Review – Codex and Food Fraud: MSU Public Comments and Codex 2017 Direction Setting

Written by: John Spink

Primary Source:  Food Fraud Initiative

ffi-blog-v2-no66-codex-cacAddressing Food Fraud in Codex Alimentarious 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 Alimentarious 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

This MSU FFI report is a response for the Codex Alimentarius Commission: Meeting of the Codex Alimentarius Commission, Notice of public meeting and request for comments by the Office of the Deputy Under Secretary for Food Safety, USDA. This submission specifically addresses the FDA request for additional comments regarding Agenda for the 39th Session of the CAC item “Food integrity/authenticity” (Food Fraud including Economically Motivated Adulteration) on June 27, 2016 in Rome.

Part I – For Codex in general

1) A critical need is for Codex to develop a position paper including definition of adulterant, adulteration, Food Integrity, Food Authenticity, and Food Fraud.

2) There is a need for Codex leadership to define and provide risk assessment, vulnerability assessment, risk management and risk communication standards to address Food Fraud.

Recommendation 1: A formal Codex statement on Food Fraud is recommended. By beginning with a statement the concept can be reviewed and assessed for possible next steps. MSU has interest, expertise and has been expanding its resources in this area and is prepared to support the US Delegation.

Part II – For the USA within Codex

1) Various aspects of the Agriculture sector — collectively and individually as well as, in the public and private sector — are addressing Food Fraud. For many public health and economic reasons it is important for the USA to establish a global leadership role.

2) Codex leadership addressing in Food Fraud and adulterants could support the evolving US food laws that would specifically provide insight for the Economically Motivated Adulteration aspects of the Food Safety Modernization Act recently published the Preventive Controls Final Rule.

Recommendation 2: It is recommended that the US Delegation propose to host and be secretariat of an Electronic Working Group which may lead to an ad hoc Inter-governmental Task Force to examine both the potential public health impacts and the trade economic aspects of Food Fraud. MSU has interest and expertise to support inputs from the US Delegation.

Codex Meeting Summary and Actions

The Codex meeting final report was summarized in one of our previous MSU reports:

The Food Fraud (Food Integrity/ Food Authenticity) related conclusion from the 39th Codex Alimentarious Commission (CAC) meeting was:

“In the future it might be appropriate to establish either a [Electronic Work Group] EWG of the Commission or an Ad Hoc Intergovernmental Task Force on Food Integrity/Authenticity.”

This recommendation was proposed by Iran, who was also the lead on the topic. Iran also was the lead at last year’s 38th session, but Food Fraud was not addressed “due to time constraints.” That meeting’s activities were presented in the report from February 2016 at the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFIC, a sub-committee under the full CAC).

The conclusion of the meeting was that creating an Electronic Working Group “might be appropriate.” Iran is leading this activity with potential support from the Netherlands and Canada. Engaging CODEX for Food Fraud standards is a priority for our industry partners so we will continue to pursue this engagement.

Research Collaborators

We are pleased to expand our research reviewer team to include colleagues who provided confidential comments:

  1. Douglas C Moyer, PhD, Assistant Professor, Program in Public Health, College of Human Medicine, MSU
  2. Neal Fortin, JD, Professor and Director, Institute for Food Laws & Regulations, College of Law and Department of Food Science and Human Nutrition, College of Agriculture and Natural Resources, MSU
  3. Vincent Hegarty, PhD, Founding Director of the International Food Law Program and Founding Director of the Institute for Food Laws & Regulations (IFLR), MSU
  4. Andrew Huff, PhD, Assistant Professor, College of Veterinary Medicine, MSU
  5. Yves Rey, Senior Advisor to the Board of Directors, Groupe Danone, (former General Manger for Corporate Quality, Groupe Danone and former Chairman of the Global Food Safety Initiative (GFSI)
  6. Robert C Baker, Director, Global Food Safety Center & Head of Technical Food Safety Development, MARS Incorporated
  7. Jason Bashura, MPH, RS, Senior Manager, Global Food Defense, PepsiCo

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 Fr

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John Spink
Dr. Spink has been focused on product fraud since the Michigan State University’s Food Safety Program and the School of Packaging began research on the topic in 2006. This work expanded to the behavioral sciences and criminology and led to the establishment of the Anti-Counterfeiting and Product Protection Initiative in 2008. In 2009 the work shifted to the School of Criminal Justice where the Initiative evolved into a Program.