Introduction

Product authenticity, claims, and chain of custody represent interconnected concepts that form the foundation of consumer trust and regulatory compliance in food manufacturing. Authenticity refers to the assurance that a product, raw material, or ingredient is exactly what it purports to be—matching its declared species, origin, composition, and quality characteristics without undeclared substitution, adulteration, or misrepresentation. Product claims are statements made on packaging, in marketing materials, or in related documentation that communicate specific attributes, benefits, or characteristics to consumers and business customers—such as “organic,” “non-GMO,” “preservative-free,” “origin guaranteed,” or “identity preserved.” Chain of custody describes the systematic documentation and tracking of a product’s movement, ownership, and handling from its source through all stages of processing, storage, and distribution until it reaches the end customer, ensuring that each transaction, movement, and change in state is recorded and verifiable. These three elements work synergistically to mitigate fraud, substantiate claims, demonstrate regulatory compliance, and protect brand integrity and consumer safety.

Significance and Intent

The importance of product authenticity, claims, and chain of custody cannot be overstated in the modern food manufacturing environment. Food fraud—deliberate adulteration, substitution, dilution, mislabelling, or counterfeiting for economic gain—now imposes an estimated £40 billion in annual global damages. High-value, easily-adulterated ingredients such as virgin olive oil, manuka honey, specialty spices, premium proteins, and botanical extracts are frequent targets for fraudulent substitution, economically motivated adulteration, and misrepresentation. The complexity of globalised supply chains, the involvement of multiple intermediaries including agents, brokers, and wholesalers, and gaps in supply chain transparency create vulnerability points where fraudulent substitution or adulteration can occur without immediate detection.

Food manufacturers face dual pressures: they must protect their consumers from unknowingly purchasing fraudulent or substandard products, and they must protect their brands and business operations from the reputational damage, legal liability, and financial penalties that follow when fraud is discovered in their supply chains. Beyond commercial considerations, there are genuine food safety implications. Some fraudulent substitutions present direct health risks—for example, undeclared allergens introduced through ingredient substitution, or toxic adulterants deliberately added to enhance product appearance or functional characteristics. Regulatory authorities in major markets including the UK, European Union, United States, and Australia now mandate that food manufacturers implement systems to assess and manage product authenticity risks, verify that suppliers maintain effective traceability, and substantiate claims made on product labels and packaging.

The intended outcome of robust authenticity, claims, and chain of custody systems is multifaceted. Food manufacturers should establish an integrated approach whereby they identify which raw materials, ingredients, and finished products present the greatest authenticity risk—based on factors including market value, processing complexity, supply chain length, and historical fraud patterns. They should implement documented procedures to verify that suppliers are operating genuine traceability systems and are capable of controlling fraud risks at their own facilities. They should maintain evidence that product claims—whether relating to provenance, production methods, ingredient identity, or functional properties—are factually accurate and substantiated by reliable data, including purchasing records, supplier certifications, testing results, and independent verification where claims are particularly high-value or health-related. Collectively, these systems should create multiple defensive barriers against fraud, reduce the likelihood that fraudulent products enter the supply chain undetected, and enable rapid traceability and recall capabilities should suspicious products be identified at any stage.

Overview of Compliance

Food manufacturers seeking to demonstrate compliance with authenticity, claims, and chain of custody requirements must establish a structured management system comprising several interconnected documented components. The system should begin with vulnerability assessments—documented risk evaluations performed on all raw materials, ingredients, packaging materials, and finished product categories to systematically identify which materials present elevated fraud risk based on factors including economic value, availability of lower-cost substitutes, sophistication of detection methods, and supply chain complexity. These assessments should inform supplier approval procedures that confirm suppliers are operating effective controls, including traceability systems, product testing, and procedures to prevent substitution or adulteration.

The management system should include purchasing specifications and supplier questionnaires or audit reports that establish clear requirements for authenticity and traceability, and raw material acceptance procedures that outline the evidence, testing, or certification required before materials are released for production use. For finished products bearing claims—whether relating to origin, production methods, ingredient composition, or functional properties—manufacturers should develop claims substantiation files containing the evidence that supports each claim, whether derived from supplier documentation, independent testing, certification records, or third-party verification. The system should encompass traceability procedures and records that track raw material lots from receipt through production to finished product dispatch, including documentation of all process steps, batches, and distribution movements. Finally, the system should include periodic testing protocols for raw materials, intermediate products, and finished goods where authenticity risks have been identified, using appropriate analytical methods to verify product composition, species identity, or origin claims.

Documented systems can be aligned with operational practices by ensuring that purchasing departments apply the established supplier approval criteria and specifications when evaluating and selecting suppliers; that goods receipt personnel apply defined acceptance criteria and perform required testing or inspection; that production staff maintain detailed batch records that enable mass balance calculations and lot traceability; and that management review processes regularly analyse supplier performance, product testing results, and complaint data to identify emerging authenticity risks or trends requiring investigation.

Documented Systems

Establishing effective documented systems for product authenticity, claims, and chain of custody requires food manufacturers to create and maintain several categories of documentation, each serving a specific compliance and operational function.

Vulnerability Assessment Documentation forms the essential foundation. This assessment should be a documented, risk-based evaluation performed on all food raw materials or groups of raw materials, as well as on finished products and any product or service that could affect authenticity claims. The vulnerability assessment should evaluate the potential risk of adulteration or substitution by considering factors including the historical evidence of substitution or adulteration of that material, economic factors that make adulteration or substitution attractive (such as large price differentials between a premium material and potential substitutes), the ease of access to the raw material or potential substitute through the supply chain, the sophistication of routine testing to identify adulterants (including whether simple, low-cost methods exist to detect adulteration or whether detection requires sophisticated laboratory analysis), and the nature of the material itself—for instance, whether the material comprises a single, easily-defined ingredient (such as pure vanilla extract) or a more complex ingredient prone to natural variation (such as spice blends or botanical extracts). The output of this assessment should be a documented vulnerability assessment plan that clearly identifies materials at low, medium, or high risk of fraud, provides the risk rating justification, and links these findings to the company’s subsequent supplier approval procedures, acceptance criteria, and testing frequency. This plan should be reviewed annually and whenever new fraud risks emerge—such as when trade associations or scientific literature report previously undocumented adulteration methods or when a competitor’s product recall reveals a novel fraud technique affecting the same supply chain.

Supplier Approval Procedures and Approval Documentation establish the systematic process for ensuring that all suppliers of raw materials, packaging, and outsourced processing services are capable of managing authenticity risks and operating effective traceability. The procedure should be documented in a written policy or work instruction, and should specify that supplier approval is risk-based, with the most rigorous approval processes applied to high-risk materials. The documented procedure should detail that supplier approval may be based on one or a combination of approaches: obtaining evidence of valid certification to a GFSI-benchmarked food safety standard (such as BRCGS, IFS, or FSSC 22000) where the certification scope includes the raw materials being purchased; conducting a documented audit by a competent third-party auditor, with the audit report retained for review and the scope confirming the auditor assessed product authenticity, product security and food defence, traceability, HACCP procedures, and good manufacturing practices; or, for suppliers assessed as lower-risk, issuing and reviewing a supplier questionnaire that covers product safety, authenticity, traceability, and good manufacturing practice requirements, with the questionnaire verified by a demonstrably competent person.

Documentation should establish that where raw materials are purchased from agents, brokers, or wholesalers rather than from the actual manufacturer or packer, the food manufacturer should obtain information allowing them to identify and approve the last manufacturer, packer, or consolidation point of the material. Supplier approval documentation should include a master list or database of approved suppliers that is current, maintained, and readily available to relevant personnel such as purchasing and goods receipt staff. This documentation should include each supplier’s approval date, approval basis (certification, audit, or questionnaire), validity period, any conditional approval (such as where full supplier approval information was not available and additional product testing is required), and any outstanding actions or re-approval dates.

Supplier Questionnaires, Audit Reports, and Certification Records constitute essential evidence of supplier capability. Where suppliers are approved based on a completed questionnaire, the questionnaire should be retained on file and should confirm the supplier’s responses regarding authenticity risk controls, traceability capabilities, testing procedures, and procedures to prevent cross-contamination or substitution. The questionnaire should be reissued at least every three years. Where supplier audits are used for approval, the full audit report should be obtained and retained, covering the scope of product safety, authenticity, traceability, HACCP, product security and food defence, and good manufacturing practice. Where suppliers hold valid certification to a GFSI-benchmarked standard, the certificate should be retained, verified for current validity, and assessed to confirm that the certification scope includes the specific products being purchased. Documentation should also record any significant changes notified by suppliers between formal reapprovals—for instance, if a supplier changes to a different source for a key raw material, or if a supplier’s certification status changes.

Product Specifications and Purchasing Specifications should define precisely what the food manufacturer expects to receive and what the finished product should contain. Raw material and packaging specifications should be accurate, comprehensive, and should include specifications for key attributes affecting authenticity—such as the expected species identity (for products prone to species substitution, such as seafood or meat-derived ingredients), country of origin or region of origin (where origin claims are made), key compositional elements (such as fat content in oils, protein content in protein ingredients, or active ingredient content in botanicals), and any certifications required (such as organic, non-GMO, kosher, or halal certification). Finished product specifications should reference the specification of key raw materials used, should identify any claims to be made on packaging (such as “made with organic ingredients” or “preserved with natural antioxidants”), and should define the evidence or testing required to substantiate each claim. Specifications should be reviewed and updated at least every three years or whenever significant changes occur—such as when a new supplier is appointed, when an ingredient is changed, when a regulatory requirement changes, or when a new market requirement emerges.

Claims Substantiation Files should be created for each significant claim made on finished product packaging, labels, marketing materials, or in technical documentation provided to customers. For origin or provenance claims (such as “Product of Italy,” “Georgian hazelnuts,” or “Norwegian farmed salmon”), the substantiation file should contain evidence from suppliers confirming the stated origin, including supplier certificates of origin, shipping documentation, invoices, bills of lading, or certifications from bodies such as Protected Designation of Origin (PDO) or Protected Geographical Indication (PGI) authorities. For production method claims (such as “cold-pressed,” “organic,” “kosher,” or “halal”), the file should contain copies of relevant certifications, supplier attestations confirming the production method was applied, and where appropriate, third-party audit or inspection reports. For composition or ingredient claims (such as “no artificial preservatives,” “gluten-free,” “dairy-free,” or “made with 100% plant-based ingredients”), the file should contain ingredient supplier documentation confirming the status of each ingredient; product testing results verifying the absence of undeclared allergens or unwanted substances; and supporting evidence such as recipes, formulations, or ingredient declarations. For functional or health-related claims (such as “rich in vitamin C,” “supports immune health,” or “good source of fibre”), the file should contain either scientific literature supporting the claim, validated laboratory testing confirming the product meets the claimed nutrient level, or evidence that the claim complies with recognised regulatory guidance for that jurisdiction. All claims substantiation should be reviewed before claims are first made on product packaging, and should be retained throughout the period during which the claim is made—and for a reasonable period thereafter.

Traceability Procedures and Records should document precisely how lot traceability is achieved across all production and distribution activities. The traceability procedure should describe the system for identifying raw materials, intermediate products, and finished goods; the method for maintaining and linking identification records; the documentation required (such as batch numbers, production dates, lot codes, or unique identifiers); and how the system enables traceability to be established both forward (from raw material receipt to customer) and backward (from finished product back to the supplier). The procedure should define the frequency and method for testing the traceability system to confirm that it functions effectively—such as through conducting mock traceability tests at least annually, systematically selecting a product or raw material and verifying that all relevant documentation can be retrieved and linked to trace the product through the supply chain. The procedure should establish that traceability testing should include a mass balance check—a reconciliation of the weight or volume of raw materials received, plus any additions during processing, minus all outputs (finished products, waste, rework, spoilage, environmental releases, packaging components) to confirm that all material inputs and outputs are accounted for. Documentation should record the results of all traceability tests, including any discrepancies identified, corrective actions taken, and timescales for completing traceability within acceptable limits (generally expected to be achievable within 4 hours, or within 1 day where information from external parties such as logistics providers is required).

Product Testing Records and Analytical Reports, particularly for high-risk or high-value ingredients, should document the results of testing designed to verify authenticity. Where vulnerability assessments have identified materials at risk of substitution, adulteration, or mislabelling, the testing programme should define the materials requiring testing, the test methods to be used (such as DNA-based species identification for meat or seafood products, stable isotope ratio analysis or trace element analysis for geographical origin verification, fatty acid profiling for oil authenticity, or targeted chemical analysis for herbs and spices), the frequency of testing, and the acceptable limits or specifications. Test records should document the date of testing, the material tested, the result obtained, any corrective actions if results were out of specification, and the signature or identification of the person responsible for reviewing and authorizing the result. Where testing is subcontracted to external laboratories, documentation should confirm that the laboratory holds recognised accreditation (such as ISO/IEC 17025 accreditation) or operates in accordance with recognised standards for the tests performed.

Practical Application

In practical daily operations, food manufacturers must ensure that personnel at all levels understand and consistently implement the documented authenticity, claims, and chain of custody systems.

Purchasing and Supplier Management personnel should apply the documented supplier approval criteria when making sourcing decisions. When a new supplier is being evaluated, purchasing should verify that the supplier meets the defined approval criteria—confirming that either a valid certification is held (and the scope of certification covers the required products), or that a supplier audit report is available (and covers the required assessment areas), or that a completed questionnaire is on file (with verification evidence that the questionnaire was completed accurately and by a competent person). Purchasing staff should maintain the approved supplier list and should not authorize orders from unapproved suppliers except through a defined exception process with documented justification—such as where a customer has prescribed a specific supplier. Where suppliers notify the company of changes—such as moving to a new production facility, changing the source of a key ingredient, or losing certification status—purchasing should update supplier approval status and, if required by the vulnerability assessment or supplier approval procedure, initiate re-evaluation or re-approval of the supplier. Purchasing staff should communicate defined specifications to suppliers at the point of order, and should document any agreed upon specifications in purchase orders or contracts, clearly identifying any authenticity or origin requirements (such as “must be certified non-GMO” or “must be organic certification required”).

Goods Receipt and Quality Assurance personnel should apply documented acceptance procedures when receiving raw materials and packaging. Before releasing any incoming material for use in production, goods receipt staff should confirm that required documentation is received—such as certificates of analysis, supplier attestations, certifications for materials requiring certification, or batch/lot traceability information. Where the vulnerability assessment has identified a material as being at risk of adulteration or fraud, goods receipt should perform any required testing (such as visual inspection for contamination or appearance, sampling for laboratory analysis, or weight checks) before releasing the material. Where the supplier approval procedure requires products to be tested before release (for instance, because supplier approval was based on questionnaire rather than certification or audit), goods receipt should ensure that testing is scheduled and completed within appropriate timescales—and should not release material until testing results confirm compliance with specifications. Goods receipt personnel should verify that the materials received match the purchasing specification—confirming that any required certifications (organic, non-GMO, or origin-specific) are present and valid, that the packaging clearly matches what was ordered, and that quantities received match documentation. Any discrepancies (such as receiving uncertified material when certified material was specified, or receiving a different supplier than specified) should trigger investigation before materials are released for use. Goods receipt should maintain records of all received materials, including supplier identification, lot or batch number, date of receipt, quantity, certifications or evidence of authenticity received, any testing performed, and the signature of the person authorizing release for production use.

Production and Batch Recording staff should maintain detailed batch records that enable traceability and support claims verification. As production occurs, production staff should record the identity and lot number of all raw materials used in each batch of finished product, the quantities used (in weight or volume), the date of production, all significant process parameters (such as cooking temperatures and times, cooling rates, mixing speeds, or ingredient additions), any rework materials incorporated, the identity of personnel involved, and the equipment used. Where products are labelled with claims such as origin or production method (organic, cold-pressed, hand-made), production staff should confirm that all materials used in that production batch comply with the claim—for instance, if a batch is labelled as containing “organic ingredients,” production records should confirm that organic-certified materials were used exclusively, and any non-organic materials were not incorporated. Production staff should also document the finished product lot number or batch code, the quantity of finished product produced, packaging used, and any spoilage or rework; this information enables the mass balance calculation. Documentation should be completed contemporaneously (at the time of production) rather than retrospectively, and should be signed by the person responsible for the production activity.

Administrative and Management Review Functions should periodically analyse traceability system effectiveness and authenticity risk management. At least annually, and whenever significant changes occur (such as new suppliers being approved, new products launching, or new customer requirements emerging), management should conduct or oversee a traceability test—systematically selecting one or more products or raw materials and retrieving all documentation to verify that the item can be traced backward to suppliers and forward to customers, and that all weights or quantities can be reconciled through mass balance calculations. Any discrepancies (such as undocumented material, unexplained weight loss, or inability to locate some records) should trigger investigation and documented corrective action. Management should also regularly review supplier performance against defined performance criteria—such as on-time delivery, quality of materials received (including results of any testing performed), compliance with specifications, and provision of required documentation. Suppliers failing to meet performance criteria should be subject to defined consequences, which might include increased frequency of incoming testing, requests for re-audit, or removal from the approved supplier list if performance does not improve.

When developing or updating finished product claims, management should ensure that claims substantiation documentation is gathered before claims are communicated to consumers or customers. For routine claims such as ingredient identity or processing method, this may involve confirming that suppliers have provided evidence of the claim (such as organic certification for claimed organic ingredients). For health-related or functional claims, substantiation should be more rigorous, with management confirming that evidence from reliable sources (such as scientific literature or validated testing) supports the specific claim being made. Management should also ensure that where claims relate to origin or source traceability (such as “traceable to individual farms” or “identity preserved from farm to shelf”), the company’s documented traceability procedures are sufficiently detailed and regularly tested to genuinely enable the claimed level of traceability to be demonstrated.

Vulnerability Assessment Updates should be undertaken annually and whenever emerging risks are identified. Each year, relevant management personnel (such as quality and technical staff, purchasing, and regulatory compliance staff) should review the documented vulnerability assessments against current market conditions, supply chain knowledge, and emerging food fraud trends. If new information suggests that fraud risks for specific materials have changed—such as because a previously low-risk material has been subject to increased fraudulent activity in the industry, or because a particular supply route has become associated with counterfeit products—the vulnerability assessment should be updated to reflect the new risk level, and corresponding changes made to supplier approval procedures, acceptance criteria, or testing frequency. For instance, if trade associations or regulatory bodies issue alerts about a particular herb being adulterated with undeclared additives, the vulnerability assessment should be updated to reflect this information, and the company should consider whether increased testing or additional supplier verification is now warranted for that material.

Pitfalls to Avoid

Food manufacturers frequently encounter challenges or shortcomings when implementing authenticity, claims, and chain of custody systems. Understanding these common pitfalls enables companies to avoid or overcome them.

Inadequate Vulnerability Assessment represents a foundational error. Some manufacturers conduct vulnerability assessments that are overly generic, failing to consider the specific material, supply chain, and fraud risks relevant to their business. For instance, a manufacturer might conduct a generic assessment stating that “all oils are at medium risk of adulteration,” without considering that whilst virgin olive oil is genuinely at high risk of adulteration with cheaper refined oils, the manufacturer’s own simple food-grade mineral oil for equipment lubrication faces minimal fraud risk. Conducting specific, material-by-material vulnerability assessments, tailored to the company’s actual supply chains, market sources, and informed by historical fraud trends affecting that specific material, produces more meaningful risk management. Additionally, some manufacturers complete the vulnerability assessment once and then archive it, failing to recognise that fraud risks change over time as new fraud techniques emerge, supply chain routes shift, or market prices fluctuate. Establishing a discipline of formal annual review and update of vulnerability assessments, informed by trade alerts, industry publications, regulatory notices, and supplier feedback, ensures the assessment remains current and relevant.

Insufficient Supplier Verification occurs when manufacturers rely on supplier claims or minimal documentation without robustly verifying supplier capability. For example, a manufacturer might accept a supplier’s email stating “we are certified to BRCGS” without obtaining and reviewing the actual certificate—and might later discover that the supplier holds certification only for a limited product scope that does not include the materials being purchased, or that the certificate has expired. Similarly, some manufacturers approve suppliers based solely on completion of a questionnaire, without any independent verification that the supplier’s questionnaire responses are accurate. Overcoming this pitfall requires establishing a discipline of obtaining and retaining authentic documentation—verified certificates obtained directly from recognized certification bodies or downloaded from public registers, full audit reports obtained from the auditor or certification body, and supplier questionnaires that are completed by authorized personnel and independently verified by a competent auditor or senior manager. Additionally, for high-risk materials, some manufacturers should consider commissioning independent supplier audits or verification visits rather than relying on supplier-provided evidence, particularly where supplier financial status is uncertain or where the material represents a significant cost or safety risk.

Inadequate Product Claim Substantiation represents significant regulatory and reputational risk. Manufacturers sometimes make claims on product packaging (such as “made with organic ingredients,” “supports joint health,” “ethically sourced,” or “individually hand-packed”) without having gathered the evidence to support the claim, or with insufficient evidence that would not withstand scrutiny from regulators or consumers. For health-related or functional claims, regulators increasingly demand robust substantiation from scientific literature or validated testing. For origin or sourcing claims, regulators may require evidence such as supplier certifications, third-party audits, or independent testing confirming the claimed origin. Manufacturers can overcome this pitfall by adopting the discipline of gathering claims substantiation documentation before claims are communicated on product packaging or marketing materials, rather than attempting to gather evidence retrospectively when a regulator raises questions. Claims substantiation should be reviewed by competent personnel (such as product development, quality assurance, or regulatory compliance staff) to confirm that evidence is adequate and defensible before the product launches. Additionally, manufacturers should establish a process for monitoring regulatory guidance on permitted claims and substantiation requirements in their target markets—since claim rules differ significantly between regions (for instance, health claims permitted in one region may be prohibited in another), and the required substantiation standards continue to evolve.

Weak Traceability Documentation and Record-Keeping undermines the entire chain of custody system. Some manufacturers maintain traceability records that are incomplete, unclear, or inconsistent—for instance, recording production batches by product name and date without unique lot codes, failing to record which specific raw material lots were used (instead using generic notation such as “flour—received this week”), or maintaining records in multiple incompatible systems such as paper records in production and separate electronic files in the office. When a traceability test is conducted or when a product withdrawal becomes necessary, personnel cannot retrieve the required information within the required timeframe (generally 4 hours for routine situations). Overcoming this pitfall requires establishing clear, standardized traceability procedures that specify exactly what information must be recorded at each stage, in what format, using what identification system (lot codes, batch numbers, or unique identifiers). Traceability records should be maintained in a centralized system—whether paper or electronic—that enables rapid retrieval. Staff responsible for recording traceability information should receive training in the procedure and should be supervised to ensure they complete records accurately and contemporaneously. Traceability should be tested regularly (at least annually) to identify gaps in records or procedures; any shortcomings should be corrected before a genuine recall situation arises.

Mass Balance Miscalculation and Failure to Investigate Discrepancies prevents manufacturers from detecting unexplained material loss that could indicate theft, fraud, or data entry errors. Some manufacturers calculate mass balance only sporadically, or do so but fail to investigate discrepancies beyond an arbitrary tolerance level. For instance, a manufacturer might determine that a 3% loss of raw material weight during production is “acceptable” without investigating whether the loss represents realistic shrinkage from water loss during cooking, or instead represents unaccounted-for material that might indicate substitution, theft, or data error. Additionally, some manufacturers calculate mass balance at only the finished product level without performing detailed mass balance at intermediate process steps, making it impossible to identify where material loss or discrepancy occurs within the process. Overcoming this pitfall requires documenting the realistic, expected loss or variation at each production step (based on process knowledge, such as water loss during cooking, product absorbed into equipment, or realistic measurement variation), and investigating any discrepancy that exceeds the established expectation. Where investigation identifies that the discrepancy represents genuine process loss (such as water evaporation during cooking), this should be documented. Where discrepancy cannot be explained, corrective action such as reviewing measurement equipment calibration, re-training staff on correct recording procedures, or investigating whether material was diverted or lost should be implemented.

Inadequate Distinction Between Traceability and Chain of Custody sometimes results in manufacturers implementing systems that track product origin but fail to document handling and condition during movement through the supply chain. Traceability systems typically focus on answering “what raw materials were in this product” and “where did each ingredient come from,” whilst chain of custody systems additionally document “who handled this product, when, and under what conditions.” For products requiring special handling (such as temperature-controlled transport for sensitive ingredients, or segregation to prevent cross-contamination for allergen control), chain of custody documentation is essential. Some manufacturers document traceability (which supplier, which lot) but fail to document chain of custody (how the product was transported, at what temperature, by which carrier), creating vulnerability where fraud or contamination could occur during transport and not be detected. Overcoming this pitfall requires manufacturers to consider, as part of their vulnerability assessment, whether particular materials require special handling during transport or storage, and if so, to establish chain of custody procedures and records that document the handling, conditions, and carriers involved.

Supplier Approval Based Solely on Questionnaire Without Re-verification represents a common shortcut that can introduce risk. Where supplier approval procedures allow for initial approval based on questionnaire (typically only appropriate for lower-risk materials), some manufacturers fail to periodically re-verify or re-audit the supplier. If a supplier’s actual practices have deteriorated or changed since the questionnaire was completed, this may not be detected until a problem arises. Additionally, some manufacturers approve suppliers based on questionnaires without having a process for verifying that the questionnaire responses are accurate—such as through a follow-up auditor visit. Procedures should establish that questionnaire-based approval is revalidated at least every three years, and that suppliers should notify the company of significant changes (such as moving to a new facility, changing the source of key raw materials, or losing certification) in the interim. For high-risk materials, even questionnaire-based approvals should be periodically audited to confirm that actual practices match the questionnaire statements.

Failure to Stay Informed of Emerging Authenticity Risks represents a gap in senior management commitment. Authenticity fraud techniques evolve continuously; new adulterants are discovered, supply chain routes change, and market prices fluctuate, all of which can shift fraud risk. Manufacturers that rely on static vulnerability assessments conducted several years ago, without incorporating emerging industry knowledge, may fail to recognize that a material they have assessed as “low risk” is now subject to widespread adulteration in their supply chain. Senior management should establish a process for staying informed of emerging authenticity risks—such as by reviewing trade association alerts and publications, participating in industry forums or working groups focused on food authenticity, subscribing to regulatory agency updates or food fraud databases, and maintaining dialogue with customers and supply chain partners about emerging risks.

In Summary

Product authenticity, claims, and chain of custody represent essential compliance and risk management requirements for modern food manufacturers. These interconnected systems protect consumers, preserve brand reputation, demonstrate regulatory compliance, and create defences against food fraud—a growing global threat responsible for an estimated £40 billion in annual damages.

Food manufacturers should begin by conducting documented vulnerability assessments on all raw materials and finished products to identify which materials present elevated fraud risk. These assessments should inform risk-based supplier approval procedures that confirm suppliers are capable of managing authenticity risks and operating effective traceability systems. Supplier approval may be based on certification to GFSI-benchmarked standards, third-party audit evidence, or (for lower-risk materials) completion of verified questionnaires.

For finished products bearing authenticity or sourcing claims, manufacturers should gather substantiation documentation demonstrating that claims are factually accurate and supported by reliable evidence before claims are communicated to consumers. Comprehensive product specifications, purchasing procedures, and goods receipt protocols should establish what is expected to be received and what testing or verification is required before materials are released for production use. Detailed traceability records and mass balance documentation should enable rapid tracking of products through the supply chain and detection of unexplained material loss or discrepancy.

Best practice implementation requires consistent application of these systems in day-to-day operations—with purchasing staff confirming supplier approvals before ordering, goods receipt staff verifying specifications and performing required testing, production staff maintaining detailed batch records, and management periodically testing the traceability system and reviewing supplier performance. Annual review and updating of vulnerability assessments, informed by emerging industry knowledge and fraud trends, ensures that systems remain current and effective.

Food manufacturers that implement these systems demonstrate serious commitment to product safety, authenticity, and regulatory compliance. By establishing multiple defensive barriers against fraud—starting with supplier verification, continuing through comprehensive documentation and traceability, and including independent testing for high-risk materials—manufacturers create confidence among customers, consumers, and regulators that their products are genuine, their claims are substantiated, and their supply chains are transparent and controlled.