FOOD PRODUCT

RECALL PROCEDURE

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INTRODUCTION
Food recalls are a common occurrence in the UK and all across the world. They can arise
due to a variety of reasons, such as a missing allergy label, the presence of a physical
contaminant, like glass, or because of a bacterial contaminant within the product, like E. coli.

Knowing how to respond to a food product recall is essential. Not only can the affected
food cause harm to consumers, it can also have catastrophic effects for a business if it’s not
correctly handled. As a food manufacturer, you must know how to handle product recalls
and understand the steps that you need to take.

WHAT IS A FOOD PRODUCT RECALL PROCEDURE?

A food recall procedure is the name for actions taken to remove any food from sale,
distribution, and consumption which may pose a food safety risk to consumers. It can occur
due to a report from various sources, including manufacturers, wholesalers, retailers, and
consumers. Additionally, a food product recall may occur during a food business’s testing or
auditing.

While food product recalling can happen at a variety of stages, from manufacture to
consumption, there are two primary categories of recall:

1. Trade level recall.

This type of recall is conducted when the food has not been sold directly to consumers. It
usually means that the product will be recovered from distribution centres and wholesalers.

2. Consumer level recall.

This is a much larger scale of recall than trade level. It involves recovering a food product
from all points in the food chain, including retrieving it from consumers after they’ve
purchased it.
There are a number of reasons why a product may be recalled. However, there are two main
types of product recall:

1. Food allergy recalls.

These are recalls that occur due to allergy concerns. For example, if the allergy information
wasn’t very clear, it was labelled incorrectly, or it was completely missing on the label.

2. Food safety recalls.

These happen when there is a safety concern about a certain food. For example, if a food
product contains a high concentration of a substance not safe for consumption (such as
pesticides or cleaning chemicals), if a foreign substance is in the product (like bits of plastic,
rubber, or metal), or if the food is found to contain harmful bacteria (such as salmonella).
Other reasons for food safety recall include contamination and environmental pollution
incidents, such as chemical spills that have affected food.

A consumer may also complain about a food product if they’ve been harmed by it or become
ill from eating it, prompting a recall.

WHAT IS THE DIFFERENCE BETWEEN A FOOD RECALL AND FOOD

WITHDRAWAL?
A food withdrawal is where action is taken to remove food from the supply chain before it
has reached consumers. It may occur when the food product has a quality defect, such as a
slightly different colour to, or being smaller than, usual. It may also occur as a precautionary
measure, such as if it’s pending an investigation.

In contrast, a recall happens when unsafe food is removed from the supply chain when the
product is already available to consumers, and they are advised to take appropriate action.
For example, returning the unsafe food for a refund or disposing of it.
STEPS OF A FOOD PRODUCT RECALL
As a food manufacturer you must know how to keep your consumers as safe as possible.
Knowing each important step in a food product recall process is therefore essential.

The first part of a product recall involves the safety issue coming to your attention. You
may notice a hazard yourself, you may be contacted from somebody further down the
supply chain, or customers may complain about a product they’ve eaten. In a worst-case
scenario, somebody may die because of allergenic contamination in your products.

You must take any food safety concern seriously and take immediate action to recall it if
needed.

STEP ONE: DECIDE IF THE FOOD NEEDS TO BE RECALLED

All food manufacturers, handlers, and retailers have a responsibility to ensure that food is
safe to eat. Food should not be placed on the market if it is unsafe. Under food safety law:


If a food business operator considers or has reason to believe that a food which it has
imported, produced, processed, manufactured or distributed is not in compliance with the
food safety requirements, it shall immediately initiate procedures to withdraw the food
in question from the market where the food has left the immediate control of that initial
food business operator and inform the competent authorities thereof.

Where the product may have reached the consumer, the operator shall effectively and
accurately inform the consumers of the reason for its withdrawal, and if necessary,
recall from consumers products already supplied to them when other measures are not
sufficient to achieve a high level of health protection.”

- Article 19 of Regulation (EC) No. 178/2002

Therefore, if you have any reason to suspect that food could pose a hazard to consumers,
you must recall it. This is regardless of how the concern comes to your attention.

STEP TWO: CREATE A FOOD RECALL TEAM

After identifying food that needs to be recalled, you should assemble a team of people who
can help you recall it. Ensure that you have plenty of people to help throughout the process
and make it run as smoothly as possible.
STEP THREE: GATHER INFORMATION ON THE FOOD SAFETY INCIDENT

Once you have your team in place, you should then begin to gather all the necessary
information. Collect details of the food, what the hazard is, how the hazard was allowed to
happen, and the extent of the problem. For example, is the food available to consumers at
the point when you recognise the safety concern?

This type of information can be gathered from a variety of internal and external sources,
including:

• Production records.
• Sales records.
• Employees.
• Suppliers.
• Complaints.
• Audit.
• Sample analysis.

STEP FOUR: GATHER INFORMATION ON THE FOOD SAFETY INCIDENT

After gathering all your information about the food you will recall, you need to notify the
relevant authorities. You must notify:

• Your food enforcement authority.

• The FSA if you are in England and Wales, FSS if you’re in Scotland, and FSANI if you’re in
Northern Ireland.
• Your suppliers and business customers.
You should notify your enforcement authority and the FSA/FSS/FSANI using established
reporting procedures. Don’t delay this – if not all information is available, provide what you
have so far rather than waiting to collect it all.

At this point, you should notify any businesses that you provided the food to, such as
supermarkets and restaurants, using the information that you gathered in step three. They
must then remove the product from the shelves, stop preparing food using it, and prevent it
from getting to consumers in any way.

STEP FIVE: GATHER INFORMATION ON THE FOOD SAFETY INCIDENT

It’s likely that you will still have a number of products in your control that are affected by the
identified issue. For example, if you have a packaging fault due to a piece of machinery, then
every product that has since gone through that machinery may have the same default.

You must check the remaining products on your manufacturing premises and identify any
further products that are a cause of food safety concern. Remove these products from your
production line and ensure that you keep them separate from food that is safe to eat.

STEP SIX: NOTIFY CONSUMERS

All customers who have been, or are likely to have been, affected by a harmful food product
must be notified of it. You must use an effective communication method to inform them of
the actions they need to take, and ensure the information provided to them is accurate.

Consumers are usually notified through a range of means:

• The shop where the affected food was sold may display a sign somewhere in the shop
(such as in the window, the entrance, or on the shop floor near the affected product).
 • They may be emailed. For example, if they signed up for a store’s loyalty card with their
email address and they scan this when they pay for an affected item, the store can track
that they bought the item and let them know.

• Notices are displayed on the Food Standards Agency website (or FSS or FSANI).

• In cases that have a particularly high risk, where lots of people are expected to be
affected or where somebody has died as a result of eating a contaminated product, then
it could appear in the news.

When you notify consumers about the food recall, you must also explain what they should
do with the affected product that’s in their possession. This usually involves taking it back to
the shop they bought it from for a full refund.

STEP SEVEN: MONITOR PROGRESS

Throughout the food recall process, you should continually monitor its progress. This means
that you should maintain communication between yourself and the food enforcement
authority, the FSA/ FSS/ FSNAI, and business customers.

STEP EIGHT: CONTROL RECALLED PRODUCTS

Once the recalled products start making their way back into your factory, you need to
decide what to do with them. You must keep them separate from other products for a
number of reasons, such as if a product contains an allergen that may contaminate other
products. Keep them in a controlled environment until you decide what you will do with
them.
STEP NINE: DISPOSE OF RECALLED PRODUCTS

In the majority of cases, food that’s been recalled will need to be disposed of. How you
dispose of the item will change based on the reason for the recall. For example, if something
contains a foreign object (e.g. plastic) then this would be disposed of very differently to
something that contained harmful bacteria like listeria. You should ensure that you have
food disposal procedures in place for recall situations.

Additionally, depending on the nature of the food recall, it may be necessary for you to keep
a sample of the product for testing.

STEP TEN: FIX THE CAUSE OF THE RECALL

Depending on the nature of the food recall, how you fix the initial cause can vary
dramatically. For example, if your product is found to contain an undeclared allergen, then
this can be rectified by either changing the packaging or changing the recipe. If the issue
stemmed from somewhere in your hazard analysis system or food production line, this
would need to involve a more careful consideration and evaluation of your procedures. It’s
essential that you fix the cause of the recall to prevent it, to the best of your ability, from
happening again.

FOOD PRODUCT RECALL EXAMPLES

Food recalls happen all the time and often they are not thought to cause serious concern.
However, there have been cases in which recalls have made national news.

GRAZE RECALLS VEGAN SNACK

In March 2019, snack company Graze recalled a

product that they labelled as vegan when it was
found that it actually contained milk. The ‘Sea
Salt and Vinegar Veg Crunchers’ were not only
mislabelled to be vegan, but also posed a serious
risk to anybody who had a milk intolerance or
allergy and judged that the product was safe to eat.

The company apologised for the product and

claimed that no other products had been affected.
However, Graze are not the only company who
have been caught out by this, with many other
companies also missing allergen information from
their packaging every week.
Image taken from Graze
BRITVIC PLC RECALLS SELECTED ROBINSONS FRUIT SHOOTS

On 30th June 2019, the Food Standards Agency announced that Britvic PLC was recalling
selected Robinsons Apple and Blackcurrant Fruit Shoots based on a small number of
reports. The reports stated that the spout within the sports bottle cap may become
detached unexpectedly, presenting a safety risk.

These bottles were sold as multipacks in Tesco and Costco and as single bottles in
McDonald’s. Point of sale notices were displayed in all retail stores that sell this product,
which explained why the product was being recalled and what consumers that bought it
should do.

FOOD PRODUCT RECALL CHECKLIST TEMPLATE

Use the checklist on the next page when carrying out a food product recall. It allows you
to keep track of the progress of your recall and ensure that you are completing all the
necessary steps.

High Speed Training has developed this food recall procedure template for you to use in the
event of needing to recall a product. This template is not exhaustive and you may need to
implement further steps based on the nature of your recall.

High Speed Training is the owner of this article and template.

 STAGES OF PERSON DATE OF
TASKS TO COMPLETE
RECALL RESPONSIBLE COMPLETION

Conduct a risk assessment for the food

Decide whether the

Review any reports about the problem with the
food needs to be
food, if you have them
recalled
Communicate the details of the recall with
everyone on the premises

Assemble a group of people in your organisation

to help with the recall
Assemble a food
recall team
Make contact with a legal firm, if necessary

Discover the cause of the hazard

Identify the affected batch

Gather information
and investigate the
food safety incident
Understand how the hazard happened

Gather any relevant information from internal

and external sources

Cease production of further affected products

Stop distribution
Block affected stock from being distributed and
stop ongoing distribution of affected products

Make a product recall notice to be shared in

Create your retail outlets
communication
materials
Write any media correspondence

Contact your food safety enforcement authority

Contact the FSA/FSS/FSANI

Notify the relevant

authorities and Contact your suppliers
people
Fill in any necessary forms and paperwork
needed for the recall

Notify your customers and anybody who you

sold and distributed the product to

TEMPLATE PRODCED BY
 STAGES OF PERSON DATE OF
TASKS TO COMPLETE
RECALL RESPONSIBLE COMPLETION

Plan for product returns

Establish return
procedures
Arrange disposal of blocked or returned affected
stock, if necessary

Plan where the returned products will go and

how you will handle them
Keep products
separate
Set aside any products in your current control
that are also affected by the hazard

Maintain contact with the local enforcement

authority

Maintain contact with the FSA/FSS/FSANI

Maintain contact with suppliers, retail outlets,

Monitor progress
consumers, and anybody else affected by the recall

Maintain contact with your legal firm

Handle any communications with the media and

PR agencies

Receive returned products

Handle returned
products
Segregate returned products from other
products

Keep a number of returned products for testing,

if necessary

Dispose of recalled
Dispose of the unsafe returned products
products

Dispose of any products that you suspect were

affected

Resolve the fault/reason for the recall

Fix the reason for the
recall
Review your hazard analysis system

Ensure that you all have all the relevant

information and documentation for the recall,
Record and close the should you need it later
recall
Close the recall when all steps are completed

TEMPLATE PRODCED BY