Food fraud — protecting food from economic deception
Plain-language summary
A vulnerability assessment and a mitigation plan for economically motivated adulteration, substitution and mislabelling, built by competent people and integrated into the FSMS.
What the clause is really asking
Food fraud is deception for gain: diluted oils, substituted species, mislabelled origin, counterfeit packaging. Version 7 anchors the requirement to ISO 22002-100:2025 clause 16.3 and, like food defence, requires the vulnerability assessment (commonly VACCP) and the mitigation plan to be developed and maintained by people with appropriate knowledge and competence, implemented and supported by the FSMS, legally compliant, covering every product and process in scope, and kept current. Brokers and traders (FII) must ensure their suppliers have a mitigation plan of their own.
What auditors look for
Auditors look at your ingredient list and ask which items carry real fraud history (spices, honey, oils, seafood, 'premium' claims) and whether your assessment rates them that way. They ask what data the assessment used, who did it and why they are competent, and how the mitigation plan changed supplier approval or incoming testing.
Typical evidence
Vulnerability assessment with scoring rationale and review date; competence records for the assessment team; mitigation plan linked to supplier approval and incoming inspection; horizon-scanning sources (fraud databases, alerts); FII supplier plan evidence
How to comply — recommendations
Assess ingredient by ingredient using real signals — price spikes, supply shortages, complexity of the chain, ease of adulteration, detectability — and record where the signals came from. Convert high scores into concrete mitigations: certificates of analysis, origin verification, targeted tests, audits. Refresh the assessment when ingredients, suppliers or markets change, not just annually.
Common nonconformities
Generic assessment that rates everything low; no data source behind the scores; mitigation plan not connected to purchasing or testing; assessment older than the current ingredient list; team with no recorded competence
Related clauses
ISO 22002-100:2025 clause 16.3 (food fraud); ISO 22000 7.1.6 (suppliers), 8.5.2; FSSC 22000 2.5.1, 2.5.3
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