Review – Trade Journal Articles on Food Fraud Compliance Requirements for GFSI, FSMA, and Sarbanes-Oxley

Written by: John Spink

Primary Source:  Food Fraud Initiative

Are you compliant with the current and pending regulatory and standards requirements to address “all” types of food fraud and “all” products?  Probably not… but there are fairly simple steps to get started.  Our MSU FFI team just published two trade journal articles that summarize numerous peer-reviewed, refereed scholarly journal articles. MSU’s Dr. Doug Moyer is co-author on both articles.


Food Fraud is beginning to be understood as a unique food risk. Industry is shifting focus to Food Fraud Vulnerability Assessments requirements and creating a Food Fraud Prevention Strategy. Full compliance requires addressing all types of Food Fraud (e.g. stolen goods and counterfeits) as well as all products, (e.g. incoming goods and outgoing or finished goods.) Also, the vulnerability assessment must cover all of your products, but not necessarily an individual assessment for “each” product.

It is important to realize that implementing a separate Food Safety, Food Fraud, and Food Defense plan does not triple the work – splitting up the tasks into three steps reduces the overall complexity.

Combining the key points from the series of articles:

“Food Fraud Compliance Requirements — The general compliance requirements for Food Fraud prevention are:

  1. Conduct a written Food Fraud Vulnerability Assessment
  2. Implement a written Food Fraud Prevention Strategy
  3. Minimally conduct an annual Food Fraud Incident Review
  4. Demonstrate Management Buy-In
  5. Address all types of Food Fraud
  6. Address all products from both incoming goods (e.g., ingredients) and outgoing goods (e.g., finished goods) through to the consumer.”

“The first steps include:

  1. Convene a Food Fraud Task Force – this is the group to start the review and others may take over the ongoing management
  2. Create an Enterprise-wide Food Fraud Policy/ Mission Statement – also begin drafting a Food Fraud Prevention Strategy – the key is to “start”, not necessarily finish or wait for the final approval of the corporate level policy/mission
  3. Conduct the pre-filter Food Fraud Initial Screening (FFIS)
  4. Review additional needs including additional information or a more detailed Food Fraud Vulnerability Assessment (FFVA)
  5. Review specific Food Fraud vulnerabilities in an enterprise risk map (Enterprise Risk Management/COSO)
  6. Consider countermeasures and control systems – specifically address the ‘very high’ and ‘high’ vulnerabilities
  7. Propose a Food Fraud Prevention Strategy — include the calibration of the Food Fraud risks on the enterprise risk map”

To provide more detail, the two trade journal articles are summarized here.

Food Safety Magazine

Our February 2017 article “Food Fraud Vulnerability Assessment and Prefilter for FSMA, GFSI and SOX Requirements” is available at:

Compliance Requirements:

  • “Food Drug & Cosmetics Act – 1938 – essentially “all” types of food fraud for “all” products have been illegal since the adoption of the sections on “Adulterated Foods” and “Misbranded Foods.”
  • Sarbanes-Oxley (SOX or SARBOX) – 2002 – reporting all types of business fraud that could lead to a negative impact on the corporation must be managed with a threshold or disclosed.
  • FSMA Preventive Controls Rule – September 2016 – controls must be place to address “hazards that require a preventive control” for all “agents” even if they come from an “economically motivated” act.
  • GFSI Issue 7 – January 2018 – This will be published in February 2017 and required a year later. The GFSI position paper on Food Fraud defines the scope as all types of fraud (specifically mentioned stolen and counterfeit goods) and all products (not just ingredients and specifically mentioning packaged goods).
  • BRC Version 7 – July 2015 – They began enforcing the food fraud requirements.
  • FSSC 22000 Version 4 – December 2017 – This was published in December 2017 and required a year later. They cover all types of fraud and all products.”

“Starting a Vulnerability Assessment: Companies are learning they must conduct Food Fraud vulnerability assessments but there is a lack of clarity on how to start. This article summarizes a Prefilter concept that was published as the ‘Food Fraud Initial Screening model (FFIS).’”

Citation: The concepts are based on the MSU FFI peer-reviewed, scholarly journal article “Introducing the Food Fraud Initial Screening model (FFIS)” published in Food Control back in March 2016.


New Food Magazine

 Our February 2017 article “Food Fraud Prevention – how to start and how much is enough?” is available at:

“For food fraud, we will not arrest our way to compliance and we will not test our way to safety.”

“Implementing a Food Fraud Vulnerability Assessment and then creating Prevention Strategy – covering all types of food fraud and all types of your products – are not optional.  If you do not have these in place you are probably out of compliance.”

“Per previously published definitions, all types of food fraud that must be addressed include: adulterant-substances (e.g., dilution, substitution, and concealment), stolen goods, tampering, diversion or smuggling, unapproved enhancements, mislabeling, and intellectual property rights counterfeiting.  Of note, the FSMA Preventive Controls rule does not provide a definition or scope of food fraud. Instead it addresses an ‘agent’ that creates a ‘hazard that requires a preventive control’ from acts that are ‘economically motivated’ with a specific example of ‘stolen goods.’ This affirms that all types of food fraud should be assessed.”

“For a company, the resource allocation decision-maker has the final say on ‘how much is enough?’”

The key points are:

  • Concept One: Formally and specifically mention Food Fraud as a Food Safety issue
  • Concept Two: Create a government-wide (or company-wide) Food Fraud Prevention Strategy

Citation: The articles present concepts and steps that we published the peer-reviewed, scholarly journal includes “Food Fraud Prevention: Policy, Strategy, and Decision-Making – Implementation Steps for a Government Agency or Industry” in the International Journal for Chemistry (CHIMIA) in May 2016 and “The role of the public private partnership in Food Fraud prevention — includes implementing the strategy” in Current Opinion in Food Science in August 2016.



Upon deeper review the requirements are clear for the scope and timing of a Food Fraud Vulnerability Assessment and a Food Fraud Prevention Strategy. That said, there is a steep adoption curve that most companies are just now approaching.  This may seem like a daunting and complex task but fortunately there are guidelines, summaries, research and best practices to help the industry to navigate the various requirements and expectations in order to fully realize an effective Food Fraud Prevention Strategy.  FFI.

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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.