When it comes to food fraud, each food safety standard has slightly different food fraud requirements. For example, some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t; some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on finished products.
Confused? We are here to help. Read on to find out which standards have what requirements, and get recommendations for creating a great food fraud prevention (VACCP) program.
Food safety standards are standards that describe requirements for food and related businesses. The requirements aim to ensure that food and food-related goods are safe for consumers and customers. The correct term for such standards is food safety management systems standards (FSMS).
There are food safety standards for all types of operations within the food supply chain, including:
- growing and packing fresh produce;
- manufacture of food and food ingredients;
- buying and selling food (“brokers”);
- storage and transport of food;
- manufacture or converting of packaging materials;
- manufacture of animal feed or pet food;
- services such as cleaning, laundry, or pest control for food businesses.
The over-arching aim of all food safety standards is to keep consumers safe, but most standards also have secondary aims. Some of the most popular food safety standards were developed by food retailing groups, and these standards were written to protecting the retailers’ brands as well as keeping consumers safe. Other standards were developed to help food businesses understand best practices and gain a way to demonstrate their excellence through independent certifications. Some standards include quality parameters, while others only address food safety issues.
There are dozens of internationally accepted food safety management system standards, each with slightly different requirements. This can make it difficult to know which standards are ‘better’ or more suitable for your food company.
To solve this problem, a standard for food safety standards was created by the GFSI (Global Food Safety Initiative). The GFSI assesses and approves food safety standards using a process called benchmarking. The aim of GFSI benchmarking is to define best practice in food safety standards and provide a way to compare and align different food safety standards.
Among the dozens of food safety standards, some are benchmarked by the GFSI (Global Food Safety Initiative), while others are not. Benchmarked standards usually have more requirements and more rigorous expectations than non-benchmarked standards. The auditing and certification processes for benchmarked standards are typically more time-consuming and often more expensive than for non-benchmarked standards.
Food Fraud in Food Safety Standards
Food fraud prevention activities are an important part of all food safety management systems because food fraud can pose a risk to food safety. Some food safety standards have separate, stand alone requirements for food fraud prevention activities, while others do not. Standards that are GFSI-benchmarked all include explicit, separate food-fraud-related requirements. Other standards rely on the hazard analysis elements of the food safety system to identify and control hazards from food fraud.
The GFSI requires all benchmarked standards to require food companies to do a vulnerability assessment for food fraud and create a mitigation plan for food fraud prevention. Most GFSI-benchmarked standards also include details about which materials should be assessed and which types of food fraud need to be managed.
Non-GFSI standards vary in how they require a food company to approach food fraud. Some specify or recommend a VACCP program, which is based on food fraud vulnerability assessment activities. Others, like AIB, require that food fraud risks be considered in the supplier approvals processes. The regulations of the USA Food Safety Modernization Act (FSMA) require that food businesses identify hazards from economically motivated adulteration type food fraud and implement preventive controls to minimise the risks.
Among the most well-known standards there are some notable differences. For example, the SQF Food Safety Code requires food businesses to assess and manage risks from counterfeit-type food fraud, while the BRC Food Safety Standard only requires businesses to assess the risks from adulteration or substitution activities. BRC requires horizon scanning activities, while the SQF and IFS standards explicitly mention food fraud training.
Below you will find a table that compares the current food fraud requirements of each of the major food safety standards.
Table 1. Food fraud requirements of major food safety standards, 2022.
|Food types to include in food fraud prevention activities||Ingredients (implied)
|Products and processes
|Food fraud types
|Economically motivated adulteration (only)
|Any type where consumer health is at risk (in definition, Appendix A)
|Unclear, however counterfeit or non-foodgrade packaging or propagation materials are included as examples
|Substitution, mislabelling, adulteration, counterfeiting
|Substitution, mislabelling, dilution, counterfeiting
|Vulnerability assessments explicitly required?||Risk assessment (implied, Appendix A)||Yes||Yes||Risk assessment||Yes||Implied (Edition 9)|
|Mitigation plan required?
|–||Mitigation activities are to be included in the vulnerability assessment||Yes||Yes||Yes||Yes|
|Does packaging need to be included in the vulnerability assessment?||Yes
(as per food fraud definition, Appendix A)
(primary packaging is a ‘raw material’)
|Is a separate food fraud procedure explicitly required?||–||–||Yes||–||Implied
(“responsibilities shall be defined”)
(“methods and responsibilities shall be documented”)
|Is training in food fraud explicitly mentioned?||–||Implied
|Is an annual review explicitly required?||–||Yes||–||–||Yes||Yes|
|–||Horizon scanning for developing threats must be done (Clause 5.4.1)||–||–||Criteria for vulnerability assessments must be defined
|Food safety risks from food fraud must be specified (18.104.22.168)|
* The full names of the standards are as follows:
AIB International Consolidated Standards for Inspection of Prerequisite and Food Safety Programs, 2023 (NEW!)
BRCGS Food Safety, Issue 9 (NEW!)
FSSC 22000, Version 5.1
GlobalG.A.P. Integrated Farm Assurance (IFA), Version 5.4-1
IFS Food, Version 7
SQF Food Safety Code, Edition 9
Among the major food safety management system standards, there are small but significant differences between food fraud prevention requirements. Key differences include whether finished products or ingredients are to be assessed, which types of food fraud must be included and the presence/absence of requirements related to horizon scanning and training.
If that all seems confusing, don’t despair…
Recommendations for a robust and compliant food fraud prevention program (VACCP)
At Food Fraud Advisors we have been working at the intersection of food fraud and food safety since the very beginning! Creating a robust and compliant food fraud program can take time and effort but it isn’t complicated. Follow the steps below to get started:
- Carefully read the food fraud clauses of the standard you are/will be certified to.
- Pay attention to the food types and the food fraud types that are mentioned in your standard. HINT: you may need to check the definitions or glossary.
- Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
- Whether or not it is explicitly required in your standard, we recommend you create a food fraud prevention procedure that defines the methods, responsibilities and criteria for food fraud prevention.
- You should also conduct training for all relevant staff and ensure that the food fraud system is reviewed at least annually.
Get a complete guide to the food fraud requirements of all the major food safety standards from us, the food fraud experts, here.