Review – GFSI Guidance Document Version 7.1

Written by: John Spink

Primary Source:   Food Fraud Initiative

Yesterday the GFSI Benchmarking Requirements (Guidance Document) Version 7.1 was published soon after Version 7 was published February 27, 2017. Regarding Food Fraud, there were NO modifications or clarifications.


The GFSI press release mentioned that the changes that were made are important due to discussions with FDA regarding the Food Safety Modernization Act. The industry goal is to try to have one system be applicable to GFSI, FSMA, and all other food safety compliance requirements.

GSFI noted:

  • “Version 7 was a broader revision than V7.1, bringing in new requirements to fight food fraud, to incorporate unannounced audits and overall to increase transparency and objectivity in the benchmarking process. It also contributed to expanding GFSI’s inclusive farm-to-fork approach by incorporating the new scope of the supply chain Food Brokers and Agents in this edition.”
  • “Version 7.1 adds a couple of new clauses for each scope under Food Safety Management Requirements, such as purchasing from non-approved suppliers and importantly, compliance with food safety legislation.”

Specifically the two new sections are:

  • “FSM AI 15.6 Purchasing (non-approved supplier) — Use of non-approved suppliers shall be acceptable in an emergency situation provided the facility has been assessed and the product meets the specification.”
  • “FSM AI 25 Food Safety Legislation — The standard shall require that the organisation establishes, implements and maintains detailed procedures and instructions for all processes and operations having an effect on food safety to be compliant in the country of manufacturing as well as the country of known destination.”

Food Fraud Requirements:

  • Addressing Food Fraud is NOT optional
  • A “documented Food Fraud Vulnerability Assessment”
  • A “document Food Fraud Mitigation Plan” (Food Fraud Prevention Strategy)
  • The scope must cover the “GFSI scope” – from the glossary and GFSI position paper this includes all types of fraud (more than adulterant-substances to include stolen goods and counterfeits) and all products (from ingredients to finished goods at retail)
  • A separate “Food Defence Assessment” and “Food Defence Plan”
  • There are only requirements to implement these actions and there is no further definition or definitions of “how much is enough.” The first step is to just complete these actions.

For more on the GFSI requirements regarding Food Fraud consider taking our free, online Food Fraud Overview MOOC (Massive Open Online Course), which includes two, 2-hour live lectures on May 18 and May 25, 2017 – registration is open:  Other MSU programs include a three credit graduate course on Anti-Counterfeiting and Product Protection (Food Fraud) that starts May 15 and runs for 15 weeks. 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.