Nina Puhač Bogadi, Natalija Uršulin-Trstenjak, Bojan Šarkanj, Ivana Dodlek Šarkanj
The malicious contamination of food has been recognized by the World Health Organization (WHO) as a real and current threat that must be integrated into food safety systems to ensure preparedness for deliberate attacks. Traditional approaches, such as HACCP, effectively address unintentional hazards but remain insufficient against intentional contamination and sabotage. Food defense frameworks such as HACCP (Hazard Analysis and Critical Control Points), VACCP (Vulnerability Assessment and Critical Control Points), and TACCP (Threat Assessment and Critical Control Points) represent complementary methodologies, addressing unintentional, economically motivated, and deliberate threats, respectively. This review critically examines food defense frameworks across the European Union, the United States, and the United Kingdom, as well as standards benchmarked by the Global Food Safety Initiative (GFSI), drawing on peer-reviewed and grey literature sources. In the United States, the Food Safety Modernization Act (FSMA) mandates the development and periodic reassessment of food defense plans, while the European Union primarily relies on general food law and voluntary certification schemes. The United Kingdom’s PAS 96:2017 standard provides TACCP-based guidance that also acknowledges cybercrime as a deliberate threat. Building on these regulatory and operational gaps, this paper proposes the Cyber-FSMS model, an integrated framework that combines traditional food defense pillars with cyber risk management to address cyber–physical vulnerabilities in increasingly digitalized supply chains. The model introduces six interconnected components (governance, vulnerability assessment, mitigation, monitoring, verification, and recovery) designed to embed cyber-resilience into Food Safety Management Systems (FSMS). Priority actions include regulatory harmonization, practical support for small and medium-sized enterprises (SMEs), and the alignment of cyber-resilience principles with upcoming GFSI benchmarking developments, thereby strengthening the integrity, robustness, and adaptability of global food supply chains.