Creating effective Food Defense and Food Fraud programs is crucial for maintaining the safety and integrity of the food supply. These programs are designed to prevent intentional adulteration, whether for malicious purposes like terrorism (Food Defense) or economic gain (Food Fraud).
The SQF Code requires under element 2.7 (Edition 9) that food operations develop and implement Food Defense and Food Fraud programs that outline the methods and responsibilities to prevent the intentional adulteration of food. With SQF Edition 10 released in March 2026 and audits transitioning in February 2027, facilities should note that Edition 10 introduces updated requirements for both programs, including the addition of cybersecurity as a formal component of food defense planning. Practitioners are encouraged to review Edition 10 requirements as part of their next annual review cycle.
In this article, we provide a guide to the development of food defense and food fraud programs.
Food Defense Program
- Management Responsibility: Assign a member of the site management as the responsible authority for the Food Defense Program. Since you have to also meet the regulatory requirements for the FSMA Intentional Adulteration Rule, you should assign a person that has the competencies to undertake these responsibilities as this role will be appointed as the Food Defense Qualified Individual. This person should have decision-making authority and be a clear communicator. To meet FSMA requirements, the Food Defense Qualified Individual should complete the FSPCA Food Defense training course, which is the recognized standard for demonstrating the necessary competency under 21 CFR Part 121. It is important to note that comprehensive enforcement of the FSMA Intentional Adulteration Rule began in September 2024. The FDA now conducts full food defense inspections, separate from standard food safety inspections, with dedicated Consumer Safety Officers reviewing written Food Defense Plans and their implementation on the production floor. Facilities should ensure their Food Defense Qualified Individual and all related documentation are fully audit-ready under the current enforcement framework.
- Conduct a Threat Analysis: It is highly recommended that a Food Defense Team is assembled with representatives from each department of the operation. This will allow proper brainstorming to identify possible threats and analyze the significance (likelihood and severity) of these. During the threat analysis, vulnerabilities in the supply chain (external) and at the site (internal) are identified, and mitigation strategies are implemented to ensure the food safety of ingredients, materials and finished products.
- Implement Mitigation Strategies: Mitigation strategies must be implemented. Below are some suggested mitigation strategies:
- Physical Measures: Implement controlled and surveilled access. Also, implement tamper evident measures of incoming materials and finished goods.
- Personnel Security Measures: Conduct background checks for new hires and temporary employees. Conduct training on mitigation strategies and create a culture of food defense.
- Operational Practices: Regularly review and update operational procedures, ensure traceability of ingredients, and establish protocols for responding to security threats or suspicious activities.
- Monitor the Plan: Monitor the implemented mitigation strategies.
- Implement Corrective Actions: If there is a deviation from the plan or an incident happens, identify the root cause, and implement a corrective action.
Food Fraud Program
Food fraud is not a minor compliance concern. The FDA estimates that economically motivated adulteration costs the global food industry between $10 and $40 billion annually, with some industry analysts placing the figure at the higher end of this range. In 2025, fraud surges were recorded in nuts, dairy, and cereals, reinforcing that no commodity category is immune. A well-structured Food Fraud Program is one of the most commercially important investments a food manufacturer can make.
- Management Responsibility: Assign a member of the site management as the responsible authority for the Food Fraud Program. This person should have decision-making authority and be a clear communicator.
- Conduct a Vulnerability Assessment: Conduct assessment on ingredients to evaluate the risk of economically motivated adulteration, drawing historical incidents. Ensure to develop criteria and methods for this assessment, focusing on supply chain, economic factors, and historical data.
- Implement Prevention Strategies: Outline methods and assign responsibilities for preventing economically motivated adulteration. Implement verification procedures for ingredient sources, conduct random testing, and maintain strong supplier relationships.
- Train Personnel: Educate staff about the types of food fraud and their roles in prevention. Regularly update training to reflect the latest trends and findings in food fraud.
Establish record keeping procedures to ensure all documentation associated with the programs is kept secure.
Conduct an annual review for both programs involving key stakeholders.
Regular audits, both internal and external, can help ensure that these programs are effectively implemented and maintained. Remember, the goal of these programs is not just to comply with regulations but to proactively protect consumers and the integrity of the food supply chain.
Preparing for SQF Edition 10: What Changes for Food Defense and Fraud Programs
With SQF Edition 10 released in March 2026 and audits transitioning to the new edition from February 2027, facilities running active SQF programs should start reviewing how Edition 10 affects their Food Defense and Food Fraud requirements. The core framework under element 2.7 remains intact, but several meaningful updates will require action.
Cybersecurity is now part of food defense. This is the most significant new development. SQF Edition 10 formally adds cybersecurity to food defense program requirements. As food facilities become increasingly dependent on networked production equipment, digital quality management systems, and cloud-based traceability platforms, the risk of a cyberattack being used to intentionally compromise food safety processes has become a recognized food defense vulnerability. Facilities will need to assess their digital infrastructure as part of their Threat Assessment and document cybersecurity safeguards within their Food Defense Plan. This aligns with FDA’s direction under the FSMA IA Rule, which recognizes that inside attackers could exploit digital systems as a means of causing wide-scale harm.
Food safety culture is now a measurable, auditable requirement. Edition 10 elevates food safety culture from a soft expectation to a structured requirement with defined objectives and measurable outcomes. For Food Defense and Food Fraud programs, this means that the commitment of senior management to intentional adulteration prevention must be actively demonstrable through training records, communication logs, and documented review processes. A paper program alone will not be sufficient.
Scoring and non-conformance weighting have changed. Edition 10 introduces an updated scoring approach that places greater emphasis on core mandatory clauses. Non-conformances against these clauses are weighted more heavily than under Edition 9. For food defense and fraud programs, which are core GFSI requirements, this means that any gap identified during an audit will carry a greater penalty than it did previously. Facilities should use the transition period to conduct a thorough gap assessment against Edition 10 before their first Edition 10 audit window opens in February 2027.
The practical takeaway: do not wait for the audit cycle to begin making changes. The transition window between March 2026 and February 2027 exists precisely to allow facilities time to update their programs, retrain staff, and document the changes. Starting that process now gives facilities the best chance of a clean transition.
FAQs
Beyond decision-making and communication skills, they should have training in risk assessment, security management, and the specific requirements of the FSMA Intentional Adulteration Rule.
It is recommended to review and update these analyses annually or whenever there is a significant change in the operation or supply chain that could introduce new vulnerabilities.
Indicators can include sudden price drops, inconsistent product availability, and unusual shipping routes. Regular audits and maintaining strong communication with suppliers can help identify such red flags.
Technology such as blockchain for traceability, AI for monitoring supply chain anomalies, and advanced analytics for risk assessment can significantly enhance the integrity and responsiveness of these programs.
SMEs can focus on critical control points, leverage sector partnerships for shared resources and intelligence, and prioritize high-risk areas to optimize resource allocation.
Yes. SQF Edition 10, released in March 2026, adds cybersecurity as a formal food defense requirement and strengthens expectations around food safety culture and management accountability within both programs. Audits under Edition 10 begin in February 2027, giving facilities a transition window to update documentation, retrain staff, and close any gaps before their first Edition 10 audit.
