GFSI Food Fraud Requirement Update for Year Five

Can you believe the GFSI food fraud requirements are five years old? Has there been a lot or a little progress? Both. The strategies, vulnerability assessments, audits, and management oversight were just starting to mature as COVID shut down business operations. I recently presented “Food fraud prevention: three years of GFSI and where are we?” in the DNV company’s Food Safety webinar series. We are now in year five since GFSI implemented the food fraud requirement in January 2018. It was interesting to reflect on ten years of some key GFSI milestones.

GFSI Food Fraud Milestones

  • 2021, March – Delay of focus on food fraud strategy implementation as COVID disrupted normal business operations. Proactive projects that were delayed included the updating the food fraud prevention strategy to fully functioning management systems.
  • 2020 – GFSI Benchmark Document version 2020 continued to include food fraud prevention as a crucial and critical part of a comprehensive food safety management system.
  • 2018, May – The publication of the GFSI Food Fraud Technical Document: This was announced in the GFSI blog post by Vice-Chair Gillian Kelleher. The GFSI technical document on “Tackling Food Fraud Through Food Safety Management Systems” (referred to more commonly as the “GFSI Food Fraud Technical Document”) was created to summarize and reinforce the primary goals and concepts.
  • 2018, March – At the annual GFSI Conference, I moderated and presented in the breakout session on “Food Fraud Compliance Challenges and Successes.” This session highlighted some confusion or lack of buy-in on the food fraud requirements. This helped to raise the industry-wide understanding of the topic and that it was valuable for protecting the food supply chain.
  • 2018, January – This was when the food fraud requirements were implemented.
  • 2017 – This was when the food fraud requirements were announced in the benchmarking document version 7.
  • 2014 – The publication of the “GFSI Position on Mitigating the Public Health Risk of Food Fraud”(referred to more commonly as the “GFSI Food Fraud Position Paper).
  • 2013 – The horsemeat in beef incident intensified and focused our mid-project GFSI Food Fraud Think Tank research.
  • The GFSI mission addresses the root causes of unsafe food, and food fraud is a potential vulnerability.
  • 2012, July – Members of the GFSI Board of Directors created a food fraud think tank to review “what” is food fraud “if/ how” should GFSI address the problem. I stated “If/ how” because there was extensive debate about if food fraud should be required in a food SAFETY management system.
  • 2012, February – At the annual GFSI Conference, I presented “GFSI Direction for Food Fraud Prevention.” I recommended how the food industry, led by the GFSI benchmarking requirements, could efficiently and holistically address food fraud in a food safety management system. This was a part of a breakout session on “Food Fraud- What You Need to Know.” Rick Roop of Tyson was the moderator, and other presenters included Tim Jackson from Nestle and Dong Qiao of the China Certification & Accreditation Institute (CCAI).
  • For reference: It was in November 2011 when food fraud was first formally defined, since it was the research question addressed in a peer-reviewed, refereed, scholarly journal article.  This included an explanation of the multi-disciplinary approach that focused on understanding and reducing the fraud opportunity. This approach enabled the shift from detection to prevention. (For more, see Spink, J, Defining the Public Health Threat of Food Fraud, Journal of Food Science.)
  • For reference: In September 2014 the “Elliott Review into the integrity and assurance of food supply networks: final report” was published. This was a UK DEFRA-funded review of the UK food fraud vulnerabilities and recommended prevention strategies. This was the first major country-level review of the food fraud vulnerability.

Food Fraud Prevention

GFSI taking the lead and creating common requirements for the food industry was the critical step. This harmonized GFSI approach has led the food industry to be the most efficient and effective industry in fighting product fraud. No other industry has such a harmonized approach, such as using the same terms and specific methods. No other industry has such holistic adoption -food fraud prevention is a requirement for all food commerce (since a food safety management system is required, and the standards now include addressing food fraud).

This harmonized and focused approach enables efficient and quick benchmarking and sharing of best practices. The common set of GFSI requirements encourages the rapid development of tools and resources that precisely meet industry needs. For example, the SSAFE Food Fraud Vulnerability Assessment Tool was created in 2016 after the GFSI requirements were defined in 2014 and long before the required implementation in 2018. There was subsequent training published in 2018. In addition, our scholarly research could be adapted to Food Fraud MOOC (free, massive open online course) training that has been continuously offered since 2013. (See

Increased Efficiency and Process Improvement

The GFSI harmonized and focused food fraud prevention requirements have led to process improvement and refinement in research, training, and implementation. There is more capability- and capacity-building across the entire food supply chain. More companies are more confident in implementing and managing their food fraud prevention strategies. The sharing of best practices has led to the refinement of programs to protect the food supply chain precisely and efficiently.


Coming out of COVID (hopefully), there is a slow shift from “assurance of supply” back to proactive measures such as reducing the vulnerability from food fraud. It is essential to take a moment to remember how and why the GFSI food fraud requirements developed and evolved. To “just get started,” a first step is doing a simple, high-level food fraud vulnerability assessment and start addressing the worst problems.

When I presented “Three years of GFSI and where we are?” I realized that we are at a point where simple vulnerability assessments are becoming actual management systems. The integrated and coordinated activities will significantly reduce the fraud opportunity. GFSI is helping create the path, and we are all leading the effort forward.

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