By Heidi Gough – RQA Principal Consultant
In 2022, a handmade chocolate bar with a pistachio filling launched in Dubai. The combination of Dubai’s aspirational image and the striking green filling helped the product go viral.
As the bars are handmade, with limited production capacity and popularity on social media[1], demand outpaced supply, similar products began appearing worldwide. These “Dubai-style” chocolate bars mimicked the original’s moulded shape and pistachio centre. Both multinational brands and smaller producers joined the trend and pistachio began showing up in everything from croissants to coffee. The surge in popularity also led to increased imports, including through grey market channels.
The Warning Signs
By 2024, pistachio supply from California had dropped by 20 percent due to a poor harvest. At the same time, global demand was increasing due to the Dubai chocolate craze. For those working in food safety and food defence, this combination should have raised immediate concerns. High consumer interest and pressure on a key ingredient created conditions ripe for risk.
Pistachio prices in the United States rose sharply in 2024, climbing from $7.65 to over $10.30 per pound in less than a year[1]. It was not an ideal time to launch new pistachio-based products!
While many Dubai-style chocolate products were safe, the combination of limited supply and high consumer demand created conditions where both food safety and food fraud risks were significantly elevated. When ingredients become scarce and prices rise, the supply chain can become vulnerable to fraudulent practices. These may include substitution of ingredients, mislabelling, dilution, or the use of unauthorised sources. At the same time, the urgency to meet demand can lead to lapses in food safety controls, such as inadequate testing, poor traceability, or compromised hygiene standards. The convergence of economic pressure, rapid market expansion, and fragmented supply chains increases the likelihood of both intentional fraud and unintentional safety failures. For food businesses, this highlights the need for heightened vigilance, stronger supplier verification and proactive risk assessments during periods of market volatility. Food business must then act to reduce the risk of consumer harm.
Grey Market Imports
As demand soared, imports started to fill the gap between consumer interest and supply but some of these imports were so called “grey market” products; products never intended for export to the destination country. Products brought in by distributors or retailers must meet local food safety regulations, including labelling requirements. Several imported Dubai-style chocolates failed to comply[2]. This poses a serious risk to consumers, especially those with allergies, if ingredients are not listed in the local language or labelled according to domestic standards.
With demand skyrocketing, counterfeit products were also produced, sold and recalled from the UK market[3]. These products were not labelled with UK nutritional information.
It’s an important lesson that importers must be aware of the legislation of the destination country and the authenticity of the products they’re bringing into the country so as not to create food safety or authenticity risks.
[1] https://www.confectionerynews.com/Article/2025/04/04/dubai-chocolate-trend-growing-fast/
[2] https://www.bbc.co.uk/news/articles/ceqg3vy9wl3o
[3] https://www.food.gov.uk/news-alerts/alert/fsa-fafa-03-2025-update-1
Ingredient Substitution
Allergens remain a persistent reason for food safety recalls with allergen-related labelling errors as the top cause of recall events for the FSA, FDA, FSANZ and MPI[1]. pistachios, an expensive ingredient in high demand and low supply, this creates specific risk. In the UK, some products labelled as pistachio-based were found to contain peanuts or other tree nuts[2], in Germany a product contained sesame[3] and a Canadian product was recalled for undeclared soy and wheat[4]. It remains unclear whether this was due to cross-contamination or deliberate substitution. However, with pistachios in short supply, the potential for fraud increases.
Microbiological Risks
Chocolate and nut butter products can cause illness in consumers if contaminated with Salmonella, with known outbreaks over the past 50 years where even low levels were proven to cause harm[5]. Recent recalls in Canada linked to Salmonella[6] and E Coli and mould in the EU[7] highlight the need for microbiological vigilance in the knowledge and approval of the manufacturers. This need is regardless of whether the issue is directly tied to the viral trend for Dubai-style chocolate, or indeed any other products.
Chemical Contaminants
Some Dubai-style chocolate bars sold in the EU were found to contain aflatoxin and ochratoxin A[8]. These mycotoxins result from mould growth during crop cultivation, harvesting, or storage. This is especially likely in humid conditions or when kernels are damaged. While routine testing is standard, high demand can lead to mistakes or intentional diversion of substandard crops.
Implications for Food Vulnerability
So how do we tackle situations like this and protect consumers? Was it foreseeable?
Product developers, procurement and commercial teams play a vital role in understanding food vulnerability. They monitor consumer trends and are aware of price shifts across the supply chain. Viral products can trigger predictable changes in demand, creating opportunities for inexperienced manufacturers or bad actors to exploit the situation. Responsible manufacturers feel the pressure to act with demand for shorter product development cycles[9] driven by social media and influencer led trends potentially introducing risk into new product development by compressing sourcing lead times and creating supply chain pressure.
When prices spike, especially for ingredients that are already considered premium or scarce, the temptation to cut corners or commit fraud increases. This has been seen in several past incidents. For example, during the global vanilla shortage in 2017[10]This led to widespread concerns about adulteration with synthetic vanillin or dilution with cheaper substances. Similarly, olive oil has long been a target for fraud[1], particularly when extra virgin varieties command high prices. Investigations have uncovered cases where lower-grade oils were mislabelled or mixed with other types to increase profit margins.
Food defence teams should stay alert to viral trends that could affect their supply chains directly or indirectly. Early awareness and proactive risk assessment are key to protecting consumers and maintaining product integrity. These examples show that price volatility is not just a financial issue. It is a signal that food safety and vulnerability teams should monitor closely to anticipate and mitigate potential risks.
So next time you see that viral trend? Before jumping on the bandwagon of NPD to exploit consumer demand, think “how could this impact food fraud or food safety?”
Your food defence team could help prevent consumer harm.
[1] Casadei, E., Valli, E., Panni, F., Donarski, J., Gubern, J. F., Lucci, P., … & Toschi, T. G. (2021). Emerging trends in olive oil fraud and possible countermeasures. Food Control, 124, 107902.
[1] https://www.rqa-group.com/product-recall-report-h1-2025-out-now/
[2] https://www.food.gov.uk/news-alerts/alert/fsa-fafa-03-2025-update-1
[3] https://webgate.ec.europa.eu/rasff-window/screen/notification/747056
[4] https://recalls-rappels.canada.ca/en/alert-recall/habibi-dubai-chocolat-brand-kunafa-pistachio-milk-chocolate-recalled-due-undeclared
[5] Lund, S., Tahir, M., Vohra, L. I., Hamdana, A. H., & Ahmad, S. (2022). Outbreak of monophasic Salmonella Typhimurium Sequence Type 34 linked to chocolate products. Annals of Medicine and Surgery, 82.
[6] https://recalls-rappels.canada.ca/en/alert-recall/dubai-brand-pistachio-knafeh-milk-chocolate-recalled-due-salmonella-0
[7] https://webgate.ec.europa.eu/rasff-window/screen/notification/787289
[8] https://webgate.ec.europa.eu/rasff-window/screen/notification/734242
[9] https://www.supplysidefbj.com/market-trends-analysis/how-gen-z-is-driving-f-b-product-development-trends
[10] https://www.cbsnews.com/news/vanilla-bean-shortage-madagascar-drives-up-us-prices/