Review of The GFSI Food Fraud Prevention Compliance Development & Requirements: Part 1 – Creation of the GFSI Food Fraud Think Tank

This is the first of three reviews of ‘The GFSI Food Fraud Prevention Compliance Development & Requirements.’ To understand where we need to go, it is helpful to start with why we started the journey and how far we have – or, in many cases, have not – progressed.

Reference: The GFSI Food Fraud Prevention Compliance Development & Requirements: A Ten-Year Review (Revision3, Accepted), Published online 27 July 2023, URL: The article was published in July 2023 and covers a review of the previous ten-years of GFSI activity regarding food fraud prevention. The GFSI compliance requirements were published in February 2017 and required in January 2018, but GFSI started five years earlier with the creation of the GFSI Food Fraud Think Tank in July 2012. This three-part series will start with the overview, then the compliance requirements of VACCP and TACCP, and then present lessons learned from other disciplines that created the GFSI food fraud prevention requirements.


From Page 766:


Ten years ago in 2012, the Global Food Safety Initiative (GFSI) formally reviewed and addressed food fraud as a separate food safety problem. GFSI expanded its focus since food fraud is a root cause of a food safety incident. This historical review was created to document the previous steps and help focus the path forward. The fundamental concepts and direction have not needed to change since, from the start, there was a holistic and all-encompassing approach to dealing with the entire problem and building on an interdisciplinary foundation. The next ten years are predicted to include more formal and rigorous food fraud vulnerability assessments, prevention strategies, and more formalized management system oversight.

From page: 768

Developing Topics Around the Time of the GFSI Food Fraud Think Tank

From 2005 to 2012, initiated by the modern food fraud incidents, there was a renaissance in risk and vulnerability prevention activity. (Frera et al., 2021; Kendall et al., 2019; Lawrence et al., 2022; Onyeaka et al., 2022; Robson et al., 2021; Smith et al., 2022; Théolier et al., 2021; van Ruth et al., 2021) The GFSI Food Fraud requirements explicitly define a way to organize and review the problems through the Vulnerability Assessment and Critical Control Point Plan (VACCP) concept, providing the application of foundational concepts (Figure 1). (Barrere et al., 2020; Cane et al., 2021; Lawrence et al., 2022; Manning et al., 2019; Rezazade et al., 2022; Roberts et al., 2022; Robson et al., 2021; Ulberth, 2020) The food industry was already more organized and had more formal quality management than other industries, with activities such as the HACCP plans that had been developing for 40+ years. The International Standards Organization ISO 9000 Quality Management has been developing since 1987 and became a common practice after the first significant revision in 2000. (ISO, 2015) Quality management kept maturing into rigorous systems such as Six Sigma. Another significant development was ISO 31000 Risk Management in 2009, which created harmonized definitions for terms such as risk, vulnerability, prevention, mitigation, likelihood, and consequence. (ISO, 2009) Other ISO concepts were developed, such as in Technical Committee 247 Product Fraud Countermeasures and Controls (TC 247 and now within TC 292). (ISO, 2010) This was the first-time product fraud, and product fraudsters were mentioned in an ISO document. A significant update was published in 2018 on ISO 22380 Security and Resilience – Authenticity, Integrity, and Trust for Products and Documents (General Principles for Product Fraud Risk and Countermeasures). (ISO, 2018a)

In addition to the ISO activity, there were other standards in development, such as COSO-based Enterprise Risk Management in 2004, and then continuously expanded. (COSO, 2014) COSO was developed to meet the U.S. Sarbanes-Oxley Act requirements related to financial reporting by the U.S. publicly traded companies (and also became a common requirement for all companies). (15 USC 7201, 2006) GFSI was founded to create a single set of benchmark requirements for food safety certification scheme owners to address a wide range of food safety laws and regulations, such as the U.S. Food Safety Modernization Act (FSMA), the European Commission General Food Law, and the Chinese Food Safety Law.

From page: 770

Additional Tools and Resources for Implementation and Training

From around 2009 to 2012, there was a significant increase in the scholarly research focus on food fraud detection and prevention. The early research was led by many, including Queen’s University Belfast (Northern Ireland, UK), Wageningen University (Netherlands), and Michigan State University (United States). Training and tools to facilitate the first steps are critical to implementing a new program. In addition to the scholarly research foundation, training and education were developed starting in February 2013 with the free food fraud Massive Open Online Course (MOOC) programs. (FFPA, 2013)

Further, training and tools were developed to help with implementation, such as the SSAFE Organization publishing their Food Fraud Vulnerability Assessment Tool in January 2016. In early 2017, SSAFE partnered with PWC for the tool to be automated and online. (PWC, 2016; SSAFE, 2015) SSAFE and the Food Fraud Prevention Academy co-developed free online training on this tool.

To create momentum for training and education, the GFSI Food Fraud Position Paper mentioned and supported the SSAFE project: (GFSI, 2014)

“The GFSI Board will support SSAFE’s initiative, which aims to develop and publish practical guidelines for companies on ‘how’ to assess and control food fraud vulnerabilities within their organizations and supply chains. SSAFE is working to have these guidelines available before the release of Version 7 of the Guidance Document so that companies and scheme owners can prepare their organization before the new requirements are effective.”

Over the years, after GFSI compliance was a food industry-wide requirement, it is fortunate that many companies and programs created updated training, education, tools, models, and other resources.

Takeaway Points

  • Due to an ever-increasing awareness of the harm to public health and the economic impact of food fraud incidents, there was a need and action to shift to focus on prevention.
  • The shift from food fraud reaction to proactive response was enabled in part by an evolution in risk research, quality management, and decision sciences that prioritized focusing on identifying and reducing the root cause of problems – looking for and managing vulnerabilities, not just risks (e.g., Food fraud prevention shifts the food risk focus to vulnerability, 2017).
  • Fortunately, there is a significant body of scholarly and academic research that includes some very simple, direct, and helpful training and education (including our Food Fraud Prevention MOOC series – see
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