FDA Finds Evidence of Limited Food Fraud in Imported Lemon Juice
The U.S. Food and Drug Administration (FDA) has released the results of a sampling assignment conducted from 2022–2025 to test domestic and imported lemon juice for economically motivated adulteration, also known as food fraud. Of the 195 samples tested, seven imported samples were found to be violative, while no violations were identified among domestic samples.
The findings represented a 3.6 percent violation rate across all samples and a 4.5 percent violation rate among imported samples.
Economically motivated adulteration occurs when ingredients are intentionally substituted, added, or omitted from a food product to increase its apparent value or reduce production costs. In the case of lemon juice, this can include the addition of undeclared sweeteners, citric acid, or juices from non-lemon sources, as well as dilution with excess water.
FDA's sampling assignment was intended to identify products that did not comply with the agency's standard of identity for lemon juice, which establishes requirements for the product's composition. For reconstituted lemon juice, the standard requires at least 6 percent soluble solids and a titratable acidity of at least 4.5 percent, by weight, calculated as anhydrous citric acid.
FDA Lemon Juice Sampling Results
Between October 19, 2022 and January 22, 2025, FDA collected and analyzed 195 lemon juice samples, including 38 domestic samples and 157 imported samples. Domestic samples were collected from retailers or manufacturers, while imported samples were collected at ports of entry before release into U.S. commerce.
To assess product authenticity, FDA used several analytical methods, including measurements of citric acid and isocitric acid concentrations and their ratio, stable carbon isotope ratio analysis (SCIRA) to identify potentially non-lemon sources of citric acid, and Brix testing to detect possible dilution of reconstituted lemon juice.
Of the seven violative imported samples, three originated from India, two from Taiwan, one from Türkiye, and one from Vietnam. FDA cautioned against drawing conclusions about country-specific adulteration rates because the sampling assignment was not designed to support such comparisons.
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FDA Takes Enforcement Action Against Violative Lemon Juice Imports
All shipments associated with violative samples were refused entry into the U.S. Additionally, the associated firms and products were placed on Import Alert 99-47 (Detention Without Physical Examination of Human Food Products That Appear to be Adulterated for Economic Gain), or subjected to increased screening and surveillance sampling.
Under the import alert, FDA can detain affected products without physically examining or sampling individual shipments. To have products admitted into the U.S., firms must provide evidence demonstrating compliance with FDA requirements, such as third-party laboratory testing results.
FDA concluded that although lemon juice remains vulnerable to economically motivated adulteration, the sampling results suggested that the practice is not widespread. The agency said it may consider more targeted sampling to further protect consumers against food fraud.
