At the same time, it raises important questions. Knowing this investigation required such significant expertise and resources, how many similar frauds remain undetected because those same resources are no longer available elsewhere? And what happens next time if it’s large numbers of consumers exposed to unsafe food?