EVEN as the Food and Drug Administration, Punjab, has imposed a statewide ban for a year on analogue paneer, also known as synthetic or non-dairy paneer, the seizure of 22,000 litres of adulterated desi ghee by the state Health Department in Kotkapura has brought into focus an increasingly sophisticated form of food fraud. Expensive milk fat is replaced with the much cheaper vegetable fat, while attempting to preserve the appearance, texture and other characteristics associated with desi ghee.Analogue paneer is often made with vegetable oils and hydrogenated fats. It typically contains palm oil, starches, emulsifying salts and additives — raising health concerns. Unlike dairy paneer, which is rich in protein, calcium and essential amino acids, processed alternatives may carry higher levels of saturated and trans fats, along with excess sodium.Hotels, restaurants, dhabas, caterers and institutional kitchens have been directed to maintain records of their paneer sources.The fake desi ghee consignment, reportedly transported from Greater Noida to a manufacturing facility on Faridkot road, has led to an FIR naming Versatile Foods and Marketing Pvt Ltd, Greater Noida, and Narayan Agro Foods Ltd, Kotkapura.The economic incentiveGenuine ghee is concentrated milk fat that costs about Rs 600 per kg, whereas many vegetable oils and fats like palm oil cost just Rs 150 per kg. That price gap creates an opportunity for adulterators to substitute some or most of the costly milk fat with cheaper vegetable fat and then sell the resulting product as desi ghee, or incorporate it into a product marketed as ghee.At 22,000 litres, even a relatively small difference between the cost of genuine dairy fat and cheaper substitute fats can translate into substantial gains.How the imitation is engineeredMilk fat and vegetable fats have different physical and chemical characteristics. A sophisticated adulteration process attempts to make the resulting mixture behave more like genuine ghee.It is claimed that products containing mono and diglycerides, including acetylated monoglycerides and other commercial emulsifier grades, are used in blending vegetable fats with dairy fat. Such substances have legitimate food industry applications under specified conditions, including in products such as bakery foods.One product attracting attention is AMG 90, or acetylated monoglyceride, which is marked for polymer use applications but was allegedly being used for adulterating palm oil with desi ghee.Where the health risk liesThe more fundamental concern is that replacing milk fat changes the composition of a product sold to consumers as ghee. Vegetable fats can have very different fatty acid profiles from dairy fat. Excessive consumption of saturated fats can contribute to an unhealthy dietary pattern, while industrial trans fats are well established as a cardiovascular health risk.If non-food grade chemicals or processing materials enter the food chain, the potential risk becomes more serious because their safety has not necessarily been established for human consumption.Investigators will need to establish whether vegetable fat was substituted for milk fat. What type of fat was used, where it came from, whether emulsifiers or other processing agents were added, whether any unauthorised or non-food grade substances were involved, and where the material was ultimately intended to be sold.What the law saysThe Food Safety and Standards Act, 2006, provides for penalties for unsafe food, with punishment under Section 59 depending on the consequences of consumption. Where unsafe food causes no injury, imprisonment can extend to six months and the fine to Rs 1 lakh. Where it causes non-grievous injury, imprisonment can extend to one year and the fine to Rs 3 lakh. In cases involving grievous injury, imprisonment can extend to six years and the fine can extend to Rs 5 lakh.If unsafe food results in death, imprisonment is not less than seven years and may extend to life imprisonment, with a minimum fine of Rs 10 lakh. The BNS provisions cited in the Kotkapura FIR also address food adulteration and sale. Section 274 deals with adulterating food or drink intended for sale so as to make it noxious, while Section 275 deals with selling or offering for sale food or drink that is noxious or unfit for consumption.