Review of The GFSI Food Fraud Prevention Compliance Development & Requirements: Part 3 – The Next Steps and Path Forward

This is the third of three reviews of ‘The GFSI Food Fraud Prevention Compliance Development & Requirements.’ This blog post reviews other prevention initiatives and their application to the food supply chain and GFSI. The foundation is set, we’ve made progress, but there is still a long way to go.

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 reviews 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 begin 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.


Lessons Learned from Other Systems Implementation: Quality, Workplace Safety, and Sustainability

The GFSI process for considering and implementing food fraud prevention mirrored other successful programs by focusing on a specific acute problem, taking a strategic level, all-encompassing, and, most importantly, focusing on achievable and straightforward first steps. GFSI took the logical first steps to address the root cause of the entire problem and “just get started.” The first successes are critical in quickly identifying implementation problems and getting momentum. Without the early successes and momentum, the new initiative could be expected to (unintentionally or intentionally) atrophy to the point of “just compliance” or oblivion. Other programs that started broad but light include corporate environmental sustainability, quality management, workplace safety, and repetitive stress injuries.

The GFSI Food Fraud Scope and Focus

After the publication of the GFSI Guidance Document in February 2017 and the compliance requirement a year later in January 2018, a critical follow-up was the publication of the GFSI Food Fraud Technical Document (FFTD) in May 2018. (GFSI, 2018) Six months after the compliance was required, the publication confirmed that the requirements were serious and would not just “fade away.” Some very novel corporate programs or compliance requirements atrophy or stagnate to the point of extinction. While the FFTD did not include any new requirements, it helped the implementation by putting all the information in one official document and clarifying some recent questions.

Conclusions from the GFSI Food Fraud Technical Document (FFI, 2016)

1. Holistic scope – all fraud and all products: The scope is all types of fraud (from adulterant-substances to counterfeits and stolen goods) and all products (from incoming goods through to products in the marketplace, including counterfeits). All types of fraud and all products can cause health hazards and lead to economic harm.

2. Just get started: There is continued emphasis on beginning the process that will be supported by continuous improvement and sharing of best practices.

3. Auditors are to confirm the process and not judge the plans: To begin the compliance, the scope is to confirm the process is started.

One of the most helpful resources was the “Detail of Type of Fraud and Examples” (Table 4). (GFSI, 2018)

The GFSI response to food fraud is applied within the food safety management system context. Based on that context, the food company focuses on assessing and protecting its product and supply chain from food safety hazards. This company-level focus efficiently supports individual resource allocation decision-making. The food fraud vulnerability assessment is evaluated based on the economic impact on the company. While reducing the vulnerability of food fraud incidents that could create food safety hazards is the focus, this effort provides a collective protection of the entire food supply chain. For example, one aspect of food fraud prevention focuses on correct labeling, including protected designated of origin (PDO). The fraudulent statement of the country of origin could fall under mislabeling, trademark imitation, or intellectual property rights infringement counterfeiting. The increased focus on all types of food fraud provides a diffusion of benefits to even small and medium-sized enterprises.

Although not a consideration during the GFSI Food Fraud Think Tank work, the more rigorous focus on mislabeling applies to environmental sustainability and corporate social responsibility claims. Claims could include organic, halal, kosher, fair trade, ethically sourced, animal welfare, environmental certifications, and others.

Overview of the GFSI Implementation Steps to Address Food Fraud

In hindsight, many opportunities and good fortune led to the evolving, developing, and implementing of food fraud requirements. The process leveraged essential GFSI resources, such as the role of the board of directors, to identify key concepts and to shepherd the process along. The GFSI Food Fraud Think Tank members had unique, interdisciplinary skills and experience that created a clear and rational approach. The GFSI Technical Working Groups effectively gathered stakeholder input and integrated it with industry-wide available resources and other standard operating procedures. After the guidance document publication and requirement, the follow-up ‘GFSI Food Fraud Technical Document provided momentum for the adoption.

The implementation of the food fraud prevention concept is moving through the ‘hype cycle.’ A theory was developed to explain the development and adoption of a new idea or technology, referred to as the ‘hype cycle.’ (Fenn, 1995; Linden et al., 2018) The cycle starts when there is a new technology or a new problem that creates activity. (Birkinshaw, 2014; Dedehayir et al., 2016; O’Leary, 2008; Van Lente et al., 2013) The series of modern food fraud incidents created the industry response to food fraud, such as creating the GFSI food fraud think tank. This activity was the ‘Technology Trigger’ that started the formal activities. Next on the hype cycle is the ‘Peak of Inflated Expectations,’ where tremendous excitement and action to explore ‘what’ is the problem and ‘how’ to respond. For several years, food fraud was among the hottest food industry meetings and project topics. This step is followed by the ‘Trough of Disillusionment’ where “Interest wanes as experiments and implementations fail to deliver – producers of the technology shake out or fail.”(Gartner, 2016)

The current state of food fraud prevention seems to be in the ‘Scope of Enlightenment’ where the problem is more clearly understood, and procedures are developed to address the root causes precisely. Through this stage is the ‘Plateau of Productivity,’ an ever-increasing efficient and effective strategy. The GFSI leadership, and through the GFSI Food Fraud Think Tank efforts, created a framework and path that has efficiently moved the topic along the ‘hype cycle.’ Looking back, when considering overall food safety management system harmonization, the GFSI itself has also moved through the hype cycle. The general GFSI activities are also providing an ever-increasing efficient and effective strategy.


Takeaway Points

  • The GFSI food fraud prevention strategy and compliance requirements have not had to change since they were adopted in 2018, and they were based on lessons learned from other quality innovations. The biggest risk was to create such complex or intensive programs that nothing would be implemented.
  • After the GFSI Food Fraud Think Tank report, the GFSI BOARD created very clear and concise guidance in a position paper, the GFSI benchmark document, and then a guidance document.
  • The food industry has one of the – and probably by far – most widely, holistic, and most clearly defined adopted product fraud prevention strategies of any industry. Even so, there is still a long way to go until there is comprehensive adoption of food fraud prevention. As I noted in the article, “The foundation is very theoretically and practically sound.”

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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