Trends in Food Science & Technology 100 (2020) 131–137

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Trends in Food Science & Technology

journal homepage: www.elsevier.com/locate/tifs

Food fraud vulnerability assessment: Towards a global consensus on T

procedures to manage and mitigate food fraud
Virginie Barrerea,∗, Karen Everstineb, Jérémie Théoliera, Samuel Godefroya
a
Food Risk Analysis and Regulatory Excellence Platform (PARERA), INAF, Université Laval, 2440 boulevard Hochelaga, Québec, QC, G1V0A6, Canada
b
Decernis, 1250 Connecticut Ave, NW Suite 200, Washington D.C, 20036, USA

A R T I C LE I N FO A B S T R A C T

Keywords: Background: Food fraud represents a risk to the food industry and food business operators are required to
Food fraud conduct a food fraud vulnerability assessment to be in compliance with GFSI requirements. There is currently no
Vulnerability assessment globally-recognized standardized process for food fraud mitigation and some food business operators have found
Consensus meeting the requirements to be challenging.
International food standard
Scope and approach: This work summarizes the main aspects of publicly-available food fraud vulnerability as-
sessment (FFVA) tools and resources, describes the general FFVA process based on a consensus of the previous
work, and highlights gaps in this process that should be addressed.
Key findings and conclusions: The main gaps identified were: appropriately grouping and prioritizing products/
ingredients, evaluating the vulnerability of multi-component finished products, collecting and evaluating sup-
porting data, evaluating potential public health and economic impacts, resource constraints among small/
medium-sized companies and in developing countries, understanding and creating standards for analytical de-
tection methods for fraud, and evaluating fraud vulnerability in food packaging.
This work can support discussions at a global level that may eventually lead to a consensus process for a
FFVA, for example, those conducted under the auspices of the Codex Alimentarius Commission.

1. Introduction
Over the last decade, food fraud has been identified as an emerging
risk to the food industry and a significant concern to consumers and
food regulators. One estimate cited that 10% of food products could
contain a fraudulent component (Everstine & Kircher, 2013). The esti-
mated total economic burden is US$10–15 billion (Grocery
Manufacturers Association, 2010). No globally accepted definition of
food fraud exists at this point, but it is generally recognized to be an
intentional act of misrepresentation of food for economic gain; it is
intended to remain undetected and misrepresents the food product to
the client or the consumer. It is worth noting that virtually all food
products can be subject to fraud through substitution, dilution, coun-
terfeit, diversion, enhancement, or mislabeling (Moore, Spink, & Lipp,
2012). Although food fraud is generally considered to be more of an
economic concern than a food safety concern, it can represent a real
public health risk (Everstine et al., 2018; Spink & Moyer, 2011), and
can have severe impacts on consumers and the industry in cases that
cause illness or death. In response to the risks that food fraud re-
presents, in January 2018, the Global Food Safety Initiative (GFSI)
published a position paper on mitigating the public health risk of food
fraud and required that GFSI-Recognized Certification Program Owner
(CPO) standards include a requirement for documented food fraud
vulnerability assessments and control plans applicable to all products.
These requirements went into effect in January 2018 (Global Food
Safety Initiative: Benchmarking Requirements Document v7.1) (GFSI,
2014; GFSI, 2019).
The European Committee for Standardization (CEN) published a
document that outlines the result of a workshop that defined concepts,
terms and definitions related to food fraud (CEN European Committee
for Standardization, 2019). The International Organization for Stan-
dardization (ISO) includes a reference to food fraud in their standard
ISO 22000 (ISO, 2018) and also has standards specific to targeted food
fraud issues (such as the determination of melamine and cyanuric acid
in milk (ISO, 2017)).
Over the past few years, other organizations have also developed
tools and resources to support food fraud vulnerability assessments
(FFVA) and mitigation plans. These include the United States
Pharmacopeia (USP) and a collaborative effort among Safe Supply of
Affordable Food Everywhere (SSAFE), PricewaterhouseCoopers (PwC),

∗
Corresponding author.
E-mail address: virginie.barrere@fsaa.ulaval.ca (V. Barrere).

https://doi.org/10.1016/j.tifs.2020.04.002
Received 20 September 2019; Received in revised form 30 March 2020; Accepted 12 April 2020
Available online 21 April 2020
0924-2244/ © 2020 Elsevier Ltd. All rights reserved.
V. Barrere, et al.
and Wageningen University. These resources generally have the aim of
reducing the risk of fraud in the food supply chain leading to an en-
hancement of consumer protection, compliance with regulations and
GFSI requirements, and the protection of the food company and the
sector. CPOs such as BRC, FSSC22000, and SQF, have developed
documents to support the food industry in complying with the new
requirements regarding food fraud (British Retail Council, 2018;
FSSC22000, 2019; SQF, 2018). Those documents present general
background, definitions and limited guidance for understanding food
fraud. However, the documents do not directly describe an exhaustive
procedure to evaluate food fraud vulnerability and develop a mitigation
plan; they often refer to other resources such as SSAFE or USP. IFS,
however, did publish a guidance document to assist industry in com-
plying with the requirements which is comparable to those of SSAFE or
USP. Various white papers and reports have also been published by
food industry members and industry groups, including Nestle (Nestlé,
2016) and the Grocery Manufacturer Association (Grocery
Manufacturers, 2010). While these are not tools or guidance docu-
ments, these documents provide useful background information and
insights.
One survey reported that, of 19 food manufacturers in the United
Kingdom, 7 used an “in-house” FFVA, 5 used a private guidance
document, 2 used the SSAFE tool, and none used the USP tool (the IFS
tool was not listed as a possible answer choice). The 5 remaining re-
spondents used other strategies (e.g. product testing) (Soon,
Krzyzaniak, Shuttlewood, Smith, & Jack, 2019). Four papers described
the application of the SSAFE tool to broad (not company-specific)
supply chains: spices (Silvis, van Ruth, van der Fels-Klerx, & Luning,
2017), organic foods (van Ruth & de Pagter-de Witte, 2020), extra
virgin olive oil (Yan, Erasmus, Aguilera Toro, Huang, & van Ruth,
2020), and the food service industry (van Ruth, van der Veeken,
Dekker, Luning, & Huisman, 2020).
The objective of a FFVA is not to detect fraud but rather assess
vulnerabilities to fraud and, subsequently, to implement measures to
prevent it from occurring (Spink, 2019). The term “vulnerability” dif-
fers in meaning from the term “risk.” The U.S. Department of Homeland
Security defines vulnerability as “a physical feature or operational at-
tribute that renders an entity open to exploitation or susceptible to a
given hazard” and defines risk as “the potential for an unwanted out-
come resulting from an incident, event, or occurrence, as determined by
its likelihood and the associated consequences” (US Department of
Homeland Security, 2015). The difference between risk assessment and
vulnerability assessment is described in Manning and Soon (2019):
“vulnerability is a measure of a system's susceptibility … to threat
scenarios whereas the level of risk focuses on the consequences and
their severity should a threat be realized.” In their Food Fraud Guidance
for Sites and Auditors (SQF, 2018), SQF notes that their food fraud
requirements talk about “vulnerabilities” rather than “risk” because a
risk (in the context of food safety) involves “something that has oc-
curred frequently before, will occur again,” and for which “there is
enough data to conduct a statistical assessment.” Vulnerability, on the
other hand, is “a condition that could lead to an incident.”
To align with Hazard Analysis and Critical Control Points (HACCP)
terminology, GFSI adopted the use of the term “VACCP” (Vulnerability
Assessment and Critical Control Points). However, many in the food
industry have noted that this acronym tends to be misleading since it
does not align with HACCP in its procedure and maintenance (personal
communications). Food operators have cited many challenges they face
with implementing a FFVA. A survey conducted in Canada in 2018
(Guntzburger et al., 2020) highlighted that only 36% of all respondents
had implemented a vulnerability assessment in their facility, while the
proportion for manufacturers only was 53% (Guntzburger et al., 2020).
This survey noted some of the reasons food industry operators had not
implemented measures to control food fraud, which included a lack of
both human and financial resources. Another survey performed in the
United Kingdom reported that 10 of 19 respondents had implemented a
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Trends in Food Science & Technology 100 (2020) 131–137
policy on fraud prevention and investigation (Soon et al., 2019).
Comments received from Food Business Operators (FBOs) and inter-
national experts on food fraud prevention at conferences, training ses-
sions, and informal discussions have noted additional challenges with
implementation. FBOs have mentioned that the existence of multiple
tools makes operators (particularly those in small and medium-sized
companies) ask which will best enable them to meet the requirements
of the auditor, client, or regulator. Also, there can be a tremendous
workload involved to assess all ingredients if a company has an ex-
tensive list of raw material and suppliers. It is clear that many in the
food industry have found implementation of a FFVA to be challenging.
Unlike food safety (prevention of accidental contamination with
foodborne pathogens or other hazards), for which guidance like HACCP
has been available for the food industry and regulators, currently, there
is no standardized food fraud prevention process that has been globally
validated. HACCP measures have been incorporated into Codex
Alimentarius (“Codex”) standards. However, FFVA protocols currently
developed and applied by the food industry sector have not been in-
cluded in any Codex text, such as a Code of Practice or a standard.
Therefore, FFVA protocols have not benefitted from the inclusive,
transparent, collaborative and consensus-driven approach inherent in
Codex procedures. There is current work underway by the Codex
Committee on Food Inspection and Certification Systems (CCFICS) that
may pave the way to such development as a next step to the committee's
current attempts to adopt a common definition for food fraud and to
identify gaps in existing Codex texts (Godefroy et al., 2020).
Food fraud is a particular challenge to food safety stakeholders
given the intentional nature of the act and the variety of (often un-
anticipated) adulterants that are used (Everstine, Spink, & Kennedy,
2013). Therefore, a wide range of factors and data sources need to be
included in a FFVA. However, the lack of consensus on an inter-
nationally recognized FFVA process results in a lack of clarity in terms
of how to best ensure compliance with requirements. This work aims to
present the main aspects of publicly-available FFVA tools and resources
to date, to summarize the general FFVA process based on a consensus of
the previous work, and to identify gaps in the consensus process that
should be addressed.
2. Description of existing food fraud vulnerability assessment
tools and resources
Three publicly available guidance documents and tools (USP,
SSAFE, and IFS) are described below in terms of format, approach,
advantages, and gaps.
2.1. Food Fraud Mitigation Guidance - United States Pharmacopeial
Convention (USP)
Format: The USP Food Fraud Mitigation Guidance (an appendix of
the Food Chemicals Codex) is a 37-page guidance document available in
.pdf format (United States Pharmacopeia, 2016).
Basic approach: The guidance was developed by a USP Expert
Panel which included representatives from industry, government, and
academic institutions. The document describes a 4-step process to 1:
assess 9 contributing factors to food fraud vulnerability, 2: assess po-
tential impacts (food safety, economic, etc.), 3: characterize the overall
vulnerability based on the previous steps, and 4: develop a mitigation
strategy. The scope of the framework focuses on fraud and mis-
representation of food ingredients, specifically; it does not include is-
sues such as theft or counterfeiting. The 9 contributing factors to food
fraud are: supply chain; audit strategy; supplier relationship; history of
supplier regulatory, quality, or safety issues; susceptibility of quality
assurance methods and specifications; testing frequency; geopolitical
considerations; fraud history; and economic anomalies. The document
provides a framework of matrices to be used when conducting the as-
sessments. The document also describes an optional “pre-screening”
V. Barrere, et al.
step that can be implemented for companies with a large portfolio of
products or ingredients. In addressing this situation, the document re-
commends grouping the ingredients by class, or prioritizing ingredients
originating from regions where fraud has been reported.
Advantages: This document was written in the format of a guidance
document, and is generally non-prescriptive with respect to the details
of implementation; therefore, it allows flexibility in adapting the pro-
cess framework to the specifics of a given organization. It provides a
thorough discussion of food fraud vulnerabilities and provides many
illustrative examples based on actual occurrences of fraud. It also lists
many supporting resources that can support the assessment.
Gaps: The lack of a corresponding tool or spreadsheet requires the
user to develop their own recordkeeping system. The process outlined
in the document can be time-consuming to implement, especially when
conducted on an ingredient-by-ingredient basis. Although the sugges-
tion to group ingredients is briefly mentioned in the optional “pre-
screening” step, further guidance on how to group ingredients and how
to conduct an initial screening step is needed. There may be a risk of
assigning group classifications in a way that does not properly represent
the vulnerability and, therefore, potentially underrepresenting the
fraud risk. Finally, the matrix system demonstrated in the document
does not include an explicit numerical scoring system, which some may
find helpful for differentiating ingredient risks.
2.2. SSAFE Food Fraud Tool – SSAFE, PwC, and Wageningen University
Format: The SSAFE tool, a collaboration among SSAFE, PwC, and
Wageningen University, is an online assessment accessible after regis-
tration (van Ruth, Huisman, & Luning, 2017). The format consists of a
series of questions followed by both a visual and narrative output of the
results.
Basic approach: This tool indicates that users can conduct an
analysis based on ingredients, products, or product groups (referred to
as “objects” within the tool). The user is asked to perform an impact
analysis (based on safety risks, economic value, and brand image) to
select which objects to prioritize. For each object, the operator answers
a set of 50 questions based on criminology concepts: motivation, op-
portunity, and control (Cohen & Felson, 1979). The user is also
prompted to indicate the degree of certainty in each response. The
output of the assessment is numerical with corresponding plots on
spider charts, with the goal of helping to visually identify areas where
action or focus may be warranted for mitigation measures.
Advantages: Creation of this tool was supported by the GFSI Board
and this tool is directly cited in many of the GFSI CPO guidance
documents. The use of an online, interactive tool that is more pre-
scriptive than a guidance document may be advantageous for some
users. The questions often involve a scenario-based approach and in-
clude links to supporting sources for information. The assessment can
be completed individually, or a user can assign sections to other col-
leagues to complete as part of an overall joint assessment.
Gaps: The question and answer format are less adaptable than a
guidance document. The assessment process can be long and laborious
to be implemented, which can be a hindrance for operators with a
broad portfolio of ingredients and products. As above, additional gui-
dance on how to implement appropriate grouping of ingredients or
products into “product groups” is warranted. This food fraud tool does
not explicitly include an impact assessment or guidance on mitigation
strategies.
2.3. IFS Standards Product Fraud-Guidelines for Implementation -
International Featured Standards (IFS) Food
Format: The IFS Standards Product Fraud – Guidelines for
Implementation is a 52-page guidance document available in.pdf
format (Tromp & Sechet, 2018).
Basic Approach: This is a guidance document published to support
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Trends in Food Science & Technology 100 (2020) 131–137
industry in meeting the requirements of IFS Food (Tromp & Sechet,
2018). The document presents the various phases of risk management
adapted to food fraud and proposes a general step by step procedure
that can be adapted to the needs of a particular organization. The
document recommends assessing two distinct aspects of vulnerability:
product risks (historical incidents, economic factors, ease of fraudulent
activity, supply chain complexity, and current control measures for
detection) and supplier risks (economic stability and legal status, his-
tory of business, commercial relationships, technical relationships,
technical compliance performance, country of supply regulatory infra-
structure and controls, and country and business ethics). Many sources
of information are presented as support these assessments. The docu-
ment does not prescribe one particular method of “risk assessment,” but
does present examples of a matrix system using the likelihood of oc-
currence and likelihood of current detection, to enable identification of
needed mitigation or control measures. The document provides several
case studies on application of the matrix to example food ingredients
and packaging materials.
Advantages: The format is a guidance document; therefore, it al-
lows flexibility in adapting implementation to the specific needs of an
organization. The example matrices include a proposed scoring system,
which allows ranking of ingredients. The document includes illustrative
examples that demonstrate how to use the matrix system. The guide-
lines also suggest a framework for tracking the overall risk score for
each combination of raw material (or packaging material) and supplier,
the score, team decision, and control measures. This resource empha-
sizes the importance of evaluating potential fraud in food packaging
materials.
Gaps: The demonstrated matrix system uses a combination of in-
gredient and supplier risk factors. Therefore, the process may be cum-
bersome for organizations with a large portfolio of ingredients and
suppliers. This process does not explicitly include economic or con-
sumer health impacts in the evaluation. Finally, there is no discussion of
whether or how to group ingredients to reduce the workload for com-
panies with a large portfolio of ingredients.
3. Consensus of procedures for implementing a food fraud
vulnerability assessment
The following discussion aims to leverage this review of currently
available FFVA approaches, presented above, towards the identification
of areas of consensus among them. This summary of areas of consensus
can offer a possible starting point for multi-stakeholder processes or-
ganized at the international level (possibly within Codex or other or-
ganizations) as recommended by recent multi-stakeholder discussions
(Godefroy et al., 2020).
Although the three resources described above outline different
concepts and procedures for implementing a FFVA, there are common
themes among all of them. The basic procedure for conducting an as-
sessment consists of the following steps:
1. Gather the team that will be responsible for conducting the assess-
ment and developing mitigation strategies
2. Gather all relevant information to be used in the assessment (in-
gredients, products, packaging materials, suppliers, etc.) and im-
plementing grouping, if applicable
3. Conduct a vulnerability assessment
4. Develop and implement a mitigation plan
5. Routinely monitor, review, and refine the vulnerability assessment
and mitigation plan
Each step is discussed in more detail below.
V. Barrere, et al.
3.1. Gather the team that will be responsible for conducting the assessment
and developing mitigation strategies
There is general consensus that the team responsible for conducting
vulnerability assessments and implementing a mitigation plan should
be multi-disciplinary. If applicable, the board of directors may take a
leading role and assist the team with providing information and en-
suring this process if part of the long-term vision of the company. The
food safety and quality assurance departments will likely play critical
roles as they manage food safety risks and oversee quality assurance
specifications. Two other important departments may be purchasing
and research and development, since they are responsible for procuring
raw materials and developing and managing recipes.
3.2. Gather all relevant information to be used in the assessment
(ingredients, products, packaging materials, suppliers, etc.) and
implementing grouping, if applicable
Information to compile could include a description of each material
including the name, the supplier or distributor, the composition, the
specifications, and the products in which it is used. If a company also
plans to track finished products, recordkeeping may include the names
and contents of all the finished products, the clients they are shipped to,
and other relevant information for tracking. Both the USP Food Fraud
Mitigation Guidance and the SSAFE tool recommend the option of
grouping ingredients or materials, and conducting the vulnerability
assessment at the group level, as a way to reduce the workload for
organizations with a large portfolio of raw materials. As noted above,
USP recommends grouping by “class” (oils, spices, dairy ingredients,
etc.). SSAFE notes that users may want to conduct an analysis based on
“product groups,” but does not indicate how these groups may be
formed.
3.3. Conduct a vulnerability assessment
The resources outlined above differ with respect to the details of the
approach to a vulnerability assessment. However, although the ap-
proaches appear different, they generally result in an overall evaluation
of similar factors that can contribute to fraud vulnerabilities. The
criminology concepts referenced by SSAFE (opportunities, motivations,
and lack of control) are inherent in the factors suggested by both USP
and IFS (such as economic factors or the effectiveness of analytical
testing programs in place).
Food safety issues should be the priority of the team implementing a
vulnerability assessment. Part of the assessment should include an
evaluation of the potential public health impacts. In addition, the as-
sessment may include an evaluation of potential economic impacts.
Fig. 1 is an example of how the frameworks described in each re-
source relate to each other. The general consensus is to consider a range
of factors that could drive food fraud motivation, opportunity, and lack
of (gaps in) controls and to document the evaluation of those factors.
The question of whether the approach stems from the perspective of
criminology concepts or the contributing factors that underlie fraud can
be left to the discretion of the team conducting the assessment.
3.4. Develop and implement a mitigation plan
Once the potential vulnerabilities are identified, a mitigation plan
should be implemented to prevent and control the risks of fraudulent
ingredients or products progressing through the supply chain and into
final products.
As noted above, existing food fraud controls may be documented as
part of the vulnerability assessment or, in some cases (such as under the
IFS framework), existing controls may be documented as part of the
mitigation plan. In situations where additional controls are warranted,
the team should identify those measures. Control measures will vary
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Trends in Food Science & Technology 100 (2020) 131–137
depending on the specifics of the ingredient and supply chain, but may
generally include measures such as targeted laboratory testing, supplier
auditing, or changing ingredient suppliers.
3.5. Routinely monitor, review, and refine the vulnerability assessment and
mitigation plan
The FFVA should be routinely reviewed and updated as needed. Due
to the nature of food fraud vulnerabilities, this may need to take place
more often than a HACCP plan review, for example. Situations that
should prompt a review of the FFVA and mitigation plan may include
the development of a new product or claim on a product, sourcing a
new ingredient, geographic-specific economic or political factors, or
market intelligence.
4. Limitations in food fraud mitigations
Although there are tools and resources available for conducting
FFVAs, this is an emerging field and there remain some general areas
where additional guidance and development of collective leadership at
the international level is warranted.
4.1. Appropriately grouping and prioritizing products/ingredients
Although grouping products/ingredients is mentioned as one pos-
sible solution to reduce the time and resources needed for a FFVA, a
range of possible options is presented without clear guidance on what is
the most effective from a risk assessment perspective. The resources we
reviewed indicated that ingredients can be grouped by class, by vul-
nerability, by supplier or wholesaler, or by country of origin. Final
products can be grouped by client, transporter and wholesaler, or
country of destination. The grouping and prioritization will likely de-
pend on the products/ingredients, the supply chain structure, and the
priorities of the team conducting the assessment. Spink, Moyer, and
Speier-Pero (2016) proposed a basic matrix based on market/region vs.
product/group that may be used as an “initial screen.” However, even
in this example, there is quite a bit of room for interpretation in terms of
what constitutes a product “group” and what classifies as a market/
region. For example, does it make sense to group all dairy products
together? Or might it be more logical (from a potential risk perspective)
to group powdered products sourced internationally separately from
liquid milk sourced domestically?
4.2. Evaluating the vulnerability of multi-component finished products
FFVA tools are mainly designed for evaluating incoming ingredients
and products. However, GFSI requires an evaluation of the potential for
fraud in final products. Therefore, assessing the ethics and the economic
and legal status of the clients, the transporters, and the intermediaries
within the entire supply chain should be performed as part of a FFVA.
However, it remains unclear to what extent upstream suppliers may be
held responsible for downstream fraud acts, and to what extent up-
stream suppliers have the ability to mitigate against fraud that occurs
downstream of their direct control. It would be challenging for one
entity to fully control the fraud risks in both the upstream and down-
stream supply chain. Fraud risks in a given ingredient are generally
better controlled earlier in the supply chain and before inclusion in a
multi-component food product. A holistic supply chain program will
rely on contributions from all parties in the supply chain, with re-
sponsibility on any one entity to evaluate their direct suppliers and
customers in addition to any relevant intermediates (wholesalers or
transporters). However, the company could document potential gaps
and corresponding controls within the upstream and downstream
supply chain beyond their direct suppliers and clients.
V. Barrere, et al.
Fig. 1. Overview of food fraud vulnerability assessment process as described in three resources: SSAFE, USP, and IFS.
4.3. Collecting and evaluating supporting data
Each resource reviewed here cites various sources of information
that can support FFVAs, including databases of food fraud-relevant
information. There are generally two types of food fraud-relevant da-
tabases: databases of records (such as incidents, occurrences, or noti-
fications) and databases of reference information specific to a food
commodity (such as compositional databases or spectral databases
based on authentic materials).
Food fraud record databases may be used to support the evaluation
of historic incidents of fraud or notification of regulatory action.
Manning and Soon (2019) have presented an extensive description of
these databases. Record databases have several limitations and should
be used in conjunction with an evaluation of the other required factors
in a FFVA. Record databases generally reflect what has been reported
and, therefore, underrepresent food fraud risk in new ingredients or
those that have not risen to researchers’ or regulators’ interest. Most
existing record databases require a subscription fee, which could re-
present a non-negligible cost for a small or medium-sized business.
(Currently, there are not regulatory or GFSI requirements to access
these subscription-based databases).
Compositional databases, on the other hand, can be both generated
by and used to support laboratory testing and authentication of food
ingredients or products. They can be particularly useful for products
such as honey and olive oil that can vary widely in their constituents
and flavor profiles and benefit from source-based marketing. These
databases compile a wide range of representative samples that can be
used to determine whether a new sample fits within that range or is
outside of it (and, therefore, may contain a fraudulent component). One
publicly-available DNA-based database that has been widely used for
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Trends in Food Science & Technology 100 (2020) 131–137
seafood identification is the FISH-BOL database (Hanner, Becker,
Ivanova, & Steinke, 2011). However, many of the databases developed
based on nuclear magnetic resonance (NMR) testing are privately-held.
There has been much discussion at meetings with international experts
on food fraud about the creation of such databases as public goods, to
be made accessible to all partners and stakeholders. This effort could be
supported by international organizations such as FAO, GFSI, and gov-
ernments. The resulting databases would be viewed as accepted and
validated source of information to support FFVAs and laboratory
testing. This effort would not be successful unless it was widely sup-
ported by all stakeholders, willing to supply a wide range of food fraud-
relevant data from existing databases, laboratories, food industries, and
governments and their associated testing and surveillance programs.
4.4. Evaluating potential public health and economic impacts
Both the USP guidance and the SSAFE tool specifically indicate that
the potential health impact of food fraud on consumers should be ad-
dressed when undertaking a FFVA. However, anticipating potential
food safety impacts resulting from food fraud can be challenging. There
are many different contaminants (biological, chemical, physical) that
could be introduced in an ingredient at various points in the supply
chain, some of which may not be anticipated based on the information
found in databases, experience, or other research. Economic impacts to
a company or other stakeholders can be assessed in term of money
(recall, sales decrease, or legal fees) and reputation (consumer trust).
Although some of the resources recommend that these potential im-
pacts be assessed, either at the beginning of a FFVA to determine
priorities or as part of the overall assessment, there remains the op-
portunity for further development of targeted guidance for effectively
V. Barrere, et al.
evaluating the impacts of food fraud, especially in the area of consumer
health.
4.5. Resource constraints at small/medium-sized companies and in
developing countries
Although food fraud requirements have been in place for a few
years, it is still a relatively new area of focus and some companies are
still coming up to speed. A lack of training in food fraud prevention and
fraud detection methods represents a real impediment to FFVA im-
plementation and success. However, this training could represent a
considerable cost for small and medium companies. Universities have a
critical role to play in disseminating food fraud training; Michigan State
University created a freely-accessible Massive Online Open Course
(MOOC) to provide tools and information on food fraud management
(Michigan State University, 2019). Another potential impediment is a
lack of translation of resources into languages other than English. The
SSAFE tool is currently available in 11 languages and the USP Guidance
is available in Mandarin, but some resources are only currently avail-
able in English. Implementation of a FFVA process throughout the
global food industry is a long-term challenge. Consideration of resource
constraints and language barriers should be taken in account if a global
guidance is developed.
4.6. Understanding and creating standards for analytical detection methods
for fraud
Analytical detection methods are one tool that can be used to both
detect and deter fraud; however, results from a food industry survey
(Guntzburger et al., 2020) indicated that many in the food industry do
not actively apply nor understand these methods. There are a wide
range of methods which usually need to be tailored to a particular food
matrix and adulterant (or set of adulterants). Non-targeted methods are
evolving and show much promise for detecting a wide range of possible
adulterants and serving as “screening” methods. Many food companies
outsource ingredient testing (for quality assurance, safety, and fraud) to
third party laboratories that use proprietary methods. One of the big
challenges in this area is that there are very few detection methods that
have been globally validated for food fraud detection. AOAC has re-
cently followed up on its Presidential Taskforce on Food Fraud with an
ongoing program that aims to define the standards that a food fraud-
focused detection method should fulfill to be validated.
4.7. Evaluating fraud vulnerability in food packaging
Food packaging can be subject to fraud, and assessing and miti-
gating the risk of packaging fraud is also a GFSI requirement. Several
types of packaging fraud could occur, including misrepresentation of
grades, composition, functionality (such as gas controlled), claims (such
as food-grade), or the undeclared presence of contaminants (such as
allergens). The IFS guidance specifically addresses packaging fraud.
However, the teams responsible for overseeing food safety and quality
often do not overlap with those that have expertise in food packaging.
In addition, food fraud record databases often lack information on food
packaging fraud. Research into understanding and providing guidance
in the area of fraud in food packaging materials should be further de-
veloped to better support consumer safety and compliance with GFSI
requirements.
5. Conclusions
Food fraud vulnerability assessment tools and resources have been
developed to assist FBOs and other stakeholders in conducting assess-
ments. However, various factors have limited certain FBOs (particularly
small- and medium-sized enterprises) in their ability to effectively un-
derstand what is required from them for food fraud prevention and in
136
Trends in Food Science & Technology 100 (2020) 131–137
fully implementing a FFVA. This paper aimed at describing what has
been developed to date in the public arena, identifying and discussing
areas of consensus, and documenting the gaps that still exist in the
FFVA process. The goal of this publication was to compile and sum-
marize this information in support of possible future multi-stakeholder
discussions about the development and validation of an internationally-
recognized FFVA process by organizations such as FAO or the Codex
Alimentarius Commission.
Development of an internationally-recognized process would enable
the food safety community to rely on a validated process, similar to
HACCP that was adopted as a reference for food safety prevention by
the Codex Alimentarius Commission. However, given that food fraud
prevention is substantially different from prevention of process-based
chemical or microbial contamination, guidance on a FFVA approach
should most likely be kept separate from HACCP guidance and the two
systems be implemented in parallel.
Development of a globally-recognized vulnerability assessment ap-
proach would support food regulators in their efforts to offer guidance
to the regulated sector, should their regulatory policy around fraud
evolve towards mandating such measures. However, successful devel-
opment of a flexible and adaptable approach would also be dependent
upon active participation by food industry groups.
Food fraud management should be considered a non-competitive
issue and will require pooling resources, enhanced information and
data sharing strategies, and global partnership efforts to develop miti-
gation measures that are truly proactive.
Declaration of competing interest
None.
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