Codex and Food Fraud: Public Comments for Their Electronic Working Group, Fifth Draft

Attached you will find our response to the US Codex Delegation’s request for public comments to the Codex Alimentarius (CODEX) Electronic Work Group (EWG) on Food Fraud. The most recent draft discussion paper remained focused on defining the core food fraud concepts and emphasizing prevention.

To review our public comments, see: Current CODEX Food Fraud Discussion Draft Version. Feel free to respond to us if you have any questions or would like to provide additional comments.

Over the years, the CODEX food fraud work has evolved and has recently been formalized. Remember, food fraud was only first defined in an academic journal in 2011. Also, the food industry’s food fraud requirements were only enacted in 2018 in the Global Food Safety Initiative (GFSI) benchmarking document. The CODEX food fraud scope and direction have evolved since it was first on the meeting agenda in 2016 (CX/FL 16/43/2-Add.1). This Proposed New Codex Work recommendation was presented at this meeting. (this was a proposal and not yet a formal discussion paper (CRD 8). The formation of an Electronic Working Group (EWG) was approved, and the first formal discussion paper was presented at the 2017 meeting. (I attended the 2017 CCFICS meeting as a part of the US CODEX Delegation. This was the first CODEX meeting where the food fraud topic was a formal agenda item.) In 2018, the US became the project’s Chair with Co-Chairs of the European Union and Iran (Islamic Republic of).

The CODEX food fraud work has had many expansions and contractions between the start and the current position. It is natural and appropriate that an international body such as CODEX explores many aspects of a topic. The original proposal identified food fraud as an essential topic and recommended that CODEX consider what and how to address the problem. The work quickly expanded beyond definitions and establishing the basic concepts to exploring methods for assessing the problem and testing methods to confirm the authenticity. Over time, this broad scope narrowed down to defining the terms and scope. The recent drafts have expanded a bit to emphasize the focus on prevention and reducing vulnerabilities. The current document is getting very efficient in providing a global, harmonized, consensus-based definition of food fraud, the types of fraud, and the focus on food fraud vulnerability assessments. The CODEX mission starts with food safety, food security, and support of the related trade. The CODEX food fraud scope is harmonized with the CODEX mission and the current global best practices that are already being refined.

Our Public Comments

Our new public comments focused on several key points (with more details in the attachment):


  • The discussion draft seems very close to being complete. As the scope has narrowed to the more basic terminology – rather than expanding into recommended responses – there have been fewer and fewer comments or edits.
  • The updated draft has continued the helpful shift from reaction to a proactive focus on prevention. The document has continued the shift from recommended actions to the more efficient and basic starting point of the definition of terms and the general emphasis on assessing and reducing vulnerability.


  • First, expand the definitions – or at least add glossary terms – such as adulterant/ adulterate/ adulterated, food security, intentional contamination/ intentional adulteration (food defense), prevention, mitigation, risk, and vulnerability. Fortunately, many codified definitions, such as from the International Standards Organization, can be referenced.
  • Second, while the document has expanded the types of food fraud, it is recommended to include adulterant-substance (a commonly used term that includes substitution, dilution, and concealment), tampering (possibly also clarifying malicious tampering, which is within food defense), and mislabeling or misbranding (as a specific type of misrepresentation).

Takeaway Points:

  • The world is getting close to a definition of food fraud that is codified by an international body. The draft definition is harmonized with the general concepts that are already being implemented.
  • Fortunately, the CODEX scope of food fraud is focused on prevention and vulnerability assessments. The scope and focus are harmonized with the general concepts that are already being implemented.
  • You can play an active role in shaping global food policies by either following our blog post updates or contacting your appropriate country Codex Delegation (


Background Regarding Codex: Codex Alimentarius (CODEX) is the world food code that the World Health Organization and the Food and Agricultural Organization of the United Nations coordinate. CODEX creates a harmonized set of “international food standards, guidelines, and codes of practice [that] contribute to the safety, quality, and fairness of this international food trade.” While CODEX creates reference materials, many countries often accept the documents as their food laws and regulations. In 2016 at the CCFICS22 meeting, food fraud was identified as an important topic, including the need for definitions of terms. In 2017 at the CCFICS23 meeting, an Electronic Work Group convened to address the food fraud topic (FF eWG). In March 2021, the FF eWG updated the Discussion Paper.

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