Steps to Prevent Food Fraud for Manufacturers

Generally, a risk or vulnerability assessment begins by understanding what ingredients are used at a facility to make your products. The Food Protection and Defense Institute defines the top 10 most fraudulent foods as alcoholic beverages, oils and fats, meat and meat products, honey, spices, grains and grain products, coffee and tea, fish and seafood, dairy, and produce. Separately, Decernis’ Food Fraud Database defines their top 10 most fraudulent foods as olive oil, milk, honey, saffron, orange juice, coffee, apple juice, grape wine, maple syrup, and vanilla extract.

Many of these ingredients are known historically to be at an increased risk for fraud, which means there is a higher risk of fraud in your supply chain if you are receiving or using these ingredients. As an example, the gap between production and consumption of both olive oil (specifically extra virgin olive oil) and honey has been studied. While the global industry is only currently producing a certain amount of these ingredients, the world consumes more than what is produced. Thus, they are being fraudulently diluted, substituted, concealed, or mislabeled.

When conducting a vulnerability assessment to determine the risk of fraud in your supply chain, consider historical risk as a factor within the assessment. Additional examples of risk factors could include your history or relationship with a supplier and complication of the supply chain, such as how many points along the supply chain the ingredient goes through until it reaches your facility. Economic factors can also make fraudulent activity more attractive and could include a pandemic or ecological factors such as drought, pestilence, and the nature of the ingredient, such as a powdered or liquid ingredient versus a solid item such as an apple.

Once these factors are chosen, you should develop a risk rating system. These ratings could be Low, Medium, and High or Minor, Major, and Critical; what this would mean for each risk factor must be identified. Next, conduct an assessment using the risk factors and risk rating system established, while documenting your results.

In addition to the high-risk ingredients, look at your most expensive ingredients. Often, those products that have assured status, such as organic, gluten-free, and non-GMO, are most easily susceptible to fraud. Others might be easy to adulterate and/or difficult to test, so manufacturers and suppliers need to stay current with historical and developing threats. Resources to do so are offered through various trade associations, government sources, and private centers. Some also offer access to food fraud databases and free assessment templates.

Once you identify the risk of potentially fraudulent activity for an ingredient during your vulnerability assessment and per GFSI requirements, you are required to develop and implement mitigation strategies to significantly minimize or prevent it. If you identify economically motivated adulteration (food fraud with a food safety issue), then you will need to develop or implement preventive controls. Some common strategies include supplier audits, sampling and testing, final product testing, and approved supplier programs.

Once you’ve completed your assessment and developed mitigation strategies to address identified risks, there is still work to do. You’ll need to review your program on a regular basis, understanding that fraudsters will always look for opportunities. For example, GFSI audits such as BRC and SQF require that a food fraud vulnerability assessment be conducted annually to consider the susceptibility of raw materials.

Further, it is important for suppliers and customers to maintain a close relationship while continuing to oversee supplier approval and evaluation processes. An in-depth, approved supplier program is essential. Processors must continue to carry out analysis that, based on their risk assessment, each has determined is necessary to corroborate the legitimacy and origin of the materials received. You must continue developing rapid and accessible analytical methodologies that identify in a timely manner whether a food is fraudulent.