We have read in at least three recent publications (Australian Extra Virgin – Production Facts and Figures (www.australianextravirgin.com.au , The OliveGrower and Processor, Weekly Times Now) that Australians consume approximately 44,000 tonnes of extra virgin olive oil (EVOO) a year. This is not correct.
Australia’s consumption of olive oil is the sum of imports and local production, less the sum of exports of local production and re-exported imports.
According to the Australian Bureau of Statistics import data, the imports of olive oil for the financial year ending in June 2008 were as follows:
Virgin olive oil packaged (often referred to as extra virgin olive oil) 12,873 tonnes
Virgin olive oil in bulk (often referred to as extra virgin olive oil) 2,220 tonnes
Total virgin olive oil 15,093 tonnes
Olive oil, excluding virgin, packaged (referred to as refined olive oil) 14,931 tonnes
Olive oil, excluding virgin, bulk (referred to as refined olive oil) 1,867 tonnes
Total olive oil excluding virgin 16,798 tonnes
Note: These refined oils are usually described as ‘pure’ and ‘extra light’ on supermarket shelves.
Olive oil and their fractions including blends333 tonnes
(referred to as olive pomace oil and blends with other vegetable oils)
Total olive oil imported 32,224 tonnes
The approximate figure of 44,000 tonnes is the total import figure added to the estimated Australian production of 12,000 tonnes giving a total consumption figure of 44,224 tonnes.
If we assume that Australian Olive Association assertion that ‘Australian olive oils are almost entirely extra virgin olive oil’, is correct, we can take 90% of Australian production as EVOO giving Australian consumption of extra virgin olive oil of around 26,000 tonnes, less exports.
Exports of virgin olive oil (which includes re-exported imports) for the financial year ending in June 2008 were 2556 tonnes.
A reasonable estimate of Australian consumption of EVOO is therefore 23,500 tonnes a year, 20,500 tonnes less that that claimed on the Australian Extra Virgin Brand website.
The website also claims that about 35% of Australian extra virgin produced in Australia is exported. The virgin olive oil exports for last financial year (2007/2008) were 2556 tonnes – including imports that are re-exported which are not separately recorded.
Official Australian olive oil production reported by the International Olive Council for 2006/2007, which would be exported in 2007/2008, is 9,000 tonnes. This gives an export percentage closer to 28% (less when re-exports are taken into account).
HTML clipboardThe perceived cost of testing olive oil to full International Olive Council (IOC) Trade Standard is frequently quoted as the reason for not requiring this level of testing for Australian and New Zealand extra virgin olive oils.The Australian Extra Virgin Brand and Olives New Zealand Certification both accept testing regimes that do not include adulteration testing. In trying to analyse the reason for this cost perception, Olive Business has made some comparisons between testing laboratories in Australia recognised by the Australian Code of Practice, and an overseas laboratory. We have compared the costs of testing between the New South Wales Department of Primary Industry Olive Oil Testing Service (NSWDPI) and Modern Olive Laboratory in Victoria. For further comparison we have included the costs from Chemiservice laboratory in Bari, Italy. The NSWDPI laboratory and Chemiservices are recognised by the International Olive Oil Council, the former for chemical and organoleptic tests, and the latter for chemical tests. The table shows that there is considerable difference in the cost of individual tests and the packages for testing to IOC international trade standard. The prices have been taken from online pricelists or direct quotations. The different listing of the tests in the price lists has required some interpretation, so the overall prices should be regarded as reasonably accurate estimates.The pricing is for single samples. If multiple samples are submitted there are significant discounts which will reduce the cost of testing per sample.
Test
Testing Laboratory Cost/test single sample
1NSW DPI Olive Oil Testing Service
Modern Olives Laboratory
2Chemiservice
Bari, Italy*
$
$
$
Fatty acid composition and trans fatty acid content
116.95
99.00
51.64
Free acidity
58.70
27.50
10.00
Peroxide value
61.50
33.00
20.00
Absorbency in ultra violet
60.35
44.00
31.00
Sterol compositionErythrodiol + uvaol
338.60
572.00
104.00
Wax content
202.00
176.00
82.64
ECN-42 Triglycerides
111.75
150.00
104.00
Stigmastadiens
270.75
253.00
82.64
2-Glyceril Monopalmitate
111.75
(tri acyl glycerides)
100.00
(tri acyl glycerides)
82.64
Unsaponifiable matter
231.00
110.00
51.66
Organoleptic evaluation
95.65
49.50
61.98
Total cost of Individual tests
1659.00
1614.00
682.20
International trade package cost
1002.60
1606.00
682.20
Postage
4.40
4.40
50.35
TOTAL COST OF TESTING
1007.00
1610.40
732.55
Cost per litre 1000 litres
$1.00
$1.61
$0.73
Cost/500ml bottle
$0.50
$0.81
$0.37
Cost per litre10,000 litres
$0.10
$0.16
$0.07
Cost/500ml bottle
$0.05
$0.08
$0.04
Cost per litre100,000 litres
$0.01
$0.016
$0.007
Cost/500ml bottle
$0.005
$0.008
$0.003
Turn around (including delivery time to lab)
10 working days
7 working days
10 working days
1 International Olive Oil Council accredited for chemical and organoleptic tests
2 International Olive Oil Council accredited for chemical tests
* Converted to Australian $ at $0.50 to 1.00 Euro
Taking the package costs as the most cost effective, the lowest cost of testing for an enterprise that produces 1000 litres of one brand of olive oil a year is 37c per 500ml bottle at Chemiservices in Italy. This comes down to 4c for a production of 10,000 litres of a single brand and 1/3c for 100,000 litres.It may be reasonably argued that the impost of 37c on small producers producing 1000 litres will reduce profit margins, but this argument is more difficult to justify for the 4c or less per bottle for larger volumes.These costs will be further reduced by submitting multiple samples if producers cooperate in submitting samples for testing.Given the importance of assuring the quality of both Australian and New Zealand extra virgin olive oils to consumers, and to provide certified analysis in the case of disputes, it is difficult to understand why the custodians of quality standards do not simply adopt the IOC international trade standard as the basis of their quality branding.Comparison of testing results between laboratoriesTo get an idea on the accuracy of testing from the three laboratories compared above, Olive Business sent a sample of the same refined olive oil for sterol composition testing at the three laboratories at the same time. The results are given in the table below.The percentage variation in the testing is concerning, especially when a sterol may be close to the IOC standard limit. The variation could have one laboratory showing the oil inside the standard with another showing it does not meet the standard.This reinforces the importance of testing samples for monitoring at two different independent IOC accredited laboratories.
Sterol Composition of refined olive as a % of total sterols
The ‘Australian Extra Virgin’ Brand (the Brand) has recently been launched under the auspices of the Australian Olive Association (AOA). The brand is underpinned by ‘The Code of Practice for The Olive Industry’ (the Code).
The Brand is only available to members of the AOA or organisations approved by them. While being a signatory to the Code is voluntary, in AOA promotional material it is referred to as ‘a Code of Practice for the industry’, and therefore has ramifications for all olive oil producers and traders. Its success or failure will have an impact on the entire industry.
The launch included a media publicity campaign and a public attack on a number of imported brands of olive oil taken from supermarket shelves and tested for the AOA by the Australian Oils Research Institute.
The website of the Brand (1) states that ‘The Code of Practice (2) guarantees the authenticity and quality of certified products and distinguishes them from imported products’.
The certification requires that ‘the products must have undergone organoleptic and chemical testing and be Australian’.
On the face of it, it is a progressive step towards improving the quality of Australian Olive Oil in the market place and increasing consumer confidence in buying the local product.
But having been so public in its general attack on ‘low grade’ imported brands – some of which were named on the
ABC 7.30 Report on 8th October 2008 – the AOA can expect its Brand to come under intense scrutiny.
Is the Code robust enough to withstand this scrutiny or is it flawed to the extent that non-compliance will be revealed and the Brand compromised in the same way as the AOA compromised imported brands?
The Code describes a series of production and quality assurance procedures with which signatories must comply. One would assume that as Australia is a signatory to the Codex Alimentarius (Codex) (3) – the United Nations sponsored international Code covering food production and processing – the Codex standard for Olive Oil would be the starting point for compliance.
There is also a standard promulgated by the International Olive Council (IOC) to which Australia has observer status – and by implication subscribes to the IOC ‘Trade Standard Applying to Olive Oils and Olive-Pomace Oils’ (4).
International standards – Codex Alimentarius and IOC Trade Standard.
Standards for olive oil in both these documents require that the product undergoes sensory analysis by a recognised tasting panel and a number of chemical tests are carried out by a recognised laboratory. Recognition of tasting panels and chemical testing laboratories is granted by the IOC on an annual basis and a current list can be obtained from their website (5).
The laboratories recognised for chemical testing are divided into two categories: ‘public or private laboratories that issue test certificates at the request of third parties, and laboratories belonging to olive oil companies that analyse their own oils’.
Sensory (Organoleptic/Taste) Testing
From November 2007 to November 2008 of IOC recognised sensory panels did not list an Australian panel. One Australian panel was listed in the 2006/2007 listing but was subsequently delisted. It can therefore be argued that during the period when the first olive oils bearing the Brand appeared there was no capacity in Australia to officially certify that an olive oil meets international standard and that any certification must be supplied by one of the listed overseas panels.
In the new listing of recognised panels published by the IOC on 1 December 2008, the Australian Panel has regained its recognition for the next year.
The Australian Extra Virgin Code of Practice requires that the olive oil must ‘have been assessed organoleptically by a person or persons accredited by The Australian Olive Association Ltd or in accordance with processes determined by the Australian Olive Association Ltd……………….’
Information provided by the AOA states that for the Brand ‘The organoleptic testing to be done by a panel of five, with one person having AOA Level Two training and the other four having Level One (or equivalent)’.
It appears that to achieve Levels 1 and Levels 2 training the tasters must have completed Course 1 and Course 2 of training provided under the auspices of the AOA. Course 1 – Understanding Extra Virgin Olive Oil - is a 6 hour course and Course 2 – Principles and Practices of Olive Oil Blending – is a 3.5 hour course. There does not appear to be any testing of a participant’s tasting performance in either course (6).
Given this level of training it would be difficult to argue that the AOA recognised tasting panels have the authority to officially classify olive oils to international standard and thereby determine the diminished financial return from large quantities of olive oil which may be downgraded.
It is fundamental to international sensory testing that tasting of olive oil is conducted by a panel of at least 8 panellists to eliminate personal taste variations. The IOC accredited panels undertake a number of tests each year to ensure that their conclusions conform to international benchmarks. The IOC also requires that a minimum of 8 panellists conduct any tasting to classify olive oils.
Given the serious financial loss resulting from olive oils being classified as virgin or lampante, and not extra virgin, there should be no compromise in establishing this testing regime in Australia.
Any shortfall in capacity in Australia to undertake the numerous sensory tests required each year can be overcome by recognising compliance certificates issued by overseas IOC accredited sensory testing panels.
Any recognition of an individual or individuals by the AOA to undertake the sensory testing outside the IOC recognised panels brings into question the integrity of sensory assessment and therefore the Brand which relies on it.
According to media reports, some of the imported extra virgin olive oil brands named by the AOA as not meeting international standards were downgraded on sensory/taste tests. Unless the taste tests were carried out overseas by IOC recognised panels, these tests have no validity. The same can be said of the taste testing of the Australian brands which were vaunted as meeting all standards.
Chemical Testing
The purity criteria for olive oil listed by the IOC Trade Standard includes the following tests:
Fatty acid composition as determined by gas chromatography
Trans fatty acid content
Sterol and triterpene dialcohol composition
Desmethylsterol composition
Total sterol content
Erythrodiol and uvaol content
Wax content
Maximum difference between the actual and theoretical ECN42 triacylglycerol content
Stigmastadiene content
Content of 2-glyceryl monopalmitate
Unsaponifiable matter
These tests are used to determine any contamination/adulteration of extra virgin olive oil with refined olive oils or other vegetable oils.
There are also a series of quality tests which are indicators of the stability of the olive oil, and residues. These tests are:
Free acidity
Peroxide value
Absorbency in ultra-violet
Moisture and volatile matter
Insoluble impurities in light petroleum
Trace elements (iron, copper)
The chemical testing criteria for Australian Extra Virgin as stated in the Code is ambiguous.
In the introduction it states that ‘It supplements the provisions of the Food Standards Australia New Zealand Code and related legislation, The Trade Practices Act, State and Territory fair trading food safety and health legislation, and international rules and codes with similar aims, such as those of the International Olive Council and the Codex Alimentarius Commission’.
This statement (and in particular the use of the word ‘supplement’ ) implies that the IOC and Codex olive oil standards are the basic requirement for signatories to the Code and that any olive oils carrying the Brand must have provided testing data from internationally recognised laboratories to prove compliance to all the tests.
The ‘Quality and Labelling Guidelines’ for Australian Extra Virgin’ defined in the Code only require the following chemical tests:
Free fatty acid contents
Peroxide value
Ultra-violet absorbency tests
This list only includes three of the quality criteria tests in the IOC/Codex chemical tests and there are no tests for adulteration or contamination with refined olive oils and vegetable oils. The ABC 7.30 Report based on AOA findings made a number of assertions regarding the presence of refined olive oils and other vegetable oils in imported brands.
If the only tests required for the Australian Extra Virgin Brand are the three quality criteria listed in the Code, it is only a matter of time before a Brand oil is found not to comply with international standards. The olive oil supply chain in any producing country, including Australia, involves a number of steps where varietal variation, contamination, adulteration or deterioration can occur:
Some olive varieties in Australia are known to produce oil which has above standard linolenic acid levels – one of the indicators of contamination with other vegetable oils.
Some olive varieties in Australia also produce oil which has above standard sterol levels, especially campesterol.
Contamination may occur in transport, storage or packing where other vegetable oils or refined olive oils have been handled.
All olive oils, imported or Australian, will deteriorate over time. This deterioration is accelerated when the product is subjected to adverse conditions of heat and light in storage, transit or on retail shelves. The chance of this is increased with the conditions encountered with exports.
The risk of contamination is recognised by one brand of Australian Extra Virgin Olive Oil in a spray can which carries the following information on the label ‘may contain traces of soya bean lecithin’. The brand is a signatory to the Code.
One explanation for the Code not requiring the full international trade standard testing regime is that the cost of testing will be a disincentive to participate. However, compromising the integrity of Australian Extra Virgin Olive Oil through adopting sub-standard testing requirements may in the long term extract a far greater cost from the Australian Olive Industry.
Recognised Laboratories
There are currently two Australian laboratories recognised by the AOA as competent to test olive oils for the Brand.
It is reasonable to propose that any chemical analysis used as a basis for certification by the Code, or for assessment of breaches, should be undertaken by an independent and IOC recognised laboratory.
Any determination made by the Code compliance committee will have to withstand legal scrutiny of the testing regime when disputes arise. This reinforces the imperative to ensure that all sensory and chemical testing is independent and to International Olive Council and Codex Alimentarius standard.
It would make sense to recognise all IOC recognised chemical laboratories worldwide as competent to undertake testing for the Code. Currently testing certificates issued by overseas IOC recognised laboratories would appear to be ineligible for compliance with the Code.
Breach of the Code and Product Recall
The Code states that ‘Any signatory may initiate the testing of an olive product’. This validates the monitoring and testing of competing brands of any of the Code signatories. This could be used as a tool to gain competitive advantage and discredit competing brands. This practice could lead to vexatious claims.
In such an instance the independence of members of the Code Compliance Committee and of the testing laboratories would seem of paramount importance.
In the provisions for a breach of the Code, it states: ‘The Committee shall take no action in respect of a first breach of the Code arising as a direct result from non-compliance of olive products provided the signatory had obtained a certificate of compliance from the supplier in respect of the offending supplies’. There is no stipulation as to where the certificate of compliance should be obtained or what tests the certificate of compliance should cover.
The Code therefore does not require immediate product recall or suspension of non-compliant products. After a testing process that could take up to two months, the offending brand is required to implement an effective compliance programme.
The non-complying product could be on retail shelves for considerable time, and if detected by other monitoring programmes not associated with the AOA could bring adverse publicity and compromise the Brand. The negative publicity associated with this may have consequences for all Australian olive oils that bear the Brand.
Guarantees and Liability
The website for ‘Australian Extra Virgin’ states that ‘The Code of Practice guarantees the authenticity and quality of certified products…………..’
This guarantee has far-reaching legal implications. If a certified product is found not to comply with international standards recognised in Australia, as the owner of the Brand, The Australian Olive Association may be liable for the failure of the guarantee. With a testing regime that does not appear to meet the requirements of international trade and Codex standards, this is a very real possibility.
The liability may also extend to the Compliance Committee and those accredited by the AOA to undertake sensory and chemical testing to international standard.
Conclusions
As it stands, the testing regime for the Code of Practice underpinning the Australian Extra Virgin Brand appears to be considerably less rigorous than that required for international trade in olive oil.
The accreditation system for sensory analysis and tasters falls well short of the requirements for recognition by the International Olive Council.
The chemical testing required does not include contamination/adulteration tests.
The independence of the testing process is questionable.
To be credible, the Brand should have as its minimum requirement that all branded oils meet all international trade standards and provide testing certification by independent laboratories and tasting panels recognised by the International Olive Council to prove this.
All overseas IOC recognised laboratories and sensory panels should be accredited by the AOA Code of Practice and classification certificates issued by them accepted as valid.
The additional selling point for the brand will be that it is authentically Australian and fresh.
To protect the interests of consumers, Australia needs a system of testing olive oils for compliance that is independent and meets international trade standards.
Actions taken on non-compliance should protect consumers while being sensitive to possible collateral damage to the production and retailing of olive oil in Australia.
In the words of the AOA President in his address to the AOA Conference in Brisbane 2003, ‘The approach to regulation of olive products needs to be careful. We do not want consumers ever thinking that there is something ‘wrong’ with olives or olive oil’.
Simon Field is an Australian olive oil producer and trader. He is a former Executive Director of the Australian Institute of Agricultural Science. As an olive oil trader he supplies Australian olive oil to a number of Australian brands. He has a commercial interest in an Australian olive oil mentioned on the ABC 7.30 Report and the subsequent discussion of compliance with International Olive Council specifications for Australian olive oil.
