UPDATE – Review and Comments on the new Codex Food Fraud Discussion Paper

Codex Alimentarius is advancing their work on creating an international food fraud guidance. This is an overview of the March 2021 updated document that will be reviewed at the May 2021 CCFICS25 meeting. This is a restart of the significant progress of the activity started in 2016. In these five years, there have been more countries involved and there have also been advances in the food fraud prevention research. There is efficient and important progress on renewing the agreement on the scope of work to first focus on the basic definitions. If there is scope creep beyond the original focus to create a first guidance document just defining the terms, then the project could become so complex that the completion would be delayed forever.

Background: Codex Alimentarius (CODEX) is the world food code that is coordinated by the World Health Organization and the Food and Agricultural Organization of the United Nations. CODEX creates a harmonized set of “international food standards, guidelines and codes of practice [that] contribute to the safety, quality and fairness of this international food trade.” While CODEX creates reference materials, the documents are often accepted by many countries as their food laws and regulations.  In 2016 at the CCFICS22 meeting, food fraud was identified as an important topic, including the need for definitions of terms. In 2017 at the CCFICS23 meeting, an Electronic Work Group convened to address the food fraud topic (FF eWG). In March 2021, the FF eWG updated the Discussion Paper. Below is a summary of our Food Fraud Prevention Think Tank (FFPTT) comments and recommendations.


CODEX, Codex Alimentarius, (2021). Discussion Paper on Role of CCFICS with Respect to Tackling Food Fraud in the Context of Food Safety and Fair Practices in Food Trade – Updated, March 2021, Electronic Work Group on Food Fraud, URL: http://www.fao.org/fao-who-codexalimentarius/sh-proxy/es/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FMeetings%252FCX-733-25%252FWorking%2BDocuments%2B2021%252Ffc25_08e.pdf

Spink, John (2021). Comments to the US Codex Delegation for the Food Fraud EWG Discussion Document, URL: https://blog.foodfraudpreventionthinktank.com/wp-content/uploads/2021/06/CODEX-FF-EWG-Comments-to-the-US-Codex-Delegation-April-2021-v5.pdf


Public Comment on the current Discussion Paper draft as shared with the US Codex Delegation:

SUMMARY: The Codex FF eWG has created a very comprehensive review of the topic and conclusion. This document stated a clear agreement that addressing food fraud is an important Codex subject. Also, it was stated as clear and agreed upon that providing definitions of terms, and the relation to other Codex works and Committees, will reduce confusion and global inefficiencies.

  • OUR RECOMMENDATION is for the eWG to retain the original, narrow scope of guidance document that only addresses (1) definitions of key terms, (2) explains the types of food fraud, and (3) explains the relation of these concepts to other Codex documents.
  • To expand beyond this narrow scope would further delay the important work – it has already been over FIVE YEARS since the need for a food fraud definition was first on the CCFICS22 agenda.
  • Other key concepts could be noted for future research, including: National Food Control Systems, Information Sharing, “Roles and responsibilities of industry and government entities when addressing food fraud” and “Guidance on how countries can modernize their national food control systems to address food fraud and intentional adulteration, e.g., an extension of HACCP and good manufacturing practices.”
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