Food Defence and Food Fraud Assessments: Beyond HACCP
How to protect your product from deliberate tampering and economic fraud, not just accidental contamination
Traditional HACCP focuses on unintentional hazards: bacteria not killed, a piece of metal from a machine, cleaning chemical not rinsed off. Two other kinds of threat are missed by the usual hazard analysis:
- Food defence: protecting food from deliberate tampering intended to cause harm, whether by a disgruntled employee or an outside party.
- Food fraud: deliberate substitution, addition, dilution or misrepresentation for economic gain, such as blending olive oil with cheaper oils or selling honey with added sugar as natural.
GFSI-recognised food safety schemes, including FSSC 22000 and BRCGS, require a documented assessment of both threats and a plan to mitigate them.
1. Three different concepts
| Concept | Motive | Example | Tool |
|---|---|---|---|
| Food safety | Unintentional | Microbial contamination from under-cooking | HACCP |
| Food defence | Intentional, to cause harm | Adding a harmful substance to a tank | Threat assessment (TACCP) |
| Food fraud | Intentional, for profit | Diluting juice with water and sugar | Vulnerability assessment (VACCP) |
2. Food defence assessment
2.1 Identifying weak points
A multidisciplinary team walks the product flow from receipt to dispatch and asks at each point:
- Could someone reach exposed product without supervision?
- Are tanks, silos and addition points closed and controlled?
- Who enters the site: employees, contractors, drivers, visitors?
- Are there isolated areas or hours with limited supervision?
2.2 Typical controls
- Access control by card and zoning.
- Locks and seals on tanks and tanker hatches.
- CCTV at critical points.
- Background checks for sensitive roles, as local law permits.
- A culture of reporting suspicious behaviour.
- Numbered seals on incoming and outgoing shipments.
3. Food fraud vulnerability assessment
3.1 Factors for each raw material
| Factor | What increases vulnerability |
|---|---|
| Economic value | High-value materials such as saffron, honey, olive oil and pistachios |
| Fraud history | Documented cases in global databases |
| Ease of detection | Fraud hard to detect visually or with routine tests |
| Supply chain complexity | Multiple intermediaries or mixed origins |
| Supplier relationship | New supplier or spot-market purchase |
| Economic changes | Crop shortages or sudden price rises |
3.2 Sources of information
- Fraud and alert databases, such as the EU Rapid Alert System (RASFF).
- Industry association and regulator reports.
- Supplier test results and in-house testing.
3.3 Typical controls
- Supplier approval and on-site audits for high-vulnerability materials, that is, second-party audits.
- Periodic authenticity testing in accredited laboratories, such as isotope analysis for honey.
- Tight purchasing specifications.
- Fewer intermediaries and buying closer to the source.
- Price monitoring: a price far below market is a warning sign.
4. Documentation and review
- A documented assessment for every raw material and packaging material.
- A mitigation plan for high-priority threats and vulnerabilities.
- Review at least annually, and when a new alert appears or a supplier changes.
- Training for the team on food defence and food fraud basics.
- Results fed into management review and the internal audit programme.
5. Common mistakes
- A generic assessment copied without linking it to actual materials and suppliers.
- Every material rated low vulnerability without justification.
- Confusing food defence with general site security.
- Not updating the assessment when prices change or new fraud cases appear.
- Not involving purchasing, even though it is the first line of defence against fraud.
Conclusion
Food defence and food fraud complement HACCP; they do not replace it. The first protects the product from those who want to cause harm, the second from those who want to profit at the expense of authenticity. Both need a team that thinks like an attacker or a fraudster and then puts in controls proportionate to the risk.
Pick the three most expensive raw materials you buy and ask: how do we know they are authentic?
FSSC 22000 Version 7 Readiness Checklist
A two-page gap check of the Version 7 additional requirements: purchasing, labelling, food defence, food fraud, allergens, culture, quality control, equipment and more.