Food fraud and economically motivated adulteration are common industry issues that cost the food industry billions of dollars a year. This guide covers the products most often targeted, the warning signs that an ingredient isn't what it claims to be, and what SQF, BRCGS, FSSC 22000, IFS and FSMA require manufacturers to do about it.
Food fraud follows money. When a crop fails, a price spikes or a supply chain gets long and hard to see, someone along it is tempted to stretch, swap or relabel the product. The same ten or so categories show up in enforcement data year after year, and the controls that catch them are well understood. Estimates of the cost run from $10–15 billion a year to as high as $40 billion.[1][2]
- 22,000 tof fake or substandard food seized in Europol's OPSON XIII operation in 2024Europol, 2024 [3]
- 46%of honey sampled at EU borders was suspected of added sugar syrupEuropean Commission, 2023 [4]
- 48%of oregano samples in an EU-wide spice check were suspiciousEU JRC, 2021 [5]
- 39%of U.S. seafood samples were mislabeled across 35 studiesChapman University, 2025 [6]
Key takeaways
- Food fraud is intentional and done for money. It covers substitution, dilution, concealment, mislabeling, counterfeiting and diverted goods. It's a criminal act, not a quality slip.
- The high-risk list is stable. Olive oil, honey, seafood, meat, spices, dairy, wine and spirits, coffee and tea, grains, and organic or origin claims. EU enforcement data puts meat, honey and olive oil near the top.
- Two popular home tests don't work. The olive oil “fridge test” and honey crystallization say nothing reliable about authenticity.
- Every major GFSI scheme requires a food fraud program: a documented vulnerability assessment and a mitigation plan, kept current. SQF, BRCGS and IFS require a review at least once a year.
- FSMA reaches it too. The preventive controls hazard analysis must consider hazards introduced on purpose for economic gain.
- Auditors look for evidence, not a form. The common findings are copied templates, stale reviews and mitigation that isn't tied to real supplier controls.
What Is Food Fraud?
When demand is high or supply is short, price pressure runs through the whole chain. Businesses look for ways to stay competitive, and a few cut corners that cross the line. Food fraud puts consumer health at risk, creates unfair competition and erodes trust in the food system, and fraudsters exploit gaps in surveillance, testing and enforcement to keep it profitable.
Fraud falls into a handful of recurring types. Your vulnerability assessment is expected to consider each type for each raw material:
| Type | What it is | Example | First line of control |
|---|---|---|---|
| Substitution | A cheaper ingredient or species replaces the declared one | Tilapia sold as red snapper | Specify by scientific name; DNA test high-risk lots |
| Dilution | A high-value liquid is cut with a cheaper one | Olive oil cut with seed oil; honey with sugar syrup | Authenticity specs and testing; price checks |
| Concealment | Poor quality is hidden with dyes, fillers or coatings | Sudan dyes in chili; lead chromate in turmeric | Dye and heavy-metal screens; approved origins |
| Mislabeling | False claims about origin, grade, species or organic status | Imported beef labeled “Product of USA” | Certificate checks; mass balance; substantiation file |
| Counterfeiting | Copies of branded products or packaging | Refilled premium spirits bottles | Authorized distributors; tamper-evident packaging |
| Grey market and theft | Genuine product sold outside legitimate channels | Diverted product with no cold-chain record | Approved-supplier list; chain-of-custody records |
Food fraud, food defense and food safety are different problems
| Food safety | Food defense | Food fraud | |
|---|---|---|---|
| Motive | None. Hazards are accidental or natural | Intent to cause harm | Intent to make money |
| Typical example | Listeria in a ready-to-eat product | Deliberate contamination of a product | Syrup-cut honey sold as pure |
| Assessment | HACCP hazard analysis | Threat or vulnerability assessment | Food fraud vulnerability assessment |
| SQF Edition 9 | 2.4.3 Food Safety Plan | 2.7.1 Food Defense Plan | 2.7.2 Food Fraud |
| U.S. rule | 21 CFR 117 (CGMP and preventive controls) | 21 CFR 121 (intentional adulteration) | 21 CFR 117.130 hazard analysis covers economic adulteration |
Auditors expect a separate food defense and food fraud assessment, or one document that clearly keeps them apart.[7]
The Top 10 Food Fraud Products
These categories have topped food fraud databases and enforcement reports for more than a decade, and the latest data says they still do. In 2023 the EU Agri-Food Fraud Network logged 758 fraud suspicions, up 26%. Setting aside a coordinated action on illegal pet trade, meat, live animals (mostly horses) and honey were the most-reported categories, with fats and oils, mostly lower-grade olive oil sold as extra virgin, close behind.[8] Europol's OPSON operations pulled 22,000 tonnes of food and 850,000 litres of drinks off the market in 2024, and about 11,600 tonnes and 1.4 million litres in 2025.[3][9]
| # | Product | Most common fraud | How it's caught | First control |
|---|---|---|---|---|
| 01 | Olive oil | Seed or lower-grade oil sold as extra virgin; false Italian origin | Fatty acid and sterol profile, UV absorbance, sensory panel | Grade specs and traceable mills |
| 02 | Honey | Sugar-syrup dilution; hidden country of origin | Isotope tests (SCIRA, LC-IRMS), syrup markers, NMR | Authenticity testing and origin traceability |
| 03 | Seafood | Species substitution; farmed sold as wild; overglazing | DNA barcoding; net-weight checks | Scientific-name specs and chain-of-custody sourcing |
| 04 | Meat and poultry | Undeclared species; false breed or origin claims | PCR species testing | Species tests and an origin substantiation file |
| 05 | Herbs and spices | Bulking agents; illegal dyes; lead chromate | Microscopy, DNA or spectroscopy; dye and heavy-metal screens | Buy whole; screen ground spices |
| 06 | Dairy | Cellulose-padded or substitute cheese; diluted milk; non-milk fat | Fat profile; true-protein methods | Variety-specific specs and supplier audits |
| 07 | Wine and spirits | Counterfeit labels; refilled bottles; false appellation | Isotope tests; label and closure checks | Authorized distributors only |
| 08 | Coffee and tea | Fillers in ground coffee; robusta sold as arabica; false origin | Microscopy, DNA, NMR | Buy whole bean or leaf; origin documents |
| 09 | Grains and rice | Non-basmati in basmati; conventional sold as organic | DNA variety testing | Variety tests and organic certificate checks |
| 10 | Organic, origin and free-from claims | The claim itself is false | No single lab test; the paper trail and mass balance | Certificate verification and a substantiation file |
Methods are examples. Use a lab accredited to ISO/IEC 17025 for the specific test.
For each product below: what the fraud looks like, what the latest evidence shows, and the controls that work at the receiving dock.
Olive Oil
- What the fraud looks like
- Lampante or refined olive oil, or cheaper seed oils such as sunflower and soybean, blended into or sold outright as “extra virgin.” Origin fraud is common too, with non-Italian oil bottled as Italian.
- What the evidence shows
- Fraud follows price. Drought cut Spain's 2022–23 olive oil harvest by more than half, and EU extra virgin prices hit a record in early 2024.[10] In one investigation, Spanish and Italian police seized more than 260,000 litres of oil and arrested 11 people in a scheme that used lampante oil, unfit to eat without refining, to cut oil sold as extra virgin.[11] In OPSON XIII, Spanish authorities seized 45,000 litres of oil and 120,000 cans of tuna after finding sunflower or pomace oil labeled as olive oil, and Italian police seized 42 tonnes of oil falsely labeled Italian extra virgin.[3]
- What doesn't work
- The “fridge test.” The UC Davis Olive Center chilled genuine extra virgin oils, seed oils and blends for eight days; none solidified completely, and some cutting oils congeal at the same temperatures olive oil does.[12] A peppery finish is a real trait of fresh extra virgin oil, but it's a sensory cue, not an authenticity test.
- Controls that work
- Buy from mills or packers that can trace to the grove. Write grade parameters into the specification (free fatty acidity, peroxide value, UV absorbance, sterol and fatty acid profile) and test incoming lots against it. Where a PDO or PGI claim is on the label, verify it with the consortium's register.
Honey
- What the fraud looks like
- Dilution with sugar syrups made from rice, wheat, beet or corn; hidden country of origin; and blends labeled as single-origin or raw.
- What the evidence shows
- In the EU's “From the Hives” action, 147 of 320 honey consignments (46%) sampled at EU borders were suspected of containing sugar syrups, including 74% of the samples from China and 93% of those from Türkiye.[4] FDA found undeclared sweeteners in 10% of 144 imported samples it tested in 2021–22.[13] Honey was among the three most-reported fraud categories in the EU network's 2023 report,[8] and from June 14, 2026, EU rules require honey blends to list every country of origin with its percentage.[14]
- What doesn't work
- Crystallization. Genuine honey can stay liquid for months depending on its sugar ratio, and syrup-cut honey can crystallize.
- Controls that work
- Require authenticity testing (isotope-ratio, syrup-marker or NMR methods) in the supplier specification, insist on traceability to the packer and apiary region, and treat brokers who can't provide it as high vulnerability. A price well below the market is a strong warning sign. Our SQF gap analysis guide for honey packers covers honey specs and tests in detail.
Seafood
- What the fraud looks like
- Species substitution (tilapia or rockfish sold as red snapper, escolar sold as “white tuna,” pangasius sold as grouper or sole), farmed sold as wild, and short weight from excess glazing or added water.
- What the evidence shows
- A 2025 meta-analysis of 35 U.S. studies and 4,179 samples found 39% of seafood mislabeled overall and outright species substitution in 26%. For the ten most-consumed species, such as shrimp, salmon and canned tuna, substitution was lower at 14%, so the risk concentrates in less common species and in restaurants.[6] In MSC's own DNA testing, products carrying its chain-of-custody ecolabel were mislabeled less than 1% of the time.[15] FDA's 2022–24 sampling of imported frozen seafood found 10 of 28 samples (36%) short-weight because of excess ice glaze.[16]
- Controls that work
- Specify species by scientific name, not market name. Run DNA barcoding on lots from new or high-risk suppliers, buy under a chain-of-custody scheme such as MSC or ASC where available, and for imports keep the records NOAA's Seafood Import Monitoring Program requires.
Meat and Poultry
- What the fraud looks like
- Undeclared cheaper species in ground and mixed products, sausages and kebabs; false breed claims (“Kobe” or “wagyu” on ordinary beef); and false “Product of USA” claims on imported meat.
- What the evidence shows
- Setting aside illegal pet trade, meat was the most-reported fraud category in the EU network's 2023 report, and horses were the most common subject of live-animal fraud reports.[8] The 2013 horsemeat scandal remains the reference case. In the U.S., USDA's “Product of USA” rule took effect January 1, 2026: the claim is allowed only for animals born, raised, slaughtered and processed in the United States, and processors must back it up.[17]
- Controls that work
- PCR species testing on ground and mixed products, especially from new suppliers; breed and origin claims backed by the supplier's documented mass balance; and a substantiation file for every origin claim on your own label.
Herbs, Spices and Seasonings
- What the fraud looks like
- Bulking with cheaper plant material (olive leaves in oregano, husks and starch in ground spices) and colorants that disguise poor quality, including banned Sudan dyes in chili and paprika and lead chromate in turmeric.
- What the evidence shows
- In the EU's coordinated control plan, 17% of 1,885 herb and spice samples were suspicious. Oregano was worst at 48%, most often cut with olive leaves; pepper was 17%, cumin 14%, turmeric 11%, saffron 11% and paprika or chili 6%.[5] Stanford researchers found detectable lead in 14% of 356 turmeric samples from India, Pakistan, Sri Lanka and Nepal, consistent with lead chromate added for color, with levels above 1,000 µg/g in some markets.[18] In 2024 Taiwan pulled from shelves and sealed nearly 600,000 kilograms of chili powder and products made with it after finding Sudan dye.[19]
- Controls that work
- Buy whole spices and grind in-house where the process allows. Screen ground spices for heavy metals and illegal dyes, use approved origins and audited suppliers, and consider microscopy, DNA or spectroscopic testing for the highest-risk items: oregano, saffron, turmeric, chili and cumin.
Dairy Products
- What the fraud looks like
- Grated “Parmesan” padded with cellulose or made from cheaper cheese, milk extended with water or whey, vegetable fat sold as milk fat, cheese analogue sold as cheese, and nitrogen-boosting adulterants.
- What the evidence shows
- In the U.S. reference case, the president of Pennsylvania's Castle Cheese was sentenced in 2016 to three years' probation and a $5,000 fine after the company sold “100%” Parmesan and Romano products that didn't meet FDA's standards of identity.[20][1] The deadliest dairy fraud on record is China's 2008 melamine scandal: milk spiked to fake its protein content affected about 294,000 infants, put more than 50,000 in hospital and killed six.[21] It's why protein measured by nitrogen alone is no longer trusted.
- Controls that work
- Specifications with anticaking limits and a named cheese variety, protein methods that tell true protein from nitrogen adulterants, fat-profile testing for milk fat claims, and supplier audits for imported dairy ingredients.
Wine and Spirits
- What the fraud looks like
- Cheap wine relabeled under premium appellations, counterfeit branded spirits refilled with industrial alcohol, diluted spirits, and false vintage or origin claims.
- What the evidence shows
- Alcohol made up most of the 850,000 litres of beverages seized in OPSON XIII in 2024, and investigators named wine and olive oil as the products counterfeiters targeted most.[3] OPSON XIV in 2025 took 1.4 million litres of beverages off the market and reported 631 people to judicial authorities.[9]
- Controls that work
- Buy only through authorized distributors, verify appellation and PDO paperwork, use tamper-evident closures and serialized labels on your own products, and test premium lines for authenticity.
Coffee and Tea
- What the fraud looks like
- Ground coffee bulked with corn, barley, chicory or husks; robusta sold as arabica; commodity coffee sold under protected origins such as Kona or Jamaica Blue Mountain; and tea cut with spent or lower-grade leaves or mislabeled as Darjeeling or another protected origin.
- What the evidence shows
- Fillers hide most easily in ground and instant coffee. Origin claims are the other target: in 2019 Kona growers sued about two dozen sellers, alleging that coffees sold as “Kona” contained little or no Kona beans. The defendants settled, paying about $41 million and agreeing to labeling changes.[22]
- Controls that work
- Buy whole bean and whole leaf where possible, require origin documents to the cooperative or estate, and use DNA or NMR authenticity testing for any origin or variety claim on your label.
Grains, Rice and Flours
- What the fraud looks like
- Basmati blended with cheaper long-grain rice, conventional grain sold as organic, and “gluten-free” flours that aren't.
- What the evidence shows
- In the largest organic fraud case in U.S. history, an Iowa grain broker admitted to at least $142 million in grain sales, most of it conventional grain sold as organic, and was sentenced in 2019 to 122 months in prison.[23] Cases like it helped prompt Congress and USDA to tighten organic oversight. For basmati, the UK industry's Code of Practice limits non-basmati rice to 7% and relies on DNA testing to check it.[24]
- Controls that work
- DNA variety testing for basmati, gluten testing for free-from claims, and organic import certificates checked against the USDA Organic Integrity Database.
Organic, Origin and “Free-From” Claims
- What the fraud looks like
- Not a product but a claim, and it cuts across every category above: conventional sold as organic, imported sold as domestic, and allergen or “free-from” claims without the controls behind them. Because the claim is the only difference between the cheap product and the expensive one, it's the highest-margin fraud there is.
- What the evidence shows
- USDA's Strengthening Organic Enforcement rule, in force since March 19, 2024, requires NOP import certificates for every organic import, certification of most importers and brokers, unannounced inspections and traceability back through the chain.[25] The “Product of USA” rule for meat, poultry and eggs followed in January 2026,[17] and the EU's honey origin labeling in June 2026.[14] Regulators are converging on the same answer: a claim must be backed by records you can produce on demand.
- Controls that work
- Verify every organic certificate against the USDA Organic Integrity Database, run a mass balance on any claim-bearing ingredient, and keep a substantiation file for each claim on your own label.
How to Spot Food Fraud in Your Supply Chain
The warning signs that protect a shopper protect a purchasing manager too, only the stakes are higher. Treat any of these as a trigger to re-score the material and tighten controls:
| Warning sign | What it looks like | What to do |
|---|---|---|
| Price that doesn't match the market | Saffron, extra virgin olive oil or manuka honey offered well below the commodity price | Raise the material's vulnerability score; ask why; test the first lots |
| A broken paper trail | Missing or inconsistent certificates of analysis; origin documents that don't match the shipping route | Hold the lot until documents reconcile; audit the supplier |
| A supplier who can't name the source | No farm, mill or processor named upstream | Require traceability to source before approval |
| Label language that hedges | “Italian-style,” “honey-flavored,” “blended,” “product of multiple countries” | Legal, but check what the blend actually contains |
| Certificates you can't verify | Organic, MSC, PDO or halal claims that don't appear on the certifier's register | Check the public register, not the label |
| A form that hides the source | Ground, powdered, minced or blended materials | Buy whole and process in-house, or test more often |
| Sudden changes upstream | New brokers, a new country of origin, or a supplier under financial pressure | Re-score the material and tighten controls until the change is understood |
What SQF, BRCGS, FSSC 22000, IFS and FSMA Require
Many retailers now require GFSI-benchmarked certification from their suppliers, and food fraud is part of every GFSI-recognized scheme. The wording differs; the substance doesn't: assess every material's vulnerability, put mitigation in place, and keep it current. GFSI made a food fraud vulnerability assessment and mitigation plan a benchmarking requirement in Version 7 of its Benchmarking Requirements (2017), and the recognized schemes built it in from 2018.[26]
| Standard | Where | What it requires | Review |
|---|---|---|---|
| SQF (Edition 9) | 2.7.2 | Vulnerability assessment covering substitution, mislabeling, dilution, counterfeiting and stolen goods; a mitigation plan; staff who know it[7] | At least yearly; Edition 10 adds “when the vulnerability changes” |
| BRCGS Food (Issue 9) | 5.4.1–5.4.4 | People who understand fraud risk; sources of threat information; a vulnerability assessment of all food raw materials; assurance or testing for materials at particular risk[27] | At least yearly, and when materials, suppliers or risks change |
| FSSC 22000 (Version 6) | 2.5.4 | Vulnerability assessment using a defined method; a documented mitigation plan with verification, supported by the FSMS[28] | Kept up to date (no fixed frequency) |
| IFS Food (Version 8) | 4.20 | Named responsibility; vulnerability assessment of raw materials, ingredients, packaging and outsourced processes; a mitigation plan with testing and monitoring[29] | At least every 12 months, or after significant changes |
| FSMA preventive controls | 21 CFR 117.130 | Hazard analysis must consider hazards intentionally introduced for economic gain; preventive controls where needed[30] | Reanalysis at least every 3 years, and when something changes |
FSSC 22000 Version 7 was published in May 2026; it adds ISO 22002-100 clause 16.3 and a competence requirement, and Version 6 audits remain allowed until April 30, 2027.[31]
SQF Food Safety Code
SQF covers food fraud in clause 2.7.2 of the Edition 9 System Elements. The site must document how it identifies vulnerability to food fraud, including raw material or ingredient substitution, finished product mislabeling, dilution, counterfeiting and stolen goods. A mitigation plan must address the vulnerabilities found, and both must be reviewed at least once a year.[7] SQFI has said sites without a completed vulnerability assessment and mitigation plan can expect a major non-conformity.[32] Edition 10 keeps the requirement and adds a review whenever the vulnerability changes.
BRCGS Global Standard for Food Safety
BRCGS covers food fraud in clause 5.4, product authenticity, claims and chain of custody. The people doing the assessment must understand food fraud risks and the raw materials involved, and the site needs reliable sources of information on emerging threats. The vulnerability assessment covers all food raw materials and weighs historical evidence of substitution or adulteration, economic factors, ease of access in the supply chain, how sophisticated routine testing is, and the nature of the material. It's reviewed at least once a year, and where a material is at particular risk, the plan must include assurance or testing.[27] Our guide to what BRCGS certification involves shows where clause 5.4 sits in the standard.
FSMA preventive controls
Under FDA's preventive controls rule, the hazard analysis must consider known or reasonably foreseeable hazards that may be intentionally introduced for purposes of economic gain, and a preventive control is required where one exists.[30] In practice your vulnerability assessment and your FSMA hazard analysis should reference each other, and a preventive controls qualified individual should sign off on both.
How to Build a Food Fraud Vulnerability Assessment
A vulnerability assessment isn't a hazard analysis. HACCP asks what could go wrong by accident; a vulnerability assessment asks where someone would cheat if they could. The steps are the same across schemes:
- Assign ownershipName the person or team responsible, and include purchasing, not just QA. Purchasing knows which suppliers are under price pressure.
- List every materialRaw materials, ingredients and packaging. Group items only where the risk is genuinely the same.
- Score opportunity and motivationHow easy is it to adulterate and how likely are you to catch it? How big is the price gap, how tight is supply, what's the supplier's history?
- Rate your existing controlsSupplier approval, certificates of analysis, upstream GFSI certification, mass balance and testing all lower the residual risk.
- Mitigate anything that scores highRestrict to approved suppliers, buy whole, test more often, audit unannounced or tighten specifications.
- Review yearly and on triggerA new supplier or origin, a price spike or a published incident should each prompt a re-score.At least once a year
Public incident databases help with the scoring. The EU Agri-Food Fraud Network's monthly reports and commercial food fraud databases are the usual starting points.
A simple scoring matrix
Most sites score each material on likelihood (opportunity and motivation) and on how likely current controls are to miss the fraud, then act on the combination. This is one common layout; any documented, consistent method is acceptable.
| Likelihood of fraud | Controls would catch it | Controls might catch it | Controls would miss it |
|---|---|---|---|
| High | Medium | High | High |
| Medium | Low | Medium | High |
| Low | Low | Low | Medium |
High: mitigation plan required. Medium: strengthen controls and monitor. Low: maintain existing controls.
Worked example
| Material | Why it's vulnerable | Existing controls | Rating | Mitigation |
|---|---|---|---|---|
| Extra virgin olive oil (bulk) | Large price gap to seed oils; record prices; long chain | Approved supplier; COA for acidity only | High | Add sterol and fatty acid profile to the spec; test every new lot for 6 months; audit the packer |
| Honey (imported drums) | Syrup dilution and origin fraud are common; brokers in the chain | COA; country of origin on paperwork | High | Isotope or NMR testing per supplier per quarter; require packer traceability; drop brokers who can't provide it |
| Ground oregano | Bulking with olive leaves is widespread; ground form hides it | Approved supplier | High | Switch to whole leaf, or add microscopy testing |
| Granulated cane sugar | Small price gap; little to substitute | GFSI-certified supplier; COA | Low | Maintain controls; review annually |
Illustrative entries only. Score your own materials, suppliers and controls.
What Auditors Actually Find
The same gaps show up again and again in food fraud programs, and none of them are hard to fix:
| Finding | What the auditor sees | How to fix it |
|---|---|---|
| A template that was never localized | It lists generic categories, not the site's own materials, and every score is the same | Rebuild it from your real material and supplier list |
| No link to purchasing reality | It says “approved suppliers only,” but the list is out of date or the site buys through brokers who aren't on it | Reconcile the assessment with purchasing records every review |
| Stale review dates | Done for the first certification audit and not touched since, despite new ingredients and suppliers | Review at least yearly and on every trigger, and record it |
| Mitigation with no evidence | “COA reviewed on receipt,” but receiving records don't show it, or the COA wouldn't detect the fraud identified | Make the control specific and keep the record that proves it ran |
| Fraud and defense mixed up | One document that treats deliberate harm and deliberate cheating as the same thing | Separate assessments, or one that clearly keeps them apart |
A food fraud program that reflects your real supply chain is one of the clearest signals to an auditor, and to your customers, that the rest of your system is real too.
Frequently Asked Questions
What are the most common food fraud products?
Olive oil, honey, seafood, meat and poultry, herbs and spices, dairy products, wine and spirits, coffee and tea, grains and rice, and products sold on organic, origin or free-from claims. The EU's 2023 enforcement data put meat, honey and olive oil near the top of the list.
What is economically motivated adulteration?
Economically motivated adulteration (EMA) is FDA's term for food fraud: intentionally adding, substituting or misrepresenting a substance in a food to make money. Under FSMA's preventive controls rule, the hazard analysis must consider hazards that may be intentionally introduced for economic gain.
What is the difference between food fraud and food defense?
Food fraud is deception for economic gain: substituting, diluting or mislabeling to make money. Food defense is protection against intentional contamination meant to cause harm. GFSI schemes require an assessment and plan for each, and auditors check that the two aren't simply the same document with a different title.
Is a food fraud vulnerability assessment the same as a HACCP hazard analysis?
No. A hazard analysis looks at unintentional hazards in your process. A vulnerability assessment looks at where a supplier or someone in the chain could deliberately cheat. The two should cross-reference each other, and under FSMA the hazard analysis must also consider economically motivated adulteration.
How often does the vulnerability assessment need to be reviewed?
At least once a year under SQF, BRCGS and IFS (FSSC 22000 requires it to be kept up to date), and whenever something changes: a new supplier or country of origin, a price spike in a key commodity, or a published fraud incident in your category.
Which raw materials should I worry about most?
Anything with a large price gap between the genuine and substitute material, a long or opaque supply chain, and a physical form that hides its source. Spices, oils, honey, seafood, and anything sold on an origin or organic claim consistently score highest.
Do I need laboratory testing to control food fraud?
Not for every material. Testing is one mitigation, and it's the right one for high-vulnerability materials where a validated authenticity method exists. For most materials, supplier approval, upstream GFSI certification, document checks and mass balance are the primary controls.
Do the olive oil fridge test and honey crystallization prove authenticity?
No. UC Davis found genuine extra virgin olive oil doesn't reliably solidify in the refrigerator, and some cutting oils congeal at similar temperatures. Genuine honey may stay liquid for months, and syrup-cut honey can crystallize. Neither replaces laboratory testing and a traceable supply chain.
Build a food fraud program that holds up
Learn to run a vulnerability assessment and mitigation plan your auditor will accept, or get help building one for your facility.
Consulting and training are offered through ASI Training and Consulting, LLC, separately from our accredited certification body, ASI Food Safety, LLC, to safeguard against conflicts of interest. Using them has no effect on a certification decision. Questions? Email US.Info@kiwa-asi.com or call 1 (800) 477-0778.
Keep reading
- BlogSQF Gap Analysis for Honey PackersHoney specs, authenticity tests and labeling rules, clause by clause.
- BlogWhat Is BRCGS Certification?Requirements, audit grades and cost, including clause 5.4.
- BlogIFS vs. FSSC 22000 vs. BRCGSHow the major GFSI schemes compare.
- BlogWalmart Food Supplier RequirementsWhat a major retailer expects from its suppliers.
- PageSQF CertificationCodes, scoring, Edition 10 timing and how to get started.
- TrainingFood Defense TrainingThe intentional-harm side of the program, under 21 CFR 121.
Sources
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- PwC. Food Fraud Vulnerability Assessment and Mitigation: Are you doing enough? pwc.co.nz
- Europol (2024). EUR 91 million worth of counterfeit and substandard food seized in Europe-wide operation (OPSON XIII). europol.europa.eu
- European Commission (2023). EU coordinated action “From the Hives” (2021–2022). food.ec.europa.eu
- European Commission Joint Research Centre (2021). Results of an EU-wide coordinated control plan on fraudulent practices in herbs and spices. food.ec.europa.eu
- Chapman University (2025). A meta-analysis of seafood species mislabeling in the United States, Food Control. news.chapman.edu
- SQFI. SQF Food Safety Code: Food Manufacturing, Edition 9, clauses 2.7.1 and 2.7.2. sqfi.com
- European Commission, DG SANTE (2024). 2023 Annual Report of the Alert and Cooperation Network. ec.europa.eu
- Europol (2025). Counterfeit and substandard food worth EUR 95 million seized in global operation (OPSON XIV). europol.europa.eu
- European Commission (2024). Short-term outlook for EU agricultural markets, autumn 2024. agriculture.ec.europa.eu
- Europol (2023). 11 olive oil counterfeiters arrested following Operation OPSON. europol.europa.eu
- UC Davis Olive Center. Refrigeration is not reliable in detecting olive oil adulteration. olivecenter.ucdavis.edu
- U.S. FDA (2022). FY21/22 sample collection and analysis of imported honey for economically motivated adulteration. fda.gov
- Directive (EU) 2024/1438 (honey origin labeling). eur-lex.europa.eu
- Marine Stewardship Council. Seafood mislabelling rate of less than 1% for products with MSC ecolabel. msc.org
- U.S. FDA. Sample collection and analysis of imported frozen seafood for economically motivated adulteration, 2022–24. fda.gov
- USDA (2024). USDA finalizes voluntary “Product of USA” label claim. usda.gov
- Stanford University, Freeman Spogli Institute (2024). Evidence of turmeric adulteration with lead chromate across South Asia. fsi.stanford.edu
- Taiwan Ministry of Health and Welfare (March 27, 2024). Update on chili powder containing Sudan dye (in Chinese). mohw.gov.tw
- U.S. Attorney's Office, Western District of Pennsylvania (2016). Court sets sentencing date in adulterated and misbranded cheese cases. justice.gov
- World Health Organization (2009). Toxicological and Health Aspects of Melamine and Cyanuric Acid. iris.who.int
- West Hawaii Today (September 27, 2023). Kona coffee lawsuit settlements. westhawaiitoday.com
- U.S. Attorney's Office, Northern District of Iowa (2019). Field of schemes: fraud results in over a decade in federal prison for leader of largest organic fraud case in U.S. history. justice.gov
- The Rice Association and British Retail Consortium (2022). Code of Practice for Basmati Rice. riceassociation.org.uk
- USDA Agricultural Marketing Service. Strengthening Organic Enforcement. ams.usda.gov
- GFSI. Tackling Food Fraud through Food Safety Management Systems (technical document). mygfsi.com
- BRCGS. Global Standard for Food Safety, Issue 9, clause 5.4. brcgs.com
- FSSC 22000. Guidance Document: Food Fraud Mitigation (Version 6). fssc.com
- IFS. IFS Food Version 8, clause 4.20. ifs-certification.com
- 21 CFR 117.130, Hazard analysis. ecfr.gov
- FSSC 22000. Scheme Version 7 (2026). fssc.com
- SQFI (2019). SQF Tips: How to Make Your Food Fraud Program Compliant. sqfi.com