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Food Fraud Vulnerability Assessment: How to Score VACCP

RISK ASSESSMENT · FOOD FRAUD AND VACCP

Food Fraud Vulnerability Assessment: Scoring VACCP Without Guessing

By Mthokozisi Nkosi, Food Safety Specialist & Lead Auditor, ASC Food Safety · 14 min read

ASC Food Fraud Vulnerability VACCP Risk Assessment Template RA18 for South African food manufacturers

Food fraud is intentional deception for economic gain using food. BRCGS Global Standard Food Safety Issue 9 handles it in clause 5.4, product authenticity, claims and chain of custody, and the FSSC 22000 additional requirements include food fraud mitigation. A VACCP assessment scores each raw material on opportunity and motivation, then on the strength of existing control. The Food Fraud Vulnerability (VACCP) Risk Assessment Template (RA18) is R690.

At a glance

What it addresses
Deliberate adulteration, substitution, dilution, concealment, mislabelling, counterfeiting and diversion, all motivated by money rather than by harm
BRCGS requirement
Issue 9, published 1 August 2022, clause 5.4: product authenticity, claims and chain of custody
Fundamental clause behind it
Clause 3.5.1, supplier approval, is one of the twelve fundamental requirements of Issue 9. a major non-conformity against its statement of intent is a fail, and certification is off the table. What happens to the audit itself is then agreed between the auditor, the certification body and site management: it can end there, or it can carry on as a non-certification gap audit. Either way a further full audit is needed before the site can be certified
FSSC 22000
Food fraud mitigation sits in the FSSC additional requirements, set out in Part 2 of the scheme document
Unit of assessment
The raw material and its supply chain, not the site as a whole
Scoring
Opportunity 1 to 5 multiplied by motivation 1 to 5 gives an inherent score out of 25. Controls reduce opportunity, never motivation
Template
Food Fraud Vulnerability (VACCP) Risk Assessment Template (RA18), R690, register plus procedure plus completion guide plus read me
Training
Food Fraud (VACCP) and Food Defence (TACCP), R1,450, self paced online with lifetime access

If your VACCP register is one page and covers everything

A single sheet that scores “all raw materials” as medium is the register I most often see on a first audit. The RA18 pack arrives with the scoring procedure written, a register laid out by material and supply chain, worked example rows, a completion guide for each field and a read me telling you what to change for your site. Editable Word and Excel, mapped to BRCGS, IFS and SQF clauses.

Food Fraud Vulnerability (VACCP) Risk Assessment Template, R690 Ask ASC to build your vulnerability assessment

What food fraud is, and how it differs from food defence and food safety

Food fraud is intentional deception for economic gain using food, and BRCGS Issue 9 handles it at clause 5.4, product authenticity, claims and chain of custody. Food defence, assessed through TACCP, addresses deliberate acts intended to cause harm. Food safety, controlled through HACCP, addresses hazards that arise without anyone intending them. The hazard can look identical in all three cases. The motive is different, so the assessment method, the team and the controls are different too.

This distinction is not academic. It decides what your register looks like. A HACCP study works forward through your process steps. A food defence assessment works through points of access and the people who hold them. A food fraud assessment works through raw materials and the supply chains that deliver them, and it asks a question your HACCP study never asks: who would make money from this, and would we notice?

The 2013 European horsemeat incident is the clearest illustration. The Food Safety Authority of Ireland announced on 15 January 2013 that DNA testing had found horse meat in beef products on sale in Irish and British supermarkets. Some products were later found to be almost entirely horse. Horse meat is not a safety hazard in itself, and the incident was reported as a mislabelling and traceability failure rather than an acute health event. No HACCP plan in Europe was designed to detect it, because HACCP looks for hazards, and this was a business model.

Melamine adulteration of dairy in China in 2008 shows the second pattern. Melamine is nitrogen rich, and the Kjeldahl and Dumas methods used to measure protein do not distinguish nitrogen from melamine from nitrogen in amino acids. Adding it raised the apparent protein figure. It was an economic act with a severe health outcome, and it worked precisely because it defeated the routine test. That is what makes food fraud a vulnerability question rather than a hazard question: the fraudster designs around your controls.

In one line: HACCP scores process steps against hazards nobody intended, TACCP scores points of access against people who intend harm, and VACCP scores raw materials against people who want margin. Our published guide to food defence and TACCP sets out the full definitional comparison, so this article stays on the vulnerability assessment itself.

Sites conflate the two intentional assessments more often than they conflate either with HACCP, and it is the single most reliable way to collect a finding in this area. Keep the two registers separate even where one team writes both.

HACCP asks what can go wrong. VACCP asks who would gain, and whether your current checks would catch them.

One register for both studies is the finding, not the shortcut

RA18 and RA02 are separate packs on purpose, at R690 each, and they share a register structure so they cross reference each other instead of merging into one sheet an auditor will open first.

Buy the Food Fraud Vulnerability (VACCP) pack, R690 Add the Food Defence (TACCP) pack with video, R690 Ask us which one you need first

The seven recognised types of food fraud

Seven types cover the field: dilution, substitution, concealment, unapproved enhancement, mislabelling, counterfeiting, and grey market production, theft and diversion. The draft Codex text adopted at Step 5 on 28 November 2024 covers the same ground in six categories of its own. The Food Authenticity Network, led by LGC, groups these under four headings, with the first four treated as adulterant substances. Naming the type matters because each type is defeated by a different control.

TypeWhat it meansControl that actually finds it
DilutionMixing a high value liquid or bulk material with a cheaper one of similar appearanceMass balance, quantitative authenticity testing, specification limits on marker compounds
SubstitutionReplacing all or part of a high value ingredient with a lower value oneSpecies or variety identification, supplier verification, unannounced sampling at receipt
ConcealmentHiding the poor quality of an ingredient or product, for example masking spoilage or off colourIncoming inspection against a written specification, sensory panels, screening for masking agents
Unapproved enhancementAdding an undeclared substance to improve an apparent quality attributeNon targeted screening, method review, testing that does not rely on the attribute being faked
MislabellingFalse claims on the pack: origin, variety, production method, date, weight, certificationChain of custody records, artwork control, claim validation, certificate verification at source
CounterfeitingCopying a brand, pack, recipe or process without authorisationPack security features, authorised distributor lists, market surveillance
Grey market, theft and diversionStolen or diverted stock re entering commerce, or product moved outside its intended marketTraceability and reconciliation, control of rejected and downgraded stock, destruction records

Codex is developing its own guidelines on the prevention and control of food fraud through the Codex Committee on Food Import and Export Inspection and Certification Systems. That text was adopted at Step 5 by the 47th session of the Codex Alimentarius Commission on 28 November 2024 and identifies six types: addition, substitution, dilution, counterfeiting, misrepresentation, and concealment of information about food safety or quality. It is still in development, so do not cite it as a finalised standard, but the overlap with the seven type model is close enough that a register built on either will map to the other.

Name the type in the register

Add a column to your register called “fraud type” and force the team to choose from the seven. It stops the assessment collapsing into a single vague worry about “quality” and it makes the mitigation column write itself, because a dilution risk and a mislabelling risk are answered by different evidence.

Why the certification schemes require a vulnerability assessment

Every GFSI recognised scheme requires a documented food fraud vulnerability assessment because the 2013 horsemeat and 2008 melamine incidents both proved that a certified site with a working HACCP plan can still ship an adulterated product. GFSI itself does not certify anyone. It benchmarks schemes, and the schemes it recognises now carry the requirement in their own words.

In BRCGS Global Standard Food Safety Issue 9, published 1 August 2022 and still the current issue, product authenticity, claims and chain of custody is section 5.4. That is where the documented vulnerability assessment for raw materials lives, together with the requirements around claims and the systems that support them. It does not stand alone. Clause 3.5.1, supplier approval, is one of the twelve fundamental requirements of Issue 9, and a major non-conformity against its statement of intent is a fail, and certification is off the table. What happens to the audit itself is then agreed between the auditor, the certification body and site management: it can end there, or it can carry on as a non-certification gap audit. Either way a further full audit is needed before the site can be certified. A vulnerability assessment that identifies a high risk material, and a supplier approval programme that never mentions it, is a gap between two clauses that an experienced auditor will find in the first hour.

For FSSC 22000, food fraud mitigation is one of the FSSC additional requirements, the set of scheme specific requirements that sit on top of ISO 22000:2018 and the sector prerequisite programme standard. FSSC 22000 Version 7 was published in May 2026, replacing Version 6, and the additional requirements remain part of the scheme. If you are working through that transition, our complete guide to FSSC 22000 Version 7 in South Africa sets out the dates and the change list.

There is also a legal reason that has nothing to do with certification. Section 61 of the Consumer Protection Act 68 of 2008 imposes liability on producers, importers, distributors and retailers for harm caused by unsafe goods, product failure, defects or hazards, or by inadequate instructions or warnings, and it does so irrespective of negligence. Section 41 deals with false, misleading or deceptive representations. If an adulterated raw material reaches a consumer through your brand, the vulnerability assessment is part of what you produce to show what you assessed and what you did about it.

7recognised types of food fraud
5.4BRCGS Issue 9 clause on authenticity, claims and chain of custody
25highest inherent vulnerability score, opportunity 5 by motivation 5
R690Food Fraud Vulnerability (VACCP) Risk Assessment Template (RA18)

Forty documents outstanding is a schedule problem, not a budget problem

You cannot write forty documents in the weeks you have left, and buying them one at a time is the slowest route there is. The BRCGS Food Safety toolkit carries 220 or more documents, indexed and cross referenced across all nine sections of Issue 9, in editable Word and Excel, and it includes one hour of premium consultation with one of our consultants.

BRCGS Food Safety Toolkit, R6,550 Talk to ASC about the raw materials most at risk of fraud

Fumigation certificates on inbound loads are supplier assurance records, and they can be falsified like any other document

ASC Pest Control is part of the ASC Food Safety Consultants group, owned and designed by food safety specialists, a SAPCA member with pest control operators registered under Act 36 of 1947, and built around what a BRCGS, FSSC 22000 or R638 audit or inspection actually asks for. Service reports, barcoded device monitoring and trend analysis live in the My ASC Pest Control Hub, so the pest file is audit ready before anyone asks for it. ASC Pest Control serves Gauteng and the Eastern Cape.

Food and beverage pest control by ASC Request a pest control site assessment

What a VACCP assessment must contain

Clause 3.5.1 of BRCGS Issue 9 is a fundamental requirement, and the assessment that feeds it contains a scope statement, a named team with evidence of competence, a complete raw material list including packaging and outsourced processes, a supply chain map for each material, a scoring method written down before it is used, the scores themselves with reasons, a mitigation plan with owners and dates, horizon scanning evidence, and a review record. Nine parts. Most registers arrive with fewer than half of them.

The two that get left out most often are the competence evidence and the horizon scanning evidence. BRCGS expects the individual or team doing the assessment to understand food fraud, including knowledge of the raw materials the site uses and the principles of vulnerability assessment. In practice that means training records, not a job title. The Food Fraud (VACCP) and Food Defence (TACCP) course at R1,450 is the shortest route to that evidence for a team of two or three, and it covers both assessments so you are not buying the same competence twice.

  1. Define the scope honestlyEvery raw material, every processing aid, every packaging material that carries a claim or a printed statement, every outsourced process such as contract blending or third party storage, and every service that touches the product. Packaging is where most scopes stop too early.
  2. Map the supply chain per materialNot “supplier X”. Name the grower or primary producer where you can, then the processor, the trader or broker, the importer, the agent and the transporter. Count the steps. The number of hands between origin and your gate is one of the strongest predictors of vulnerability you have.
  3. Write the scoring method before scoringDefine what a 1 and a 5 mean for opportunity and for motivation, in words, with examples from your own materials. Define the bands and what each band obliges you to do. A method written after the scores is a method built to justify them.
  4. Score inherent vulnerabilityOpportunity multiplied by motivation, with a written reason in each row. The reason column is what the auditor reads. A score with no reason is a number, not an assessment.
  5. Record existing controls and their evidenceName the control, the document that describes it, the person who owns it and the record that proves it happened. A control with no record does not reduce a score.
  6. Re-score with controls appliedControls reduce opportunity. They do not reduce motivation. Re-score opportunity only, and calculate the residual vulnerability. This keeps the assessment honest and it stops the register drifting to green.
  7. Write the mitigation plan for anything above the thresholdAction, owner, date, and the evidence that will close it. Then put review dates on the calendar and link the whole register to your supplier approval programme.

How to score vulnerability: opportunity, motivation and control

Score two things and record a third, which is how the RA18 register at R690 is built. Opportunity, from 1 to 5, is how easily this material could be adulterated or substituted without your current checks noticing. Motivation, from 1 to 5, is how much money is available from doing it. Multiply for an inherent score out of 25. Control strength, from 1 to 5, is recorded separately, and it works by reducing opportunity on the second pass.

Opportunity is a property of the material and the chain, not of the supplier’s character. Score it on physical form, on the number of intermediaries, on whether the material is bought on a specification you can test, and on how hard the relevant test is. Whole peppercorns are harder to falsify than ground pepper. A material bought direct from a single named processor has less opportunity than the same material bought through two traders.

Motivation is a property of the market. Score it on the value gap between the genuine material and the plausible substitute, on price volatility over the past two years, on supply shortage, and on whether a premium claim rides on the material. A crop failure or a currency move that widens the gap raises motivation for every buyer in the market at the same time, which is why horizon scanning feeds this column and nothing else does.

Controls cannot reduce motivation

This is the error that quietly ruins most registers. A team applies a control, then lowers both scores, and the residual figure drops below the action threshold. You cannot change what a fraudster stands to gain. You can only change how easily they get past you. Reduce opportunity on the second pass and leave motivation exactly where it was.

ScoreOpportunity: could it be done without us noticing?Motivation: is there money in it?Control strength
1Single step chain, bought direct, tested on receipt by a method that would detect the fraudNo meaningful value gap, stable price, no premium claimValidated control with records, verified at the source
2Short chain, known processor, routine testing that would probably detect itSmall value gap, stable supplyDocumented control with consistent records
3Two or more intermediaries, specification exists but the fraud is not covered by routine testingNoticeable value gap or recent price movementControl exists, records incomplete or unverified
4Long or opaque chain, material is ground, blended, powdered or concentrated, testing is specialistLarge value gap, volatile price, premium claim on the packControl described but not implemented consistently
5Origin unknown, brokered, no test in place that would detect the likely adulterantSevere shortage or a price spike, high premium, documented history of fraud in this commodityNo effective control

Set the bands and the obligation each one carries before you score. We use 1 to 6 as low, 8 to 12 as medium and 15 to 25 as high, which uses every possible product of two scores from 1 to 5 without leaving a gap. Low means the existing controls stand and the material is reviewed annually. Medium means a named monitoring action with a frequency. High means a written mitigation plan with an owner and a date, and a shorter review interval.

Get the scoring method out of your head and onto paper

Most teams lose a fortnight arguing about the matrix before a single material is scored. The RA18 pack arrives with the definitions written for opportunity, motivation and control strength, the bands set, the register laid out by material and supply chain, worked example rows to argue with, and a completion guide that explains every field. Editable Word and Excel, mapped to BRCGS, IFS and SQF clauses.

Food Fraud Vulnerability (VACCP) Risk Assessment Template, R690 Send us your supplier list and we will rank the exposure

Worked example: seven materials scored

The table below is a worked example built to show the method, not a statement about any real supplier, product or company. The scores are illustrative. Your own scores must come from your own materials, your own chains and your own control records, and the reason column is what makes them defensible.

Raw material (illustrative)OpportunityMotivationInherent (O x M)Control strengthResidual opportunityResidual vulnerabilityBand and action
Ground paprika, imported through a broker, origin not named on the certificate of analysis55252420High. Mitigation plan: named origin on specification, direct processor contact, colouring agent screening on every consignment
Honey, bulk, blended origin, single trader54202416High. Mitigation plan: origin declaration, sugar syrup marker testing on a stated frequency, mass balance quarterly
Extra virgin olive oil, imported bulk, sold on a variety claim45203315High. Mitigation plan: chain of custody to the mill, authenticity testing on first delivery per season, claim validation on file
Frozen white fish fillet, imported, sold by species name44163312Medium. Species identification on a defined sampling plan, supplier declaration per consignment
Skimmed milk powder, imported, approved supplier with audit history4416428Medium. Certificate of analysis verification against an independent check twice a year, protein method reviewed
Refined white sugar, local mill, direct contract224412Low. Existing specification and approved supplier controls stand. Annual review
Corrugated shipper cartons, local converter, direct122412Low. Existing controls stand. Reassess if the carton carries a certification logo

Two things about this table matter more than the numbers. The first is that low scores appear in it. A register in which every material lands in the medium band tells an auditor the team scored to avoid work rather than to find out anything. The second is that control strength moves the opportunity column and nothing else. Skimmed milk powder and frozen fish fillet share the same inherent score of 16, and they separate only because one has a stronger control history.

Have us score it with your team, on your site

If your raw material list runs past a hundred lines, or if a customer has asked for the assessment before their own audit, we can run the material mapping, chair the scoring session and write the register with your technical team, then link it to your supplier approval programme. Gqeberha head office, 14 Brickmakers Kloof Road, +27 41 004 0382. Johannesburg +27 10 500 4661. Cape Town +27 21 300 4024. Consultation from R480 an hour, and a full project is scoped and quoted as one figure.

See our consulting services Ask ASC which assessment you need first

The raw material characteristics that raise vulnerability

Six characteristics do most of the work in a vulnerability score, and the 2013 horsemeat substitution carried most of them: price volatility, complex supply chain, geographic concentration, ease of substitution, economic incentive and testing difficulty. Score each material against all six and the opportunity and motivation figures stop being opinions. Materials that carry four or more of these should never sit in the low band without a written justification.

📈Price volatilityA material whose price has swung sharply in two years invites substitution at the peak. Track your own purchase price history: it is free intelligence and it sits in your own accounting system.
🚚Complex supply chainCount the hands between the primary producer and your gate. Brokers, agents, repackers and consolidators each add a point where a document can be changed and a material swapped.
🌎Geographic concentrationWhere one region supplies most of the world’s volume, a bad season there raises motivation everywhere at once. Concentration also makes origin claims harder to verify independently.
🧭Ease of substitutionGround, powdered, minced, concentrated, blended, filleted. Anything that destroys the visual identity of the raw material makes substitution cheap and detection expensive.
💰Economic incentiveThe value gap between genuine and substitute, multiplied by volume. A small gap on a material you buy by the container is a larger prize than a big gap on twenty kilograms.
🔬Testing difficultyIf the fraud can only be detected by a method you do not have, cannot afford or would need a specialist laboratory to run, opportunity rises regardless of how good your paperwork is.

Add a seventh in practice: whether the material carries a claim. Organic, halaal, kosher, free range, non GMO, single origin, fair trade and variety claims all move value onto a piece of paper, and paper is cheaper to falsify than food. Any material supporting a claim on your pack belongs in the assessment even where the material itself is cheap, because the fraud target is the certificate, not the commodity.

Somebody has to explain why paprika scored higher than sugar

An auditor will ask your food fraud team to explain why paprika scored higher than sugar. The Food Fraud (VACCP) and Food Defence (TACCP) course at R1,450 covers both assessments, the scoring logic and the mitigation options, self paced online with lifetime access and a QR verifiable certificate. ASC does not charge VAT on training, so the price shown is the price paid.

Food Fraud (VACCP) and Food Defence (TACCP), R1,450 Talk to ASC about a horizon scan for your materials

How horizon scanning works and where to get intelligence

Horizon scanning is the routine of checking external sources such as the RASFF Window and the FDA import alerts for emerging fraud in your commodities, recording what you found, and deciding whether it changes a score under clause 5.4 of BRCGS Issue 9. Auditors want a dated log rather than a folder of printouts: which sources were checked, what was relevant, what was not, and which register rows changed as a result.

  • RASFF Window, the European Commission’s public database of Rapid Alert System for Food and Feed notifications, searchable from 2020 onward at webgate.ec.europa.eu. Filter by product category and by hazard category to see what is being detected and where.
  • United States FDA import alerts, published at accessdata.fda.gov, which list products and firms subject to detention without physical examination. Browsing by country and industry shows you which commodities are under sustained suspicion.
  • Food Authenticity Network, led by LGC and run as a public private partnership at foodauthenticity.global. Open access guidance, authenticity methods, centres of expertise and a document library. This is the source to use when you need to know whether a test for a given adulterant exists at all.
  • UK Food Standards Agency alerts at alerts.food.gov.uk, a searchable list of food alerts, allergy alerts and product recalls, filterable by type and date.
  • National Consumer Commission product recalls at thencc.org.za, which publishes product safety recalls notified in South Africa across food and non food categories.
  • Europol and INTERPOL Operation OPSON reports, the annual joint operation against counterfeit and substandard food and drink. The OPSON XIV results reported seizures worth EUR 95 million across 31 countries, more than 11,500 tonnes of food and 1.4 million litres of beverages, with 631 individuals reported to judicial authorities.
  • Your own data, which most sites ignore. Unexplained supplier price drops, sudden willingness to supply a scarce material, changes in certificate of analysis format, goods receiving rejections, mass balance variance, customer complaints about taste or colour, and laboratory results drifting toward a specification limit rather than sitting around a mean.

Set a frequency and keep it. Quarterly is workable for most manufacturers, monthly if you buy heavily traded commodities. Assign it to a named person, give them thirty minutes and a template, and require an entry even when the answer is that nothing changed. A log with four dated entries a year and two register changes is stronger evidence than fifty pages of unread alerts.

Scan by commodity, not by brand

Search the databases for your material categories rather than for supplier names. Fraud moves through commodities. If honey adulteration is being detected across three continents, that raises the motivation score on your honey no matter how good your supplier is, and the register should show that you noticed.

The other half of the intentional pair

If your certification body has asked for food fraud, they will ask for food defence in the same audit. Scoring access points, screening, seals and site security needs a separate register with its own logic. The Food Defence (TACCP) Risk Assessment Template (RA02) at R690 covers TACCP with a register, procedure, completion guide, read me and an instructional video, so the two assessments arrive complete rather than as one document doing half of each job.

Food Defence (TACCP) Risk Assessment Template, R690 Ask ASC for a quote against your supply base

Mitigation that stands up at audit

Mitigation stands up at audit when it is specific to the material, owned by a person, evidenced by a record and proportionate to the score. Six controls carry most of the weight: the raw material specification, supplier approval at clause 3.5.1 of BRCGS Issue 9, testing, mass balance, traceability, and authenticity testing where the claim or the value gap justifies the cost. Generic statements about supplier relationships carry none.

ControlWhat it must actually say or doEvidence an auditor asks for
Raw material specificationState the authenticity criteria, not only the safety and quality criteria. Named species, variety, origin, production method, marker compound limits, and the tests that verify themSigned current specification, agreed by the supplier, version controlled, matching what the label claims
Supplier approvalRisk based approval that reflects the VACCP score. High band materials need more than a questionnaire: a certificate check at source, an audit, or a site visitApproval records, valid certificates verified with the issuing body, audit reports, the approval decision and who made it
Change notificationA contractual obligation on the supplier to notify any change of source, sub supplier, process or formulation before it happensThe clause in the supply agreement, and records of notifications actually received and acted on
Routine testingTesting tied to specific rows in the register, at a stated frequency, with a defined action on an out of specification resultThe sampling plan, laboratory reports, trend review, and the record of what happened the last time a result failed
Mass balanceReconcile quantity received against quantity used, sold, held and wasted over a defined period, per materialThe reconciliation with input and output figures, the tolerance applied, the investigation of any variance outside it
TraceabilityForward and backward trace completed within the time limit your scheme sets, including all claims and chain of custody recordsThe dated exercise with quantities reconciled, not just codes matched, and the corrective action where it failed
Authenticity testingA method that actually detects the fraud you scored: DNA species identification, stable isotope ratio analysis, chromatography, spectroscopy, nuclear magnetic resonanceLaboratory scope and accreditation, method reference, sample plan, results held against the specification

Supplier approval is where a food fraud finding usually turns into a bigger problem, because clause 3.5.1 is a fundamental requirement of BRCGS Issue 9 and a major non-conformity against its statement of intent is a fail, and certification is off the table. What happens to the audit itself is then agreed between the auditor, the certification body and site management: it can end there, or it can carry on as a non-certification gap audit. Either way a further full audit is needed before the site can be certified. If your VACCP register puts a material in the high band and the supplier file for that material contains a two year old questionnaire, the two documents contradict each other in writing. The Supplier and Purchased Material Approval Risk Assessment Template (RA11) at R690 is the pack that closes that gap, because it scores approval method against material risk instead of applying one questionnaire to everyone.

Traceability is the other control that has to work under pressure rather than on paper. A withdrawal caused by an authenticity failure moves faster than a microbiological one, because the customer usually finds out from a laboratory or a journalist rather than from you. The Traceability, Withdrawal and Recall Risk Assessment Template (RA20) at R690 scores where your trace breaks: at rework, at bulk decanting, at blending, and at the point where a batch code stops travelling with the product.

Close the supplier approval gap before the auditor opens both files

A high risk material with a low effort approval is a contradiction the auditor can see without leaving the meeting room. Score your approval method against material risk, then evidence the trace that has to run if a claim turns out to be false. Both packs carry the register, procedure, completion guide and read me, in editable Word and Excel, mapped to BRCGS, IFS and SQF clauses.

Supplier and Purchased Material Approval Risk Assessment, R690 Browse the risk assessment library Talk to ASC about a VACCP review before the audit

The difference between mitigation and detection

FSSC 22000 carries food fraud mitigation, not food fraud detection, in its additional requirements. Mitigation reduces the chance that adulterated material ever reaches you. Detection finds it after it has arrived. Specification, supplier approval, contract terms, shortening the chain and buying direct are mitigation. Testing, mass balance, traceability exercises and certificate verification are detection. A plan built only from detection controls is a plan that accepts the fraud and tries to catch it, and auditors are increasingly willing to say so.

Both are needed, but they answer different questions and they should be labelled differently in the register. Ask of each control: does this stop it happening, or does it tell me it happened? A high band material with three detection controls and no mitigation control is a material you are still buying blind. Paprika bought through a broker is a supply chain problem wearing a laboratory costume.

🛡MitigationNamed origin on the specification. Direct contract with the processor. Fewer intermediaries. Change notification clauses. Approval based on a site visit rather than a questionnaire. Dual sourcing so a shortage does not force a rushed purchase.
🔍DetectionAuthenticity testing on a sampling plan. Mass balance reconciliation. Traceability exercises with quantities. Certificate verification with the issuing body. Trend review of laboratory results. Goods receiving checks against the specification.

There is a practical reason to keep the labels separate. When a score has to come down, only mitigation moves the opportunity column much. Detection controls raise the chance of catching a fraud in progress, which is worth having, but they do not make the material harder to adulterate. Sites that write “increase testing” against every high band row usually find the residual scores barely move, and that is the method working correctly rather than failing.

A vulnerability assessment needs a review record, not a one off

ASCloud is the ASC paperless compliance platform: digital checklists, HACCP records and traceability supporting FSSC 22000, BRCGS, HACCP and R638 sites. The printing stops, the evidence sits where an auditor can see it, and where ASC manages your food safety system on the weekly option, your consultant approves the checklists and keeps an eye on the site between visits rather than waiting for the next one. Ask us for a walkthrough on your own checklists.

See ASCloud, the ASC paperless system Ask ASC for an ASCloud walkthrough

How often to reassess, and what triggers a review

Review the whole assessment at least annually, and review affected rows immediately whenever the picture changes. BRCGS deals with the requirement in clause 5.4, and your own procedure should state the interval and the triggers in writing so that the review is a scheduled task with an owner rather than something that happens the week before an audit.

  • A new raw material, a new packaging material carrying a claim, or a new outsourced process
  • A new supplier, or a change of source, sub supplier or manufacturing site within an existing approved supplier
  • A change of broker, agent, importer or transport arrangement, even where the material and price are unchanged
  • A sharp price movement in either direction, particularly a drop nobody can explain
  • A supply shortage, crop failure, drought, export restriction or currency move affecting one of your commodities
  • A new claim on the label, or a change to an existing one
  • A relevant notification from your horizon scanning sources, or a public incident in one of your commodities anywhere in the world
  • An internal signal: a failed traceability exercise, a mass balance variance outside tolerance, a certificate that could not be verified, or a customer complaint about identity, taste or colour

Record every review, including the ones where nothing changed. A register with a single date on it tells an auditor the document was written once. A register with four dated reviews, two of which changed a score with a stated reason, tells them the system is alive. That difference is worth more at audit than any amount of extra detail in the rows themselves.

Make your internal auditors the people who find this first

A food fraud register goes stale between audits because nobody internal is checking it. Internal and Supplier Auditing Practices at R3,500 trains your team to audit the supplier files, the traceability exercise and the vulnerability register the way a certification body will, self paced online with lifetime access and a QR verifiable certificate. Our guide to building internal and supplier auditors sets out how to structure the programme.

Internal and Supplier Auditing Practices, R3,500 Ask ASC to build your vulnerability assessment

The findings that come up

BRCGS Issue 9 writes food fraud findings against clause 5.4, and they cluster in a small number of places, almost all of them structural rather than technical. The assessment exists but its scope is short, its scores have no reasons, its controls have no records, or its output never reaches the supplier approval programme. Fix those four and most of the rest disappear.

  • Scope stops at raw materials. Packaging carrying a claim, processing aids, outsourced blending or storage, and services are left out. Packaging is the most common omission and the easiest for an auditor to spot from your artwork.
  • One score for the whole site. A single line saying raw materials are medium risk. Vulnerability is a property of a material and its chain, so the register has to run by material.
  • Motivation scored on the supplier’s honesty. Rows justified with “long standing supplier, trusted”. Motivation is set by the market, not by the relationship, and the relationship belongs in the control column.
  • Controls credited with no evidence. A score reduced because testing is done, and no sampling plan, no laboratory report and no action record when a result failed.
  • No competence evidence for the team. BRCGS expects the individual or team to understand food fraud and the principles of vulnerability assessment. Job titles are not records. Training certificates are.
  • Horizon scanning is a folder, not a log. Printouts filed with no dates, no decisions and no link to a register row. The auditor wants to see a scan that changed something.
  • The mitigation plan is all testing. Every high band row answered with “increase analysis”. No specification change, no supplier action, no attempt to shorten the chain.
  • Claims with no chain of custody. Organic, halaal, free range or single origin on the pack, with certificates on file that were never verified with the issuing body and no reconciliation of certified input against certified output.
  • Mass balance never run, or run only on the easy material. A reconciliation on packaging film and none on the blended commodity that scored 20.
  • VACCP and TACCP merged. One document trying to be both, thorough on materials and thin on access points, or the reverse. The auditor reads the thin half.
  • No review after a public incident. A widely reported fraud in one of your own commodities, and a register whose last review date is eleven months old.

Where a finding has already been written, the correction is rarely another version of the same document. Work back to why the register was thin: usually no method, no owner and no time. Our guide to BRCGS Issue 9 implementation sets out how the sections connect, and the complete guide to food hygiene audits covers how findings are graded and closed out.

Two ways to have a defensible register by month end

Buy the pack and write it yourself with a method already built, or bring us in to map the materials, chair the scoring and write it with your team. Both end in the same place: a register with reasons, owners, dates and a review schedule. Consultation from R480 an hour, and a full project is scoped and quoted as one figure rather than billed by the hour.

Food Fraud Vulnerability (VACCP) Risk Assessment Template, R690 Talk to ASC about the raw materials most at risk of fraud

Read next from the ASC risk assessment library

Frequently asked questions

What is the difference between VACCP, TACCP and HACCP?
HACCP controls unintentional food safety hazards in your own process. TACCP, food defence, addresses deliberate acts intended to cause harm, such as sabotage or malicious contamination. VACCP, food fraud, addresses deliberate acts motivated by money, such as dilution, substitution or false claims. The motive is what separates them. Auditors write findings when a site submits one document and calls it all three.
Does BRCGS require a food fraud vulnerability assessment?
Yes. BRCGS Global Standard Food Safety Issue 9, published 1 August 2022, deals with product authenticity, claims and chain of custody in clause 5.4, and that section is where the documented vulnerability assessment for raw materials sits. Supplier approval, in clause 3.5.1, is one of the twelve fundamental requirements of Issue 9, and a major non-conformity against its statement of intent is a fail, and certification is off the table. What happens to the audit itself is then agreed between the auditor, the certification body and site management: it can end there, or it can carry on as a non-certification gap audit. Either way a further full audit is needed before the site can be certified.
How do you score opportunity and motivation in a VACCP assessment?
Score opportunity on how easily the material could be adulterated or substituted without your current checks noticing, and motivation on the money available from doing so. Multiply the two for an inherent vulnerability out of twenty five. Controls reduce opportunity, never motivation, so re-score opportunity with your controls in place to get the residual figure that drives action.
Which raw materials are most vulnerable to food fraud?
Materials that combine a high value gap with a hard test. Ground and powdered spices, oils sold on a variety or origin claim, honey and syrups, fish and meat sold by species, fruit juice concentrates, dairy powders, and anything carrying a premium claim such as organic, free range, halaal or single origin. Physical form matters: whole is harder to falsify than ground.
Is authenticity testing required for every raw material?
No, and a plan that tests everything usually means nobody scored anything. Testing is a detection control and it is expensive, so it belongs on the materials your assessment put in the high band, on a stated frequency, with a defined action when a result fails. For low band materials, specification, approved supplier status and traceability are normally the proportionate response.
What is mass balance and how often should it be done?
Mass balance reconciles the quantity of a material received against the quantity used, sold, held in stock and lost as waste, over a defined period. It is the cheapest way to expose dilution or an undeclared substitution, because falsified material has to appear somewhere in the numbers. Run it on your high band materials and on every material carrying a claim, and follow the interval your certification scheme states.
Where can I get free food fraud intelligence for horizon scanning?
The RASFF Window at webgate.ec.europa.eu carries European notifications from 2020 onward. The United States FDA import alert database at accessdata.fda.gov shows which products and countries are subject to detention without physical examination. The Food Authenticity Network, led by LGC, publishes methods and mitigation guidance. In South Africa the National Consumer Commission publishes product safety recalls.
How often must a food fraud vulnerability assessment be reviewed?
At least annually, and immediately on any change that alters the picture: a new raw material, a new supplier or a change of source within an approved supplier, a change of broker or agent, a formulation change, a new claim on the label, or a reported incident affecting one of your materials. Record the review date and the reason, even where nothing changed.
Can VACCP and TACCP be combined into one document?
They can share a team and a meeting, but they should not share a register. Food fraud is scored by raw material and supply chain against economic motive. Food defence is scored by point of access and person against intent to harm. Combining them almost always produces a document that covers materials properly and access points badly, and the auditor finds the thin half.

Key takeaways

  • Food fraud is economically motivated, food defence addresses intent to harm, and food safety addresses unintentional hazards. Keep three separate registers even where one team writes them, because auditors write findings against sites that merge them.
  • BRCGS Issue 9 covers product authenticity, claims and chain of custody in clause 5.4, and supplier approval in clause 3.5.1 is one of the twelve fundamental requirements. FSSC 22000 carries food fraud mitigation in its additional requirements.
  • Score opportunity and motivation from 1 to 5 per raw material and multiply. Controls reduce opportunity only. A register where a control lowered the motivation score is a register that will not survive questioning.
  • Horizon scanning is a dated log with decisions in it, drawn from checkable public sources such as the RASFF Window, FDA import alerts, the Food Authenticity Network and the National Consumer Commission recall listings, plus your own price and rejection data.
  • Mitigation stops fraud reaching you. Detection tells you it arrived. A mitigation plan made entirely of testing is a detection plan, and the residual scores will show it. The Food Fraud Vulnerability (VACCP) Risk Assessment Template (RA18) is R690 and carries the register, the scoring procedure, the completion guide and the read me.
MN
Mthokozisi Nkosi
Food Safety Specialist & Lead Auditor, ASC Food Safety

Managing Director and Principal Consultant at ASC Food Safety Consultants. Completing a PhD in Public Health, with an MPH, MSc Data Science, MBA and BSc (Agric) Hons in Food Science and Technology. PCQI, Registered Lead Auditor with Exemplar Global and IRCA, SAATCA registered R638:2018 Lead Implementer and FoodBev SETA assessor. He works with manufacturers across South Africa on supply chain integrity, supplier approval and certification readiness, supported by a team of food scientists, biochemists and FSSC 22000 Lead Auditors.

Start with the register, or start with the whole system

The RA18 pack gives you the food fraud register, the scoring procedure, the completion guide and the read me in editable Word and Excel, mapped to BRCGS, IFS and SQF clauses. If food fraud is one of many documents outstanding, the toolkits carry the full management system with one hour of premium consultation from one of our consultants. Browse the full set at the risk assessment library, the ASC shop, or see the full course list for your team’s training.

Food Fraud Vulnerability (VACCP) Risk Assessment Template, R690 Send us your supplier list and we will rank the exposure

Published by ASC Food Safety, South African food safety and quality consultants. This article is general guidance and not a substitute for certification-specific advice.

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