As prices for the main ingredient, kadaif, have surged amid the "Dubai jjondeuk cookie" craze, recipes using substitutes such as soy noodle (soy milk noodle), konjac noodle, and somyeon (wheat flour) have been popping up. These are the so-called "jjap-jjonku."
However, legal interpretations diverge on whether it constitutes fraud if restaurants sell Dubai jjondeuk cookie made with substitute ingredients without informing consumers.
◇ With ingredient costs tripling, "somyeon, konjac" go in… the rise of jjap-jjonku
According to the app "Polcent," which tracks price changes on online marketplaces, prices for some 1㎏ pistachio products sold on Coupang more than tripled in a month. One product that was around 20,000 won in early December last year had risen to the 80,000 won range as of Jan. 13. Kadaif also nearly doubled over the same period to around 30,000 won for 500g. Marshmallow prices showed a similar trend. All are core ingredients of the Dubai jjondeuk cookie.
The Dubai jjondeuk cookie is a dessert made by filling Middle Eastern kadaif and a pistachio paste toasted and ground with white chocolate, then wrapping it in marshmallow and dusting it with Kakao powder. As the Dubai jjondeuk cookie craze has spread on social media, supplies of the main ingredients have tightened and prices have soared.
As Dubai jjondeuk cookie prices rise, substitute recipes are drawing attention. Since kadaif is a thin noodle made from a dough of flour and water, using soy noodle can maintain the texture while lowering the cost. Breaking soy noodle into small pieces and stir-frying it in butter is said to yield a texture and nutty flavor similar to kadaif.
Konjac noodles and rice noodles have also emerged as alternatives. These ingredients are relatively inexpensive and lower in calories, making them popular as "healthy Dubai jjondeuk cookies." While Dubai jjondeuk cookies sold on the market are about 500–600㎉ each—roughly the equivalent of two bowls of rice—using soy noodles or konjac noodles can reduce the calories.
In addition, gelatin can be used instead of marshmallow, or the convenience store candy Mallang Cow can be melted and used. Another method that has appeared is splitting a Chaltteok Pie in half and adding pistachio paste.
◇ Ordered for delivery and got jjap-jjonku… potential fraud and Food Sanitation Act violations
The issue arises when substitute ingredients are used in products for sale rather than personal consumption. Some shops, citing supply difficulties, have used somyeon instead of kadaif or removed pistachios from the filling and still sold the item under the Dubai jjondeuk cookie name, stirring controversy.
The legal community notes that selling products using substitutes without properly disclosing the materials and supplies could constitute fraud under the Criminal Act. Attorney Kim Seong-su of Law Office Gwangya said, "The Dubai jjondeuk cookie is a product where the materials and supplies are the key," adding, "If substitutes are used and this is not disclosed, it can be seen as a deceptive act, and since consumers likely would not have purchased had they known, there is room for fraud to be established."
Others say applying the fraud charge would not be easy. Attorney Jeon Min-jae of Law Firm Trinity said, "If a seller explicitly advertised 'we use kadaif' but used other ingredients, it could be an issue of false or exaggerated advertising," but added, "Unless Dubai jjondeuk cookie is trademarked and the use of kadaif has become an official requirement, it would be difficult to apply fraud if the appearance or taste is not significantly different."
Recently, more gukbap restaurants and burger shops have been making Dubai jjondeuk cookies themselves and selling them as "loss leaders." This, too, raises legal issues. Kim said, "If they sold without filing a business notification for manufacturing and selling confectionery, there is potential for violating the Food Sanitation Act."