How to Manage a Food Recall or Withdrawal

A food recall removes unsafe food from the supply chain when it poses a threat to public health and safety; a withdrawal removes food for quality, labelling or suitability issues that are not safety risks. If you manufacture, import or wholesale food in Australia, you generally must have a written recall plan, notify your state or territory food regulator and the FSANZ Recall Team, retrieve affected stock, and report. Act fast and confirm every step with your regulator. Key takeaways: A recall addresses a public health and safety risk and must be reported to authorities; a withdrawal handles quality, labelling or suitability problems that are not safety issues and generally does not require a formal recall.. Under clause 12 of Standard 3.2.2, food businesses that manufacture, import or wholesale food generally must have a written food recall system, make it available to an authorised officer on request, and comply with it when recalling unsafe food.. FSANZ coordinates recalls nationally and maintains the Food Industry Recall Protocol, but you notify through your home state or territory food regulator and the FSANZ Recall Team; the recalling business runs the recall itself.. Recalls are classed as trade (business-to-business only) or consumer (food has reached the public); consumer recalls need public notification and point-of-sale notices.. Interim and final recall reports are generally due within set timeframes; always confirm current requirements, contacts and timeframes with your regulator, as these can change.. Recall versus withdrawal at a glance: Aspect, Recall, Withdrawal. Reason — A public health and safety risk — Quality, labelling or suitability, not a safety risk. Typical triggers — Contamination, undeclared allergen, foreign matter, unsafe date marking — Minor labelling error, quality defect, out of specification. Report to authorities — Yes, notify your regulator and the FSANZ Recall Team — Generally not; managed internally through distributors and retailers. Recall vs withdrawal: know the difference The first decision in any incident is whether you are running a recall or a withdrawal, because they trigger very different obligations. A food recall is the action taken to remove food from the supply chain and, where necessary, from consumers, when the food poses a threat to public health and safety. Typical triggers include microbiological contamination (for example Listeria, Salmonella or pathogenic E. coli), undeclared allergens, foreign matter such as glass or metal, chemical or contaminant issues, or incorrect date marking or storage instructions that make food unsafe. Undeclared allergens are consistently among the most common causes of food recalls in Australia, which is why accurate allergen declaration under the Food Standards Code (including the Plain English Allergen Labelling requirements in Standard 1.2.3) is so closely tied to recall risk. A food withdrawal is the removal of food from the supply chain for reasons that are not a public health and safety issue, such as a minor labelling error that does not affect safety, a quality defect, an ethical or suitability concern, or a product that is out of specification. Because there is no safety risk, a withdrawal generally does not need to be reported to authorities in the same way and is managed internally through your distributors and retailers. The distinction matters legally and practically. Treating a genuine safety issue as a quiet withdrawal can leave unsafe food in consumers' hands and expose your business to enforcement. When you are unsure whether an issue is a safety risk, treat it as a potential recall and seek advice from your state or territory food regulator promptly. Trade recall vs consumer recall If you decide a recall is needed, it will usually be classified as one of two types, which determines how far you must reach. A trade recall applies when the affected food has only been distributed to other businesses (for example distributors, wholesalers, food service, or retailers' warehouses) and has not been made available to the general public. Recovery is confined to the trade level. A consumer recall applies when the food has been dispersed at all levels of the market, including to consumers. This is the most extensive type and requires recovering product from every point down to the household, which means public communication is essential. The type is generally decided in consultation with the recall coordinator based on where the product has actually gone, so accurate distribution records are critical to getting the classification and reach right. The FSANZ role and your recall plan Food Standards Australia New Zealand (FSANZ) coordinates food recalls at the national level and maintains the Food Industry Recall Protocol (FIRP), the reference document that explains how recalls are conducted in Australia. FSANZ does not usually run the recall for you; the food business that owns or supplies the product (the recalling company) is responsible for carrying it out. FSANZ, working with state and territory regulators, provides coordination, liaises across jurisdictions, and monitors that the recall is effective. FSANZ also advises other bodies such as the Australian Competition and Consumer Commission (ACCC) and the relevant state or territory health authority of recall information. Under clause 12 of Standard 3.2.2 (Food Safety Practices and General Requirements), food businesses engaged in the manufacture, importation or wholesale supply of food are generally required to have in place a system to recall unsafe food, to set that system out in a written document (a food recall plan) and make it available to an authorised officer on request, and to comply with it when recalling unsafe food. (The newer Standard 3.2.2A on food safety management tools does not displace this recall duty.) Your plan should document internal procedures and staff responsibilities, notification contacts (your home state regulator, the FSANZ Recall Team, distributors, wholesalers, retailers and consumers), the distribution and traceability records needed to identify and retrieve affected food, and procedures for retrieving product and assessing any returned stock. FSANZ publishes a Food Recall Plan Template and recall templates you can adapt. Keep the plan current, test it, and make sure the named contacts are correct — a plan written years ago with staff who have left is a common failure point. Step-by-step: managing a recall When a potential safety issue emerges, move quickly and methodically. The steps below follow the general approach in the Food Industry Recall Protocol, but always confirm the current process, forms and contacts with your regulator, because details and phone numbers can change. Investigate and decide: gather the evidence (complaint, test result, supplier alert), assess the health risk, and decide whether it is a recall or a withdrawal. Involve your food safety lead early.. Notify your regulator and the recall coordinator: contact your home state or territory food regulator and the FSANZ Recall Team without delay, and complete the Food Recall Report and distribution list as soon as possible.. Identify the affected product: pin down product name, brand, pack size, batch or lot codes, best-before or use-by dates, and the quantity produced and distributed.. Determine distribution: use your traceability records to map exactly where the product went and decide, with the coordinator, whether it is a trade or consumer recall.. Prepare communications: draft the recall notice and, for consumer recalls, arrange public notification (recall notice via press or website) and point-of-sale notices for retailers.. Retrieve and isolate stock: instruct customers to stop selling and return or dispose of product; clearly segregate and label recovered stock to prevent it re-entering the supply chain.. Report and reconcile: submit the interim and final recall reports within the required timeframes, reconciling how much product was recovered against how much was distributed.. Review and correct: run a root-cause analysis, fix the underlying problem, and update your recall plan and food safety program.. Who to notify Getting the notification chain right is one of the most important parts of a recall. Your first external contact is generally to your home state or territory food regulator (for example the NSW Food Authority, or the relevant health department in Victoria, Queensland and other jurisdictions) and to the FSANZ Recall Team, which coordinates nationally. FSANZ lists a recall phone line (currently (02) 6228 8226, then press #1 for the Recall Team) and the food.recalls@foodstandards.gov.au email address — always use the current details published on the FSANZ site, as contact points can change. Beyond the regulator, you will typically need to notify everyone in your distribution chain: distributors, wholesalers, transport and storage providers, retailers, and food service customers. For a consumer recall you must also reach the public, usually through a recall notice and point-of-sale material. Depending on the product and where it was sold, you may also need to inform export authorities if any product went overseas, and any co-manufacturers or brand owners if you produce food under another company's label. Keep a log of who was notified and when — this becomes part of your recall records and evidence that the recall was effective. Records, traceability and reporting A recall is only as good as your records. The Food Standards Code's traceability expectations (one-step-back, one-step-forward records) mean you should be able to identify your immediate suppliers and immediate customers for any batch. Practically, that means keeping accurate records of raw material batches, production and batch coding, and distribution — who received what, in what quantity, and when. During and after a recall you will generally need to provide reports to FSANZ. Under the current Food Industry Recall Protocol, an interim post-recall report (progress and partial figures) is generally due about two weeks after the recall is initiated, and a final post-recall report with final stock-recovery figures is generally due about four weeks after initiation; confirm the exact timeframes and forms required at the time, as these are set out in the current protocol and can change. The final report should reconcile the quantity distributed against the quantity recovered or accounted for, which is why disciplined traceability records make the difference between a fast, contained recall and one that drags on. Worked examples: Undeclared allergen: a recall: A batch of sauce is found to contain milk that is not declared on the label. Because an undeclared allergen is a public health and safety risk, this is a recall, not a withdrawal. The business notifies its state regulator and the FSANZ Recall Team, identifies the affected batch codes, and retrieves stock. Minor labelling error: a withdrawal: A product's label has a spelling error that does not affect safety or allergen information. This is a withdrawal, so the business removes affected stock through its distributors and retailers and manages it internally, without the formal notification a recall requires. Checklist: A current, written food recall plan naming responsibilities, records and notification contacts is in place, tested, and available to an authorised officer on request. Up-to-date contact details for your state/territory food regulator and the FSANZ Recall Team are recorded and accessible after hours. Traceability records allow you to identify one step back (suppliers) and one step forward (customers) for every batch. Batch/lot coding and date marking let you isolate affected product precisely. A decision process exists to classify incidents as recall or withdrawal, and trade or consumer. Templates for the recall notice, point-of-sale notice, Food Recall Report and distribution list are ready to adapt. A method for segregating, labelling and disposing of recovered stock is defined. Responsibility for interim and final reporting and reconciliation is assigned. Common mistakes: Treating a genuine safety issue as a quiet withdrawal to avoid a formal recall, leaving unsafe food with consumers. Having no written recall plan, or one with outdated staff names and contact numbers. Poor traceability records, so you cannot quickly identify affected batches or where product was distributed. Delaying notification to your regulator and the FSANZ Recall Team while trying to manage the issue internally. Failing to segregate and clearly label recovered stock, allowing it to re-enter the supply chain. Under-reaching a consumer recall by not publishing public notices when product has reached households. Missing the interim and final report deadlines or failing to reconcile distributed versus recovered stock. Fixing the immediate batch but skipping root-cause analysis, so the problem recurs. State and territory notes: NSW: Your home-state contact is generally the NSW Food Authority; notify them alongside the FSANZ Recall Team, which coordinates nationally. VIC / QLD: The relevant state health department is generally your home-state contact in Victoria, Queensland and other jurisdictions; confirm the current contact for your jurisdiction. All states/territories: You notify through your home state or territory food regulator plus the FSANZ Recall Team, but the recalling business still runs the recall itself.