NEW PUBLICATION – The Current State of Food Fraud Prevention: ‘How to Start?’ and ‘How Much is Enough?’

This invited article was for a special issue of Science Direct on the current state of food safety. This 2019 publication is now free to download. The food fraud prevention update includes a practical recommendation for ‘How to Start?’ and ‘How Much is Enough?’

Link to the free article:

Current Opinions in Food Science and Technology is one of the top Food Science scholarly journals (e.g., Scopus CiteScore 11.8, 96th percentile in Food Science of 12/ 338 publications, SNIP score 1.983 and SJR score 1.379, published by Elsevier). The high impact factor in a peer-reviewed, refereed, scholarly journal is a measure of the rigor of the research and the refinement of the application to the field.

The special issue editors asked me to review the current state of food fraud prevention. Beyond the overall review, they asked me to update our nearly 10-year-old foundational research on the subject. At this time, it was natural to shift from the “what” is food fraud and beyond the “how” to respond to “how to start” and “how much is enough.”

To note, scholars may laugh at a simplistic title, like “How to Start.” This may seem like a basic concept, but it is fundamental to shifting to a management system. A comprehensive decision-making system is based on management practices and enterprise-wide risk tolerances for a company or a country. It is an essential shift from food science and food authenticity, beyond criminology-based root cause research, to actual resource allocation decision-making.

The article started with a review of the basics and the expanded Enterprise Risk Management/ COSO topic. Over the years, the Corporate Board Room has adopted the application of enterprise-wide risk calibration to support front-line decision-making. I provided a more explicit connection between the ERM/COSO and food regulation compliance.

The practical application was laid out in the Food Fraud Implementation Method (FFIM). This method has been refined over the years and was finally formalized and published. After conducting an incident review and hazard identification, the method includes 10 questions, 2 concepts, 7 steps and 1 decision. (To note, the article had seven questions but over time this was later expanded to ten.)

The Food Fraud Implementation Method (FFIM): “How to Start”

Over time, the development of a food fraud prevention strategy has been refined down to several simple questions.

“10 Questions”: For this first pass, the response is just “yes” or “no.”

  1. Have you conducted at least one Food Fraud Vulnerability Assessment (Y/N)
  2. Is it written (and can you show it to me now) (Y/N)
  3. Have you created a Food Fraud Prevention Strategy (Y/N)
  4. Is it written (and can you show it to me now) (Y/N)
  5. Can you demonstrate Implementation (Y/N)
  6. Do you have Executive Level Sign-off (Y/N)
  7. Have you minimally conducted an annual Food Fraud Incident Review (Y/N)
  8. Do you have a method to review your incidents and general market incidents (Y/N)
  9. Note: Do you address all types of Food Fraud (e.g., adulterant-substances, stolen goods, diversion, intellectual property rights counterfeiting, etc.) (Y/N)
  10. Note: Do you address all products from both incoming goods (e.g., ingredients) and outgoing goods (e.g., finished goods) through to the consumer.” (Y/N)

“2 Concepts”:

  1. Concept One—Formally and specifically, mention food fraud as a ‘food’ issue (e.g., in a formally approved and published corporate policy handbook)
  2. Concept Two—Create an enterprise-wide food fraud prevention plan (e.g., this is the Food Fraud Prevention Strategy, and it is the only link between the food fraud incident assessments and calibration with the risk tolerance assessment to the enterprise-wide system)

“7 Steps”:

  1. Convene a Food Fraud Task Force
  2. Create an Enterprise-wide Food Fraud Policy/Mission Statement and begin drafting a Food Fraud Prevention Strategy/Plan
  3. Conduct the pre-filter Food Fraud Initial Screening (FFIS) (e.g., this is a very high-level vulnerability assessment that covers all products across the entire enterprise. One risk matrix or assessment could meet the objective.)
  4. Review additional needs, including additional information or a more detailed Food Fraud Vulnerability Assessment (FFVA) (e.g., in ERM/ COSO terms, this is a “detailed assessment.”)
  5. Review-specific Food Fraud vulnerabilities in an enterprise risk map (Enterprise Risk Management)
  6. Consider countermeasures and control systems to address the ‘very high’ and ‘high’ vulnerabilities (e.g., it is helpful to provide examples of possible countermeasures or control systems. These examples will help calibrate if there is enough information to make a confident resource-allocation decision.)
  7. Propose a Food Fraud Prevention Strategy, including the calibration of the Food Fraud risks on the enterprise risk map (E.g., this should be in a corporate human resources template to facilitate actual resource-allocation decision discussions.)

“1 Decision”:

  • Finally, after the FFPS proposal is submitted, the last step is for management to decide on the optimal plan. It is essential to consider that no decision on the new proposal is a decision – no decision is a decision that accepts the status quo. In some situations, the total resources applied to the problem may be reduced.

Enterprise Risk Management: How Much is Enough

The connection of the Food Fraud Vulnerability Assessment to the enterprise-wide risk assessment leads to a calibration of the problems. The enterprise-wide risk map defines the issues that are above the risk tolerance. The most valuable part of the process is that the same map illustrates when there is “enough” of a risk treatment. Zero risk is not practical and often not even possible.

Takeaway Points:

  • Food fraud prevention is continuing to evolve and mature as a science. An expanding field of study includes some focus on business management systems and supply chain management.
  • With the refined work processes, now is an excellent time to conduct a strategic review of your food fraud strategy. If you have not implemented a comprehensive food fraud prevention strategy yet, you will be able to leap generations of iterations.
  • The theoretical foundation of the Food Fraud Prevention Strategy is becoming a ‘standard operating procedure’ that provides guidance on an optimal – not maximum – system.


Spink, John W. (2019). The current state of food fraud prevention: overview and requirements to address ‘How to Start?’ and ‘How Much is Enough?’, Current Opinion in Food Science, Volume 27, 2019, Pages 130-138, ISSN 2214-7993, [Now open source – free to download], URL:

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