Review – Codex and Food Fraud: Public Comments and for Electronic Working Group Third Draft

Attached you will find our comments submitted to the U.S. Codex Delegation for consideration in the formal U.S. comments to the Codex EWG that is creating definitions for Food Fraud, Food Integrity, and Food Authenticity. Our team is an active member of the U.S. Codex Delegation.

New Public Comments – Link:


Addressing Food Fraud in Codex Alimentarius is critical to global harmonization of terms and the focus on prevention. The recent Codex meetings discussed Food Fraud but there were no concrete actions. Our Food Fraud Initiative is generating funding to be able to participate in these activities. Building on our years of working with ISO and GFSI, we have a unique perspective on product fraud standards development. We have volunteered with the US Delegation to lead an “Electronic Working Group” or an “Ad Hoc Intergovernmental Task Force on Food Integrity/Authenticity.”

Summarized in a USDA report, Codex Alimentarius Commission (CAC, or more commonly referred to as Codex) was established by the Food and Agriculture Organization (FAO) of the United Nations (UN). The purpose is “protecting the health of consumers and ensuring fair trade practices in the food trade.” Most impactful is that Codex is the international “food code” and is “THE” food law for many of the over 180 member countries. The activities and direction are presented in the Codex Procedural Manual.

Public Comments to US Delegation  – New Comments for September 2018

FOOD INTEGRITY AND FOOD AUTHENTICITY – Comments for the Third Draft Published August 2018. For reference, we have also included Appendix Two that presents the evolution of the Food Fraud definitions.

  • For “Section: Title” Overall title wording: The title is confusing and does not directly mention the food fraud concept.
  • Recommendation: change the title to at least include the term “food fraud.”
  • For “Section 2.3” Definition of Food Fraud: Edits are recommended.
  • Recommendation: a new proposed text is noted. To: “Any deliberate action of organizations businesses or individuals to deceive others FOR ECONOMIC GAIN OR AVOIDANCE OF AN ECONOMIC LOSS in regards to the integrity of food to gain undue advantage. Types of food fraud include but are not limited to: adulteration, substitution, dilution, tampering, simulation, counterfeiting, and misrepresentation.
  • For “Section 2.3” Definition of the types of food fraud:
  • Recommendation: Each type of food fraud should be defined at least in a glossary including: adulteration, substitution, dilution, concealment, unapproved enhancement, substitution, dilution, tampering, simulation, counterfeiting, product overrun, theft, diversion, and false or misleading statements made about a product.
  • For “Section 2.1” Definition of Food Integrity: The current definition does not explicitly include food safety and health hazards.
  • Recommendation: alternate text is proposed. To: “The status of a food product where it is authentic and not DEFICIENT, HARMFUL, altered or modified with respect to expected characteristics including, safety, AUTHENTICITY, quality, and nutrition.”
  • For “Section 2.2” Definition of Food Authenticity:
  • Recommendation: alternate text is proposed. To: Food authenticity is the quality of a food to be genuine and undisputed in its nature, origin, identity, and claims, and to meet expected properties”.
  • For “Section 2”, To include a definition of adulterant and adulteration.
  • For “Section 2,” To include an overall explanation of how all the terms are related.
  • Recommendation: It would be helpful to explain the relationship between the terms such as specifically how food fraud and food integrity are different. Also, how food authenticity is achieved related to food fraud and food integrity.
  • For “General Comments,” Several of the terms used in the definitions are not defined.
  • Recommendation: Provide definitions of terms that are used to define key concepts such as Food Integrity and Food Authenticity including: Authenticity/ authentic, Authentication, Identity/ identify, origin/ undisputed origin and material good/ good/ product.

International standards are critical to harmonization of terms and a common focus on prevention. We have experienced great benefits from being involved as the Chair of the US Delegation to International Standards organization Technical Committee 247 on (Product) Fraud Countermeasures and Controls (ISO TC 247). Every standard cannot address every issue but there are important foundational steps such as ISO – and Codex – at least creating definitions. We are thankful for funding that will allow us to engage the Codex Food Fraud questions.

The Codex Alimentarius world food code is constantly evolving and the Food Fraud EWG is evidence of the level of international engagement and collaboration. Please take part in the Codex process through your company or national bodies. Also, please review our document and provide your comments and insights directly to us.

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