Food Fraud Mitigation Strategies

Aligned with SQF Code Edition 9 – System Element 2.8.2

Requirement Overview

SQF Code Edition 9, System Element 2.8.2, requires:

“Mitigation strategies shall be developed and implemented for those ingredients identified as being at risk of economically motivated adulteration as per 2.8.1.”

Once high-risk ingredients have been identified through a food fraud vulnerability assessment, organizations must take proactive and documented steps to reduce or eliminate the chance of fraud.

Disclaimer: Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). This resource is intended for internal education and compliance support. For official documents, visit www.sqfi.com.

Key Compliance Objectives

  • ✓ Prevent fraud in high-risk ingredients identified in vulnerability assessments

    ✓ Strengthen supplier qualification and trust through verification

    ✓ Establish a testing program for ingredient authenticity

    ✓ Integrate food fraud mitigation into quality, purchasing, and procurement systems

Step-by-Step Compliance Implementation

1. Prioritize Ingredients for Mitigation

  • Use these criteria to rank ingredients by fraud risk:

    • • Results from the Food Fraud Vulnerability Assessment (SQF 2.8.1)

      • Known global fraud issues (e.g., turmeric, honey, olive oil)

      • Ingredient format (e.g., powder, blend, high-value items)

      • Complexity and transparency of the supply chain

    Evidence to Maintain:

    • • List of prioritized ingredients

      • Risk justification for each based on fraud history or supply chain risk

2. Develop and Document Mitigation Measures

  • Mitigation strategies may include:

    • • Documented supplier approval and requalification procedures

      • Certificates of authenticity and validated Certificates of Analysis (COAs)

      • Authenticity testing for targeted ingredients

      • Packaging with tamper-evident seals or serialized identifiers

    Evidence to Maintain:

    • • Mitigation plans per high-risk ingredient

      • Documentation of supplier qualification and monitoring

      • SOPs outlining COA verification process

3. Implement Supplier Verification Protocols

  • Supplier controls should be risk-based and include:

    • • Regular supplier audits

      • Ingredient origin or batch-level traceability

      • Verification of authenticity documentation

      • Adjusted testing frequency based on supplier or material risk

    Evidence to Maintain:

    • • Supplier audit reports and approval records

      • COA verification logs

      • Risk-based supplier scorecards

4. Conduct Routine Authenticity Testing

  • Testing recommendations:

    • • Use validated methods (e.g., FTIR, DNA barcoding, isotope analysis, HPLC)

      • Include both random and scheduled testing

      • Rotate high-risk ingredients and adjust scope annually

    Evidence to Maintain:

    • • Testing schedules and reports

      • Non-conformance documentation with corrective actions

      • Retest procedures and investigation outcomes

5. Verify and Review Mitigation Effectiveness

  • Continuous Improvement Actions:

    • • Compare test results to historical benchmarks

      • Revise strategies following incidents or supplier issues

      • Perform an annual review of all food fraud mitigation plans

    Evidence to Maintain:

    • • Annual program review summary

      • Mitigation strategy updates

      • Documentation of corrective actions related to fraud risks

Common Audit Findings & Recommended Fixes

Audit Finding Suggested Solution
No documented mitigation plan Create written strategies linked to each risk score
Supplier testing not performed Implement and log a testing schedule
No review or update of strategy Set calendar-based reviews and document changes
Unverified COAs from suppliers Add a COA verification step to receiving QA workflows

Auditor Verification Checklist

During an audit, be prepared to provide:

  • • Ingredient-specific mitigation strategies

    • Supplier verification and approval documentation

    • Testing protocols and result summaries

    • Annual review and continuous improvement records

Implementation Roadmap

Build Your Program

  • ✓ Identify high-risk ingredients based on vulnerability assessment

    ✓ Document mitigation strategies and SOPs

Train and Validate

  • ✓ Educate QA, purchasing, and receiving staff

    ✓ Establish COA and authenticity verification steps

Operate and Monitor

  • ✓ Conduct regular fraud testing on flagged ingredients

    ✓ Maintain supplier audit and requalification records

Improve Continuously

  • ✓ Perform annual reviews of strategy effectiveness

    ✓ Update documentation in response to market or supply changes

Why This Matters?

Robust food fraud mitigation strategies:

  • ✓ Reduce the likelihood of economically motivated adulteration

    ✓ Support consumer safety and brand protection

    ✓ Help avoid costly recalls and regulatory action

    ✓ Fulfill SQF and GFSI benchmarking requirements

Need Help Setting Up or Reviewing Your Food Fraud Program?

Food Safety Systems offers:

  • ✓ Editable mitigation strategy templates by ingredient

    ✓ Testing SOPs and COA verification procedures

    ✓ Supplier approval checklists and audit tools

    ✓ Risk prioritization tools and annual review templates

GET STARTED NOW

This document is for internal training and compliance use only. It is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI).

Please refer to www.sqfi.com for official certification requirements.