INDONESIA’S COMMENTS ON FOOD FRAUD

2nd CIRCULATION

Indonesia would like to thank for the great work done by chair and co-chair for EWG on food fraud
to prepare this discussion paper. Please find attached Indonesia’s comments for consideration.

We would like reproposed the definition for food fraud, as below:

Food fraud is the act of purposely (1) altering, adulterating, misrepresenting, mislabeling,
substituting, diluting, placing information that is misled consumer interpretation at any point along
the food supply chain so that the safety, quality, and fair trade practices of food are compromised,
(2) distributing and unknowingly distributing of such products.

Furthermore, Indonesia would like to response the questions for EWG on food fraud regarding
the scope of the proposed new work, what types of government controls are used to prevent “food
fraud” and “intentional adulteration” and what mechanisms are carried out when food fraud occurs
with public health risks as greater priority, as follows:

1. The scope for proposed new work on food fraud should include:
a) How is the vulnerability assessment carried out on products with potential food fraud
and their impacts?
b) How to identify the risk of possible Food Fraud at any point along the supply chain,
especially at the highest risk involving Food Business Operators (both imported
products and domestic production products)?
c) How to design a mitigation and control program to prevent Food Fraud?
d) How is the implementation of mitigation and control carried out to prevent Food Fraud?
e) How to design a corrective action program if Food Fraud occurs?
f) How to communicate between Codex member countries if there is an indication of Food
Fraud on internationally traded products?
2. Types of government controls that used to prevent “food fraud” and “intentional adulteration
in Indonesia are as follow:
a) Implementation of product traceability system through product registration before
traded, labeling, implementation of quality assurance systems (audit and inspection of
SOP, GMP, HACCP and FBOs certification);
b) Market surveillance in the supply chain, among others through sampling at producers,
distributors and markets for detection methods (DNA test);
c) Other administrative measures, such as QR Code, Barcodes and etc. (it depends to
the readiness of each country);

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3. Public health is prioritized when food fraud occurs, mechanisms implemented in Indonesia
are:
a) Re-export for the import products;
b) Product withdrawal from distribution done by producers (recall) and/or product
destruction;
c) Temporary suspension of production and/or distribution activities;
d) Revocation of product licenses;
e) Criminal sanctions and fines;