Food Safety

Dossier – Physical contamination and food safety: unmasking global risks

May 8, 2025

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Safeguarding against physical contamination is a cornerstone of food safety, impacting everything from individual consumer health to the complexities of international trade.

This dossier offers a focused analysis that moves beyond a general overview. While acknowledging the foundation provided by international standards (Codex Alimentarius, ISO) and the convergence seen in global regulatory frameworks, it critically examines the reality on the ground, specifically addressing the significant ‘iceberg’ of unreported physical contamination incidents that occur but do not enter public recall databases due to how regulatory actions are handled.

By providing a comparative look at regulatory and control systems across key global regions, the text connects these approaches to the prevailing data gaps. It further explores the application of established food safety management standards and investigates the potential of innovative technologies and research as essential tools for improving the detection and prevention of physical hazards across the food supply chain.

Table of Contents

Physical contamination, definition and implications for food safety

Physical contamination in food safety refers to the presence of foreign materials, often visible, not intended for human consumption. The most common foreign bodies in food products are:

glass fragments, metal pieces, plastic shards, as well as
natural materials such as stones, wood splinters, insects and animal parts, or
human nails and hair.

The causes of physical food contamination can be traced to:

accidental factors, linked to contamination of raw materials, breakdowns in equipment, presence of pests, human errors (including poor hygiene practices and lack of controls);
deliberate adulterations, with intent to commit fraud or cause harm (to operators’ reputation and/or public health).

Physical contamination of food products is itself a source of various hazards and requires a concrete, case-by-case analysis of the risks of:

causing direct damage to consumers, ranging from minor injuries to serious outcomes including choking or internal damage;
serving as vectors for biological or chemical contamination, potentially hosting harmful bacteria and other substances.

Beyond health risks, physical contamination incidents can trigger significant economic consequences for food chain operators, including costly product recalls, brand reputation damage, and potential legal liabilities.

The unreported contamination iceberg

It is important to note that official recall registers and notification systems capture only a small portion of the physical contamination incidents that occur across all agri-food supply chains. There exists a substantial ‘iceberg‘ of unreported contaminations, particularly those involving pests (such as insects and rodents) that are discovered during routine inspections of raw material storage facilities, production plants, restaurants and cafeterias.

These contamination incidents, identified by control authorities during regular inspections, rarely lead to formal recall and withdrawal orders unless physical contamination of food products is verified. Consequently, such incidents do not appear in central recall registers but are typically addressed through enforcement actions against the facilities involved, including warning letters, fines, temporary closures for remediation, or license suspensions.

This situation creates a significant data gap in understanding the true prevalence and nature of physical contamination risks throughout the food supply chain. Research by Manning and Soon (2013) suggests that for every documented food safety incident in official registers, there may be numerous undocumented cases addressed through regulatory interventions that do not become public knowledge. This underreporting is particularly pronounced in countries with less developed regulations on transparency regarding food safety enforcement actions.

Regulatory frameworks

International Standards: Codex Alimentarius

The Codex Alimentarius serves as the definitive international reference for food standards and guidelines. Developed by the Codex Alimentarius Commission (established by FAO and WHO), it aims to protect consumer health and ensure fair practices in international food trade.

Within this framework, a hazard is defined as any biological, chemical, or physical agent in food with the potential to cause adverse health effects. The Codex emphasizes implementing the Hazard Analysis and Critical Control Points (HACCP) system as a fundamental tool for ensuring food safety, including controlling physical hazards. The HACCP system comprises seven principles:

Conduct a hazard analysis;
Determine Critical Control Points (CCPs);
Establish critical limits;
Implement monitoring procedures;
Establish corrective actions;
Implement verification procedures;
Establish comprehensive documentation procedures.

The Codex Commission’s “General Principles of Food Hygiene” (CXC 1-1969) outline essential hygienic practices throughout the food chain, including environmental control, hygienic production practices, proper handling, storage and transport, thorough cleaning and maintenance, and robust personnel hygiene practices.

While the “General Standard for Contaminants and Toxins in Food and Feed” (CXS 193-1995) primarily addresses chemical contaminants, its definition of contaminant as “any substance not intentionally added to food” encompasses physical contaminants. The general principles of preventing contamination at the source and applying appropriate control measures apply equally to managing physical hazards.

European Union

The EU’s General Food Law – Regulation (EC) No. 178/2002 provides the foundation for addressing food safety hazards, defining a “food hazard” as any biological, chemical or physical agent with potential adverse health effects:

Article 14 prohibits placing unsafe food on the market, considering food unsafe if harmful to health or unfit for consumption due to contamination “by foreign matter or otherwise“;
the EU’s Rapid Alert System for Food and Feed (RASFF) includes “foreign bodies” as a specific hazard category, with annual reports providing valuable data on types and frequency.

Council Regulation 315/93/EEC and Commission Regulation (EU) 2023/915 specifically prohibit marketing foods containing contaminants at levels unacceptable from a public health perspective and require maintaining contaminant levels “at the lowest level reasonably achievable” (ALARA) through good working practices.

The EU broadly defines a “contaminant” as any substance not intentionally added to food, present as a result of production, farming, animal husbandry, veterinary medicine, manufacture, processing, preparation, treatment, packing, transport or holding. This definition encompasses physical contaminants as “foreign matter“.

United States

In the United States, food safety is overseen by the Food and Drug Administration (FDA) and the United States Department of Agriculture (USDA). Regarding physical contamination:

the FDA’s Compliance Policy Guide (CPG) Sec. 555.425 addresses food adulteration with hard or sharp foreign objects, establishing size thresholds for regulatory action. Generally, hard or sharp objects between 7mm and 25mm in length are considered potentially harmful, particularly in ready-to-eat foods or those requiring minimal preparation;
under the Food Safety Modernization Act (FSMA), the FDA has implemented the Hazard Analysis and Risk-Based Preventive Controls (HARPC) rule, which requires food facilities to develop written food safety plans including hazard analysis and establishment of preventive controls;
the USDA’s Food Safety and Inspection Service (FSIS) considers meat, poultry, and processed egg products containing foreign materials as adulterated regardless of size. The FSIS emphasizes preventing contamination throughout the production chain;
both agencies have established recall procedures for contaminated products, with recalls classified based on the level of public health risk. Class I recalls indicate a reasonable probability of serious adverse health consequences or death.

Brazil

In Brazil, the regulatory landscape for food safety is primarily defined by the National Health Regulatory Agency (ANVISA) and the Ministry of Agriculture, Livestock and Food Supply (MAPA). ANVISA has primary responsibility for overseeing processed food products, while MAPA focuses on production and processing of animal products, fresh fruits and vegetables, and grains.

ANVISA serves as Brazil’s primary regulatory body for ensuring food safety, functioning similarly to the FDA in the United States. It monitors food production, distribution, and labeling processes to prevent foodborne illness and ensure compliance with established standards. To establish and enforce sanitary requirements for food production, ANVISA publishes Collegiate Board Resolutions (RDC) and Normative Instructions (IN) that set maximum allowed levels for various contaminants.

MAPA is responsible for enforcing regulations throughout the lifecycle of agricultural products, from production and commercialization to import and export. These regulations include specific measures designed to prevent the introduction of physical hazards into food. To enhance food safety, MAPA has implemented programs such as the Safe Food Program (Programa Alimentos Seguros – PAS) and supports the HACCP system to identify and control biological, chemical, and physical hazards throughout the food production process.

Studies on consumer complaints in Brazil have identified several types of physical hazards commonly found in food products. In meat products, these include bones, plastic fragments, insects, and metal pieces. In dairy products, the most frequently reported physical hazards are general foreign objects, followed by detection of insects and hair. These findings highlight the need for vigilance and effective control measures across different food sectors in Brazil.

China

China’s Food Safety Law, promulgated in 2009 and revised in 2015 and 2021, aims to safeguard public health by regulating all aspects of the food supply chain. The law establishes a comprehensive risk assessment system that includes assessment of biological, chemical, and physical hazards. Food safety standards in China are mandatory and include limits for harmful substances.

The Food Hygiene Law (amended in 1995) explicitly prohibits the sale of food containing foreign matter or exhibiting abnormalities in sensory properties. It requires that food establishments maintain hygienic standards and adopt measures to prevent contamination.

China has developed National Food Safety Standards (GB standards), including GB 2762-2017 for maximum levels of contaminants. While specific standards for physical contaminants may not be as detailed as those for chemical hazards, the general prohibitions against foreign matter provide a regulatory basis for addressing these issues.

China has implemented a food recall system that requires manufacturers and distributors to establish recall plans and report safety incidents. Responsibility for overseeing food safety is shared among multiple government departments, including the National Health Commission and the State Administration for Market Regulation.

Japan

Japan’s Food Sanitation Law aims to prevent health hazards arising from food consumption by regulating food, additives, equipment, containers, and packaging. The law prohibits the sale of food that is rotten, decomposed, contains toxic substances, is contaminated by pathogens, or may harm human health due to uncleanliness, foreign substance mixing, or other causes.

A 2018 revision introduced mandatory food hygiene control based on the HACCP system for all food business operators. The law requires reporting of food recall information when a company initiates a voluntary recall due to safety or allergen-related violations. The Ministry of Health, Labour and Welfare (MHLW) establishes specifications and standards for various food categories to ensure safety and quality.

Japan has implemented a Positive List System for food contact materials (e.g., utensils, containers, and packaging), allowing only substances whose safety has been assured.

United Arab Emirates (UAE)

The United Arab Emirates has established a comprehensive legal framework through Federal Law No. 10/2015 on Food Safety. This law prohibits trading harmful, adulterated, deceptive, deteriorated, or inedible food. While it does not explicitly list physical contaminants as a separate category, the prohibition of adulterated food implicitly includes foreign objects.

The UAE has implemented several systems to enhance food safety, including the National Food Accreditation and Registration System and the National Rapid Alert System for Food. Local municipalities play crucial roles in overseeing food safety requirements and conducting regular inspections, often enforcing compliance with HACCP principles and focusing on hygienic design to minimize contamination risks.

The UAE has established procedures for recalling unsafe food products and participates in the Gulf Rapid Alert System for Food (GRASF), facilitating immediate exchange of information on food products that threaten health among GCC countries.

India

The regulatory framework for food safety in India is primarily governed by the Food Safety and Standards Act of 2006, which established the Food Safety and Standards Authority of India (FSSAI) as the apex body responsible for setting scientific standards for food safety. The Act defines ‘contaminant‘ as any substance present in food due to production, processing, or environmental contamination, although interestingly excluding insect fragments, rodent hairs, and other foreign matter from this definition.

The FSSAI conducts regular inspections of food businesses to ensure compliance with hygiene and safety protocols designed to prevent the introduction of foreign objects into food products. It is also responsible for managing food recalls in situations where unsafe food products, including those contaminated with physical hazards, enter the market, as outlined in the Food Safety and Standards (Food Recall Procedure) Regulation, 2017.

Food Safety Management Standards

ISO 22000:2018

ISO 22000:2018 specifies the requirements for a food safety management system (FSMS), providing a framework for organizations throughout the food supply chain to implement systems that ensure the safety of food products. Built on HACCP principles, it incorporates prerequisite programs (PRP) for a comprehensive approach to food safety management.

A fundamental requirement is that organizations must identify and assess all potential food safety hazards in their operations. This hazard analysis forms the basis for establishing control measures essential for preventing or reducing hazards to acceptable levels, including Critical Control Points (CCP) and Operational Prerequisite Programs (OPRP).

PRPs include basic conditions necessary for maintaining a hygienic environment throughout the food chain, minimizing the likelihood of contamination. Specific PRPs relevant for controlling physical hazards include:

design and maintenance of facilities and equipment;
effective cleaning and sanitization protocols;
pest control measures;
personal hygiene practices by food handlers.

ISO 22000:2018 recognizes the importance of detection equipment for physical hazards, including:

magnets for metal fragments;
filters and sieves for foreign materials;
metal detectors for metallic contaminants;
X-ray equipment for detecting glass, stone, and dense plastics.

The standard emphasizes verification activities to confirm that the implemented PRPs and hazard control plans effectively control the identified hazards.

FSSC 22000

FSSC 22000 is a globally recognized certification scheme for Food Safety Management Systems accepted by the Global Food Safety Initiative (GFSI). Based on ISO 22000 requirements, it includes additional requirements that enhance food safety management practices and sector-specific PRPs tailored to different parts of the food supply chain.

Beyond ISO 22000 requirements, FSSC 22000 emphasizes:

food defense to protect against intentional contamination;
food fraud mitigation to ensure authenticity and integrity;
robust allergen management protocols.

A key additional requirement is equipment management to ensure hygienic design and prevent physical contamination. Organizations must have documented purchasing specifications that address hygienic design principles, legal and customer requirements, and the intended use of equipment. A risk-based change management process is required for new equipment or modifications to existing equipment.

FSSC 22000, while focusing primarily on microbiological hazards, can provide insights into the effectiveness of cleaning and sanitization, essential for controlling physical contaminants. The standard emphasizes quality control measures, requiring rigorous QC procedures to ensure product quality and safety. Guidance documents assist organizations in implementing specific requirements, providing practical information and best practices.

Reports and data on physical contamination

European Union RASFF notifications

Examination of recent European Union Rapid Alert System reports for Food, Feed and food-contact materials (RASFF) for the period 2019-2023 reveals important trends in physical contamination notifications. Within this system, “foreign bodies” consistently appear as a recognized hazard category.

The most frequently reported physical contaminants include metal fragments, glass and plastic, originating from various sources during production and processing, such as equipment malfunctions, packaging materials, or accidental introduction during handling. Some product categories are more frequently associated with physical contamination notifications, including fruits and vegetables, nuts and nut products, and confectionery and bakery products.

The geographical distribution of RASFF notifications provides insights into the origins of contaminated products. While notifications may originate within the EU, a significant number involve products imported from third countries. Specific countries may experience higher rates of notifications for certain types of contaminants, potentially reflecting differences in agricultural practices, processing technologies, or quality control measures.

During the analysis period, physical contamination notifications have shown variability. While there may not be consistent trends in overall notification numbers, specific types of contaminants or affected product categories may show fluctuations from year to year, influenced by regulatory changes, advances in detection technology, or specific contamination incidents leading to increased vigilance.

EU member states take various actions in response to RASFF alerts, including rejection of contaminated shipments at border control points, withdrawal of affected products from the market, and issuance of public warnings. The specific measures depend on the severity of the risk and the extent of product distribution within the EU.

United States: FDA and USDA recall data

Analysis of recall data from the United States Food and Drug Administration (FDA) reveals foreign object contamination as a significant reason for food recalls. The most commonly cited foreign objects include glass fragments, metal pieces, and plastic fragments, found in various food categories including bakery products, beverages, processed foods, and fresh produce.

The Food Safety and Inspection Service (FSIS) of the USDA reports recalls related to foreign material contamination in meat, poultry, and egg products, including hard plastic, metal fragments, and unexpected bone fragments. Both agencies classify recalls based on the potential risk to public health, with Class I recalls indicating the highest risk. Recalls for foreign material contamination occur across all risk classifications, highlighting the potential for both severe and less severe health consequences.

While comprehensive annual reports specifically focused on physical contamination may not be readily available as standalone documents, both agencies maintain recall databases that provide details on recalled products, reasons for recalls, distribution areas, and risk classifications, offering valuable insights into the ongoing challenges posed by physical contaminants.

Brazil: consumer complaints and recall events

In recent years, Brazil has recorded an increase in the number of food recalls. This increase is attributed to several factors, including improved communication among the various regulatory agencies involved in food safety, enhanced surveillance of both domestic and international food markets by the responsible authorities, and a greater level of commitment from food production establishments to ensure the safety of their products.

Consumer feedback reported on websites in Brazil indicates the presence of physical hazards in a range of food products. These contaminants include foreign objects that are not part of the food itself, as well as insects, hair, plastics, and metal fragments, with such complaints noted in categories like dairy products.

A specific study investigating consumer complaints related to meat products in Brazil identified several main types of physical hazards, including the presence of bones, plastic fragments, insects, and metal pieces. Another study focused on consumer complaints regarding dairy products found that the most frequently reported physical hazard was the presence of general foreign objects, followed by detection of insects and hair.

China: reports on food safety incidents

Reports on food safety incidents in China reveal various challenges, including contamination. While many high-profile incidents have involved chemical contaminants or deliberate adulteration, physical contamination remains a concern. Recalls have been initiated because of foreign objects such as adulterated plastic tapioca pearls with polymers or rodent remains in bakery products.

China’s regulatory framework, including the Food Safety Law and the Food Hygiene Law, provides a legal basis for addressing physical contamination by prohibiting the sale of food containing foreign matter. The established food recall system and the multiple government agencies overseeing food safety demonstrate a structure for handling contamination incidents. While detailed statistical reports specifically on physical contamination might not be as prevalent as those on chemical or biological hazards, available information suggests that physical contaminants are a recognized issue leading to recalls and regulatory attention.

Japan: food recall data

Analysis of Japanese food recall information indicates physical contamination as a recognized cause for product recalls. Recalls have been reported due to foreign materials such as glass fragments, metal pieces, and animal remains in various food products, spanning different categories including bakery products, processed foods, and beverages.

Trends suggest that recalls due to contamination, including physical contamination, are a recurring issue. The mandatory reporting system for food recalls established in 2021 as part of revisions to the Food Sanitation Law has likely improved transparency and availability of information regarding food safety incidents, including those involving physical contaminants. This system allows for tracking and analyzing recall data, providing insights into the types of hazards encountered and the effectiveness of preventive measures.

United Arab Emirates: recall information

Publicly available information regarding food recalls in the UAE indicates that recalls are initiated for various reasons, including contamination issues. While specific data on recalls related to physical contamination might be limited in readily accessible reports, news articles and official announcements provide some insights, including recalls for products due to potential contamination with unspecified contaminants.

Regulatory documents and journalistic accounts highlight the UAE’s commitment to ensuring food safety through stringent regulations and regular inspections. The focus on HACCP compliance and hygienic design in food establishments underscores the importance of preventing all types of contamination, including physical hazards. The National Rapid Alert System for Food suggests that the UAE is equipped to respond to and manage food safety incidents, including those involving physical contaminants.

India: recall procedures and FSSAI actions

To manage incidents where unsafe food products enter the market, including food contaminated with physical hazards, the FSSAI has established the Food Safety and Standards (Food Recall Procedure) Regulation, 2017. This regulatory framework provides a structured mechanism for recalling food products deemed unsafe. However, the effectiveness of this system depends on timely detection and reporting of contamination incidents.

In India, recalls are more commonly initiated and enforced directly by the FSSAI rather than voluntarily by food businesses, which might suggest a less proactive approach from food businesses in India when it comes to voluntarily recalling products for physical contamination concerns. News in India frequently highlights the presence of various physical contaminants in food consumed in the country, including cockroaches, hair, nails, and metal pieces in meals ordered from restaurants and through online food delivery services.

Leveraging technology to combat physical contamination

Advanced detection technologies

Recent technological advances offer promising solutions for detecting and preventing physical contamination in food products:

microwave detection combined with machine learning techniques for detecting various types of physical contaminants (Alfian et al., 2022);
AI-enhanced electrical impedance tomography for improved detection capabilities (Alsaid et al., 2024)
advanced X-ray systems capable of detecting smaller and less dense foreign objects (Schmidt et al., 2023)
automated visual inspection systems using computer vision and AI to identify visual anomalies (Gao & Sun, 2023)
hyperspectral imaging technology that can detect both surface and subsurface contaminants (Shehzad et al., 2025) These technologies complement traditional detection methods such as metal detectors, magnets, and manual inspection (Onyeaka et al., 2023).

Process-based strategies for contamination control

Beyond detection technologies, process-based strategies have proven effective in reducing physical contamination risks:

supplier qualification programs with stringent requirements for raw material quality (Foundation FSSC, 2023);
implementation of foreign material control programs (International Organization for Standardization, 2018)
equipment design and maintenance protocols that minimize the risk of parts becoming detached during production (Codex Alimentarius Commission, 2020);
environmental monitoring programs that track and address potential pest activity (Manning & Soon, 2013);
statistical process control methodologies applied to physical contaminant detection (Jasper et al., 2022).

Emerging research directions

Cutting-edge research is exploring innovative approaches to physical contamination control:

predictive modeling using historical contamination data to forecast high-risk periods or conditions (Wang et al., 2022);
integrated food safety management systems that simultaneously address biological, chemical, and physical hazards (Bouzembrak et al., 2022);
consumer-facing authentication technologies that allow end users to verify product integrity before consumption (Kumar et al., 2024).

Conclusion: the continuing challenge of physical food contamination

This analysis highlights the persistent and multifaceted challenge that physical food contamination poses to the food industry and public health. Despite well-established regulatory frameworks and robust food safety management standards, contamination incidents continue globally.

The significant “iceberg” of unreported contamination incidents discovered during routine inspections but not resulting in formal recalls represents a crucial data gap for understanding the true extent of the problem. Increased transparency in enforcement actions and improved information sharing among regulatory bodies could provide valuable insights for prevention strategies.

The continuing challenge requires ongoing vigilance and proactive measures from all food industry stakeholders. This includes consistent application of robust food safety management systems, adherence to regulations, and implementation of effective detection and prevention technologies.

Continued monitoring, data analysis, and lesson sharing from contamination incidents are essential for improving food safety practices and protecting public health. As food supply chains become increasingly complex, international collaboration involving industry, regulatory bodies, and consumers is crucial for mitigating risks associated with physical contaminants and ensuring a safe food supply.

Dario Dongo

References

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Dario Dongo

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.