After nearly a decade and repeated rounds of public comment, Codex’s food fraud definition is finally consistent, harmonized, and ready for publication. We have submitted comments to the U.S. Codex Delegation recommending finalization of the draft Guidelines. Our comments and full supporting report follow below.
To review our public comments, see: https://blog.foodfraudpreventionthinktank.com/wp-content/uploads/2026/08/CODEX_FF_EWG_Comments_US_Delegation_August_5_2026_-v9-FINAL.pdf
A Consistent, Harmonized Definition
Since the Codex Food Fraud Electronic Working Group (EWG) began in October 2017, the Food Fraud Prevention Academy (FFPA) has submitted seven formal rounds of public comment to the US Codex Delegation on the Codex Committee on Food Import and Export Inspection and Certification Systems’ (CCFICS) Food Fraud Electronic Working Group (EWG): October 2016, September 2018, November 2019, April 2021, April 2022, January 2023, and March 2025. Across those submissions, the work moved from a broad discussion of food integrity and food authenticity toward a defined set of Draft Guidelines on the Prevention and Control of Food Fraud. Our consistent position throughout: Codex should first finalize a harmonized definition of food fraud, supported by a concise glossary, before expanding into testing methods, national control systems, or detailed implementation.
By 2023 and 2025, our comments grew more supportive and narrower, a signal the draft was approaching completion. On August 5, 2026, in response to CL 2026/77-FICS, comments were submitted on the Draft Guidelines now at Step 6/7 — meaning the text has been circulated to Members and Observers for comment and returned to committee for revision. If finalized, it advances to Step 8 for possible adoption at next year’s Commission session.
Answering Codex’s Three Questions
The August 5 submission responded directly to the three questions Codex posed to delegations.
- Feed for food-producing animals: The recommendation was affirmative that the current scope appropriately recognizes and includes feed where it affects food safety or leads to food fraud.
- Definitions of Food Integrity and Food Authenticity: Our recommendation was affirmative that both definitions should be retained, since they clarify their relationship to food fraud and preserve the conceptual history of the work, which began under that framing.
- Further Government Obligations: On Sections 6 and 7, which allocate responsibilities to competent authorities and food business operators, the recommendation was to finalize them as written; they provide a practical, prevention-focused division of responsibility.
- Comment on the Food Fraud Scope: A deep review supported that the Codex working definition of food fraud is consistent and highly aligned with GFSI and prevailing formal definitions. The current wording is appropriate and should be retained unchanged. No textual revisions are warranted, and reopening the definitions could delay finalization without providing a proportionate benefit.
- Food Faud Definition (Codex, Working Definition, Aug 2026): “Any deliberate practice intended to deceive others in regard to the characteristics of food to gain an unfair economic advantage.”
No Revisions Recommended
The overall recommendation was to finalize the draft as-is. The definitions, types of food fraud, principles, and assigned responsibilities are aligned with established practice, and reopening wording that is already substantially settled would risk another comment cycle — potentially delaying final publication by a year or more without a proportionate benefit. Several editorial wording nuances were flagged for future drafting consistency, but none rose to the level of a material flaw. A separate recommendation proposed adding a note in the Codex Procedural Manual documenting the EWG’s definitional work.
- Codex Procedural Manual (2025)
- Section 2.6 Format for Codex commodity standards — Essential composition and quality factors
- Paragraph 90: “This section should contain all quantitative and other requirements as to composition including, where necessary, identity characteristics, provisions on packing media and requirements as to compulsory and optional ingredients. … It should also include quality factors which are essential for the designation… with the object of preventing fraud.” [7]
- Proposed New Footnote 7: “The reference to “preventing fraud” in this paragraph implicitly includes food fraud. Food fraud means: “Any deliberate practice intended to deceive others in regard to the characteristics of food to gain an unfair economic advantage. (Working Definition, FF EWG, Guidelines on the Prevention and Control of Food Fraud, as of August 2026).
After nearly a decade of engagement, the Codex Draft Guidelines on the Prevention and Control of Food Fraud are ready to move forward without substantive change.
Takeaway Points
- A harmonized, consensus definition of food fraud is more valuable to the global food system than further delay in pursuit of perfect wording.
- Six rounds of public comments since 2018 show that patient, consistent engagement can move an international standard from concept to near-completion.
- Support finalization of the Draft Guidelines as written and engage your own country’s Codex delegation to reinforce the case for adoption.
Reference:
SPINK, John W. (2026). Comments to the US Codex Delegation on the Draft Guidelines on the Prevention and Control of Food Fraud at Step 6/7 (August 05, 2026), Food Fraud Prevention Academy, URL: https://blog.foodfraudpreventionthinktank.com/wp-content/uploads/2026/08/CODEX_FF_EWG_Comments_US_Delegation_August_5_2026_-v9-FINAL.pdf