What was the starting point?

A certified company, solid on hygiene and HACCP, whose fraud assessment had never been put to the test by a customer. This is a composite case: it brings together situations our teams meet in Moroccan food companies, without describing any one client.

The exporter, based in the Casablanca region, receives whole seeds (cumin, coriander, nigella), dried chillies, dried herbs and saffron bought from cooperatives through intermediaries. It sorts, cleans, grinds and blends (ras el hanout, the North African spice blend, and grilling blends), then packs in bulk bags for industry and in jars for retail. Steam treatment of the spices is outsourced to a subcontractor. To complete its ranges, it also buys turmeric and pepper already ground from a Casablanca trader. The site is certified to IFS Food Version 8.

A British importer, certified to BRCGS Food Safety Issue 9, wants to list it for a range of ground spices and “Moroccan origin” saffron. Its technical team sends a supplier questionnaire and, before any order, asks for the food fraud vulnerability assessment, the mitigation plan, the food defence plan and evidence of the saffron’s origin.

The request is not arbitrary. BRCGS (3.5.1.2) obliges the buyer to approve its suppliers through a certification, an audit or a questionnaire whose scope covers food defence and product authenticity. And the origin claim it will print on its own label obliges it to verify the status of each batch and to carry out mass balance tests (5.4.5).

The gap analysis established the starting point:

  • a one-page fraud assessment, one line per family, everything rated “low”, with no criteria and no sources;
  • neither packaging nor the outsourced treatment in the scope, although IFS Food Version 8 (4.20.2) covers them;
  • a trader listed on price alone, with no audit and no known certification;
  • no authenticity testing in the testing plan;
  • saffron batches mixed at intake, whatever the cooperative of origin;
  • a generic food defence plan, with no sensitive area defined.

Which decisions came before redoing the assessment?

Five decisions, approved by top management. They set the scope and the workload.

Decision

Options

Choice in this case

Rule applied

Team

Quality alone or a mixed team

Purchasing, quality, production, logistics, top management

Defined responsibilities and appropriate specific knowledge (IFS 4.20.1)

Scope

Materials only or the full IFS scope

Raw materials, ingredients, packaging and the outsourced treatment

IFS 4.20.2

Grouping

By family or by form

Each spice split into “whole” and “ground”

The nature of the raw material is a criterion (BRCGS 5.4.3)

Method

Generic template or the site’s own grid

Written grid, 7 criteria scored from 1 to 3, thresholds and a precautionary rule

Method is free but documented (IFS glossary)

Horizon scanning

Ad hoc or scheduled

Fixed list of sources, quarterly review of alerts

IFS 1.2.5, BRCGS 5.4.2

The grouping changed everything. The GFSI’s 2018 technical document gives unauthorised additives in spices (Sudan dyes) among its examples of unapproved enhancements. A ground, blended or strongly coloured spice offers more scope for this kind of fraud than a whole seed that can be examined at goods-in.

What did the new assessment show?

Three levels, and more surprises on the purchasing side than in production. The table sums up the conclusions, without publishing scores or test results.

Group

Level assigned

Main reasons

Turmeric and pepper bought ground from the trader

High

Ground form, long chain, unaudited supplier, economic incentive

Chilli and paprika ground on site from dried chillies

High

Colour sought by customers; unauthorised dyes cited by the GFSI among spice frauds

Saffron

High

High price, intermediaries, origin claim carried by the customer

Blends containing a component bought ground

High

The most vulnerable component sets the level of the blend

Whole seeds from known suppliers

Medium

Real economic incentive, but whole form can be checked at goods-in

Dried herbs

Medium

Risk of other plant material, visual check possible

Outsourced steam treatment

Medium

The treatment certificate must match each batch

Salt, glass jars, caps, cartons

Low

Certified suppliers, little economic incentive for fraud

The “low” rating for packaging is no formality: it is written, justified and reviewed like the others. The GFSI says so in the same document: concluding that vulnerability is low is acceptable as long as the assessment is carefully conducted and clearly documented.

Which mitigation plan was adopted?

A plan that changes purchasing first, then targets testing. The measures follow the logic of the GFSI’s 2014 position: monitoring, testing, origin verification, specifications, supplier audits.

Group

Measures

Owner

Verification

Spices bought ground

Gradual switch to whole-form purchases ground on site; in the meantime, an audited trader and a certificate of analysis for each batch

Purchasing

Targeted testing by a laboratory accredited for the method, at a risk-based frequency

Chilli and paprika

Specification with authenticity criteria, audited suppliers of dried chillies

Quality

Testing for unauthorised dyes according to the testing plan

Saffron

Purchase from identified cooperatives, batches kept separate by cooperative, origin documents filed

Purchasing and logistics

Six-monthly mass balance, targeted testing

Blends

High-risk components subject to the same measures as the material on its own

Production

Recipe review at every change of component

Outsourced treatment

Written agreement, treatment recorded batch by batch

Quality

Certificates matched to batches, periodic microbiological verification

For saffron, keeping batches separate was the heaviest measure, and the most useful. Without it, no mass balance was possible, and the importer could not have substantiated the origin claimed on its label. Moroccan law shows what is at stake: Law no. 13-83 on the repression of fraud in goods (loi n° 13-83 relative à la répression des fraudes sur les marchandises) punishes deception about the species or origin of goods when that false designation must be considered the main reason the customer entered into the contract.

On the food defence side, the threat assessment was redone around three areas. Intake of bulk sacks is now checked on arrival (sacks intact, supplier label present). The grinding room is now locked outside production hours. At dispatch, every bulk bag receives a numbered seal recorded on the delivery note.

How was the file presented to the buyer?

As one coherent package, not a pile of documents. The file contained the written method, the full assessment, the mitigation plan, the list of horizon-scanning sources, a summary of the food defence plan, the latest traceability test and the first saffron mass balance.

The importer’s technical team asked two questions: how blends inherit the level of their components, and by what date ground purchases would be replaced. Both answers already existed in writing. The importer then scheduled its own supplier audit; how to prepare for one is described in our article on preparing for a supplier audit.

What lessons for other exporters?

Three lessons apply equally to an olive oil mill, a fish cannery or a dried fruit packer. First, read the buyer’s request through the buyer’s own standard: it is not asking for a document, it is looking for the evidence it needs for its suppliers and its labels. Second, assess the form in which the material arrives, not just its name. Third, act on purchasing before piling up tests: a shorter chain protects better, and costs less, than a testing plan that chases fraud.

The full method is in our guide to the food fraud vulnerability assessment, the overall framework in our food defence and food fraud guide, and the resources to plan for in our article on the cost of a food defence programme.