Preliminary Results – Food Fraud Annual Update Survey: Some Simple Adjustments and a Crucial Revelation

The preliminary results from our Food Fraud Annual Survey show progress, but also some concerning compliance gaps. Most of the issues – such as fully documented compliance, executive sign-off, and formal incident review methods – can be addressed quickly. Overcoming over-confidence will be a challenging paradigm shift.

PLEASE PARTICIPATE – the survey is still open:

Our ‘Food Fraud Annual Update’ Survey was intended as an annual review starting in 2019 but was delayed due to COVID. It restarted in 2023.

This survey research project aims to understand the current state of Food Fraud Prevention compliance. This informs the content of new research projects and training programs. The Food Fraud Annual Update Survey provides the key agenda emphasis for our Food Fraud Annual Update Professional Education workshop. This survey is intended as an annual update to review the trends over time.

General Findings

The preliminary research findings will first be reviewed below in clusters of topics, including overall compliance, executive approval, incident review method, and then the role of suppliers.

Compliance – only 46% of the respondents are completely confident they are fully compliant (Q14 to 20): Would you be comfortable telling your customer (or your boss) that you’re not confident you meet the Food Safety Management System compliance requirements? RECOMMENDATION: This finding is a bit baffling since there has been so much food fraud compliance activity in the marketplace. Basically, more guidance and training would increase the awareness of the exact compliance requirements and the methods to meet those expectations.

Executive Approval – only 33% are 100% confident of ‘sign off’ or ‘approval’ by an executive or senior officer of the company (Q19): This is only a formal compliance requirement for one of the food safety management standards, but it is usually a requirement for more formal enterprise risk management compliance (e.g., US Sarbanes Oxley Act or the US DOJ Evaluation of Corporate Compliance Programs). Note: while this might seem like ‘just a signature,’ the company’s officers realize they are making a formal and legal statement that their actions are revised, approved, and certified as compliant – they do not make these statements lightly. So, requiring an executive signature is simple, but it also provides tremendous formality to the statement. RECOMMENDATION: Food companies should simply ask for or require their suppliers to include ‘executive approval’ of any risk assessment or prevention program.

Incident Review Method — 50% are 100% confident in their method to identify and assess new food fraud incidents (Q21): This is a surprisingly high percentage which is great unless their expectation for a thorough process is too simple or narrow – for example, does it include finished goods in the marketplace or return fraud? RECOMMENDATION: covered in the other recommendations.


Within the survey, it became apparent that there were different needs for suppliers and food manufacturers.

Suppliers – a seeming lack of awareness of their food safety management system requirements: Suppliers to the food industry often seem not to be aware that they are ‘food suppliers’ and in the ‘food industry.’ There appears to be a lack of awareness of the food fraud compliance requirements and, more broadly, a lack of understanding of the Food Safety Management System requirements. RECOMMENDATION: food companies should clearly define the compliance expectations of their suppliers – if GFSI-type compliance is required – and then clarify the details and recommend professional education.

Compliance Overconfidence

Most respondents responded that, ‘yes,’ they were compliant. The survey questions covering background topics – such as reviewing the scope of the types of food fraud that the address – revealed that the risk assessors are generally overconfident and actually not fully compliant. Specifically, most of the Food Fraud Prevention Strategies did NOT cover the entire GSFI scope – which means that most companies are not fully compliant with the GFSI food fraud requirements.

Overconfidence Due to Scope Confusion – only 24% of respondents cover the entire GFSI Scope: There seem to be several types of food fraud assessments that are conducted to meet separate requirements. That means that the people managing food fraud are generally aware of the full compliance requirements – or their companies only assign the task to a group with a limited scope of activities. For example, only 88% of the respondents consider adulterant-substances – this is usually the main or only type of food fraud covered. Intellectual Property Rights Counterfeiting and theft are clearly defined with the GFSI scope, but only 55% and 41% of the respondents cover these issues. More research is required, but it appears that food fraud is only being addressed by one functional group – or groups that are not communicating – within a company. Even mislabeling had a relatively low coverage rate of 76% — mislabeling is often the most prevalent type of food fraud in customs incident reports. E.g., a supplier quality assurance group may fully cover raw materials for incoming goods. Still, there is no follow-up to address problems in commerce, such as gray market, theft, diversion, or counterfeiting.


Summary of the Results and Discussion – the Food Fraud Prevention programs are maturing, but most are not yet fully compliant: Companies have started, and the increased experience and expertise of the users have increased awareness of program or method gaps. In most cases, the gaps can be quickly and thoroughly resolved with a clear understanding of the compliance requirement and clear methods to complete the tasks.

Takeaway Points

  • While the food fraud prevention requirements are maturing, significant gaps are leaving the food supply chain vulnerable – and making companies vulnerable to being non-compliant.
  • The full GFSI food fraud scope was defined not to make life difficult but to protect a company and the food supply chain fully – a customer or board of directors needs a company’s entire supply chain to be protected from product fraud.
  • Fortunately, a simple gap analysis should reveal the program’s weaknesses, and there are usually straightforward processes or methods that can lead to full compliance.
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