ISO 22380:2018, ‘Security and resilience – Authenticity, integrity and trust for products and documents’ is the new international standard aimed at the prevention of food fraud. Under the aegis of combating criminal activities in the agri-food chain, for the better protection of food safety and public health.
Food fraud, a phenomenon still lacking definitions and harmonized regulations
The regulations against fraud food date back to ancient Egypt, were reintroduced in ancient Rome and still apply, in various forms, in different national legal systems. (1) In Europe as elsewhere, with sanctioning regimes ranging from simple fines to the death penalty, in countries such as China.
In Europe however, there is still no harmonized definition of food fraud. And the Commission led by Jean-Claude Juncker, beyond the false proclamations of Commissioner Vytenis Andriukaitis, has done nothing but relegate the phenomenon to a special ‘Knowledge Center’.
The Foundation FSSC (Food Safety System Certification) has instead taken an interest in addressing the phenomena of ‘food fraud mitigation and food defense’ with specific Guidelines.
ISO (International Standard Organization) has in turn developed an international reference standard, ISO 22380:2018. Which fits into the series of ISO 22000 standards, dedicated to systems safeguarding food safety throughout the entire course of the ‘supply-chain’. (3) From primary agricultural production to distribution and administration (‘food service’). Without excluding the production and use of substances, materials and articles intended to come into contact with food (‘Food Contact Materials’ or FCM ).
Food fraud, according to ISO, it is characterized by the following elements:
– intentionality of the unlawful act, by its material authors and/or paragraphsauthors,
– economic motivation, aimed at an illegal profit,
– deception or fraud, which affects the consumer.
GSFI (Global Food Safety Initiative) has then divided fraudulent cases into two categories:
– sale of harmful foods, or potentially such. For example, unsafe or expired foods and/or ingredients, animal-origin ingredients without traceabilityà, unauthorized additives,
– data falsification related to food (e.g. farmed fish products presented as wild catch, animal species and varietiesà fruits and vegetables substituted with cheaper alternatives economical, false declarations of origin or provenance).
ISO 22380:2018, food safety and resilience
Resilience is the key word that ISO 22380 associates with the guarantee of food safety with respect to the risk of food fraud. In materials technology, resilience expresses the ability to resist breakage under dynamic stress (and is measured with a specificimpact test). By analogy, the ‘food safety management system’ must be strengthened to the extent that it can resist ‘economically-motivated adulteration’. It is no longer enough to reason in terms of ‘food safety’ or ‘food defense’, the effective HACCP plans and anti-tampering procedures must be integrated.
ISO 22380:2008, ‘Security and resilience – Authenticity, integrity and trust for products and documents – General principles for product fraud risk and counter measures’ offers valid support to all organizations, even outside the food sector. As in every management system, with a view to improvement.
The standard is based on the analysis of the context – external (market, suppliers, etc.) and internal – for the mapping of areas vulnerable to fraud events. As a premise for the design, review, and implementation of procedures aimed atmitigatesthe identified risks. The vulnerability analysis must consider, in particular:
– ingredients and products more prone to fraud attempts, due to intrinsic characteristics and historical data (e.g. fruit juices more than fresh fruits, extra virgin olive oil more than seed oils),
– market pressure (e.g. price list fluctuations, sudden increases in demand for an ingredient or the extension of its use)
– factors under the control of buyer (quality controlà, traceabilityà).
The measures to be consolidated or to be structured from scratch to prevent fraud require the adequacy of purchase specifications (which must include criteria suitable to thwart any attempts of fraude, e.g.. UV absorption test for EVOO) and the suitabilityà of the analysis plan (the budgeted analytical set must therefore also include authenticity indicatorsà). In addition to continuous attention to external signals (which come from alert systems, bibliography and trade press, intelligence activities intelligence).
The relationship with suppliers is an essential phase to focus on. If the customer is the goal to achieve, the suppliers are the foundation. The relationship with them cannot be limited to the meeting scheduled at price list renewal nor to generic contractual clauses safeguarding food safety. It is essential instead to establish and monitor over time the reliability level of each of them. It is precisely necessary to maintain a relationship also on the operational level of quality control. Through regular activitiesà By audittand the periodic rotation of the responsible parties.
Dario Dongo and Giulia Baldelli
Notes
(1) For more details, see our free ebook ‘Food safety, mandatory rules and voluntary standards', come on https://fareagrifood.com/wp-content/uploads/2025/11/SICUREZZA-ALIMENTARE.-REGOLE-COGENTI-E-NORME-VOLONTARIE.pdf
(2) Cf. penal code, art. 515, commercial fraud. See the article https://www.foodagriculturerequirements.com/approfondimenti_1/frode-in-commercio-ed-etichette-alimentari-i-casi-atipici. About the measures a contrast of the frauds provided for by EU reg. 2017/625, see also https://www.foodagriculturerequirements.com/archivio-notizie/controlli-pubblici-ufficiali-rating-degli-operatori-e-trasparenza-si-preannuncia-una-svolta, https://www.foodagriculturerequirements.com/archivio-notizie/controlli-pubblici-ufficiali-le-misure-a-contrasto-delle-frodi-alimentari-previste-nel-nuovo-regolamento-ue-2017-625
(3) Regarding the ISO 22000 standard, the previous articles are cited https://www.greatitalianfoodtrade.it/iso-22000/iso-22000-filiera-sicura, https://www.foodagriculturerequirements.com/cosa-facciamo/iso-22000-2005-e-iso-9001-2015, https://www.greatitalianfoodtrade.it/iso-22000/iso-22000-pianificazione
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT – Food Times) and Égalité.
Graduate in chemistry and pharmaceutical technologies with a nutritional focus, expert in quality management systems, social responsibility and supply chain
