Codex and Food Fraud: Public Comments for their Electronic Working Group, Fourth Draft

Attached you will find our response to the US Codex Delegation request for public comments to the Codex Alimentarius Electronic Work Group on Food Fraud. The most recent draft discussion paper has a noticeable shift to core food fraud concepts and prevention. To review our public comments, see:

Background Regarding Codex

Codex Alimentarius (CODEX) is the world food code that is coordinated by the World Health Organization and the Food and Agricultural Organization of the United Nations. 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, the documents are often accepted by many countries 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.

Current Draft Version

Over the years, the CODEX food fraud work has evolved. Remember, food fraud was only first defined in an academic journal in 2011. Also, the food industry food fraud requirements were only formalized in 2017 in the Global Food Safety Initiative (GFSI benchmarking document). There has been a lot of innovation and adaptation from the start of the CODEX work and the current state. Along the way, in 2018, the US became the project’s “host country” with “co-host countries” of European Union and Iran (Islamic Republic of). This draft version is an evolution that shifts to a more traditional food fraud focus and places more explicit emphasis on prevention.

Public Comments

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

  • The focus on prevention in addition to the importance of testing and detection.
  • Clarify all terms and definitions including adulterant and contaminant.
  • Expand to include animal feed and other related products.
  • Retain a focus on first defining the terms and concepts and not expanding into implementation and management details or guidance (the food fraud draft document has been in editing for seven years already).
  • Continue to harmonize terms and concepts with other international standards such as ISO 31000 Risk Management, ISO 22380 Product Fraud Prevention, and ISO 28000 Supply Chain Security.

CODEX has a critical role in food fraud prevention due to the opportunity to create a published, global, consensus-based definition of the term and application. While the process may seem very slow, a key is that it is a methodical and formal approach. Follow the summaries in our website and blog or contact your appropriate country Codex Delegation (


CODEX, Codex Alimentarius, (2021). Discussion Paper on Role of CCFICS with Respect to Tackling Food Fraud in the Context of Food Safety and Fair Practices in Food Trade – Updated, March 2021, Electronic Work Group on Food Fraud, URL:

Spink, John (2021). Comments to the US Codex Delegation for the Food Fraud EWG Discussion Document, URL:

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