Food fraud and food defence in BRCGS – how to protect your facility against deliberate food contamination and adulteration?

Food safety risks are most often associated with accidental errors – insufficient heat treatment, microbial contamination, or human error on the production line. However, BRCGS Food Safety Issue 9 has for years required consideration of threats of a completely different nature: deliberate food adulteration for financial gain (food fraud) and deliberate product contamination by a malicious individual (food defence). Both areas are verified during the audit and are among the most difficult requirements to implement correctly.

Food fraud – what it is and why the standard requires it

Food fraud refers to the deliberate marketing of a product that does not meet its declared characteristics, with the aim of gaining an economic advantage. It can take many forms: dilution of the active ingredient (e.g. olive oil with sunflower oil), substitution of species (lower-grade fish sold as a more expensive variety), under-declaration of the ingredient’s content on the label, incorrect labelling of the country of origin, or false certificates.

BRCGS Food Safety Issue 9 requires a food fraud vulnerability assessment to be carried out for all raw materials and ingredients. The organisation must identify which raw materials are at risk of fraud, assess the likelihood and consequences of this risk, and then implement a food fraud risk mitigation plan comprising specific measures to reduce the identified vulnerabilities. The plan must be regularly reviewed and updated – at least once a year or following any significant change in the supply chain.

In practice, the raw materials at highest risk of food fraud are those of high economic value or rarity, with a complex supply chain, global origin and limited traceability of composition – olive oil, honey, fruit juices, fish, spices, meat and meat products, herbs and plant extracts. For these categories, the risk mitigation plan must be particularly specific.

Food defence – protecting a facility against deliberate acts of sabotage

Food defence is a requirement distinct from food fraud, although the two are often confused. Whilst food fraud involves the adulteration of a product for financial gain, food defence addresses the risk of deliberate contamination of a product or the facility’s infrastructure by a malicious individual – an employee, an intruder or an external party – without any financial motive.

BRCGS Food Safety Issue 9 requires a food defence risk assessment to be carried out, covering the identification of areas of the facility and process stages vulnerable to deliberate contamination. Based on this assessment, the organisation must implement documented protective measures – physical, procedural and organisational – to mitigate the risk of unauthorised access to the product or production process.

Protective measures may include controlling access to production and storage areas (locks, access card systems, entry logging), procedures for verifying the identity of visitors and suppliers, CCTV monitoring of key areas, securing raw materials and semi-finished products against unauthorised access, procedures for dealing with staff in conflict situations, and food defence incident response plans. Key personnel must be trained to recognise and report suspicious activities.

Vulnerability assessment – how to carry it out correctly

The most common mistake when implementing food fraud and food defence requirements is treating them as a mere formality – copying a standard risk assessment template without adapting it to the specific characteristics of the facility and raw materials. BRCGS auditors verify whether the assessment reflects the organisation’s actual risk profile.

A proper food fraud vulnerability assessment should consider four dimensions of each raw material: opportunity (how easily this raw material can be adulterated without detection), motivation (how much profit can be made from adulteration), vulnerability (how difficult it is to detect adulteration using standard control methods) and history (whether the raw material or supplier has been linked to food fraud incidents in the past). Based on this analysis, raw materials are classified according to risk levels, and for those with a high risk, additional verification measures are implemented – laboratory tests, supplier audits, certification requirements.

A food defence risk assessment, on the other hand, should physically map the facility – identifying all entry points, storage areas for raw materials and finished products, stages of the production process involving open products, and areas of particular vulnerability. For each identified risk area, appropriate protective measures must be defined, along with a person responsible for their implementation and monitoring.

The most common non-conformities identified during audits

• An assessment of vulnerability to food fraud based on a template without adaptation to specific raw materials, suppliers and supply markets – auditors verify whether the scope of the analysis covers all raw materials used and whether the justification for the risk classification is substantive
• A risk mitigation plan lacking specific actions – general statements (“we verify suppliers”) without specifying how verification is carried out in practice, who carries it out and how often
• Failure to update following a change of supplier or raw material – an assessment carried out once and not updated for years, despite changes in the supply chain
• Food defence treated as a synonym for food fraud – no separate assessment of the risks of deliberate contamination and no documented physical security measures for the facility
• Lack of staff training on recognising and reporting suspicious activities – a requirement verified by auditors through direct interviews with employees at various levels