Food recall management is essential for ensuring the safety of public health. When food is found to be unsafe, contaminated, mislabeled, or non-compliant with safety standards, a recall must be quickly executed to protect public health. This process involves identifying, communicating, and removing the affected products from the market to prevent consumer harm and maintain trust.
Food Business Operators (FBOs) are responsible for initiating and managing recalls. They must monitor their products and act swiftly when a recall is needed. This includes forming a recall team, notifying authorities, and informing consumers and other stakeholders.
Regulatory authorities, like the Food Safety and Standards Authority of India (FSSAI), oversee the recall process, ensure compliance, and guide FBOs. Cooperation between the industry and regulators is crucial for effective recalls, reducing public health risks, and maintaining food industry credibility.
Steps for food recall management
At the very beginning of the recall the FBO should initiate the formation of a recall management team and assign the recall duties to each person and should ensure that all members of the recall management team are informed of the decision to conduct a recall and each member knows their responsibilities during the recall.
The team should include people responsible for:
- Decision making
- Quality assurance / technical advisory
- Media communication
- Complaint investigation
- Contacting accounts
- Food Authority Contact
- Legal Counsel
The management team document should contain the following:
RECALL MANAGEMENT TEAM | ||||
NAME | ALTERNATE PERSON | BUSINESS PHONE | AFTER HOURS PHONE | RESPONSIBILITIES DURING RECALL |
Inform the concerned regulatory authority at the earliest opportunity, after an incident is identified that may lead to a recall and should be updated throughout the process. The information should include the following:
- a detailed description of the nature of the problem
- the name, brand, size, lot code(s) affected
- details of complaints received and any reported illnesses
- the distribution of the product – local or national
- when was the product distributed (specific dates)
- label(s) of the product(s) which may be recalled
- the total quantity of products manufactured and distributed
- the name of your firm’s contact with the authority
- the name and telephone number(s) for your firm’s after-hours contact
The detailed information is given under Schedule I of FSS (Recall Procedure) Regulations, 2017.
It is the responsibility of FBO to ensure that all products which need to be recalled are identified. In addition to those products directly affected by the problem, the FBO should:
- determine if any other codes, brands or sizes of the same product are affected
- determine if any other products are affected
The FBO should ensure that all products to be recalled that are in your firm’s control are not distributed and;
- determine the locations of the recalled product(s) e.g. on-site, at the plant, offsite storage
- determine the amounts at each location
- identify and segregate products to prevent distribution
Informing the consumer:
Depending on the extent of the recall, the company concerned should inform the consumer of the recall at the earliest possible moment. Information dissemination may take the form of a press release, letter to the concerned parties or paid advertisement in the media. Sufficient telephone hotline service should be made available to deal with enquiries.
Information within the Food chain:
The FBO shall inform everyone in the food chain from the raw material vendor to the supplier and any other relevant retailer or trade association of the affected food by written communication, phone, e-mail, fax, or a combination of thereof.
The press release, letter or advertisement shall be in the form of ‘Food Recall Notice’ and shall contain the following information, namely:-
- Name of the Food Business Operator recalling the food;
- Name of the food, brand name, pack size, batch and code number, date of manufacture, used by date or best before date;
- The contamination or violation in the food or reason for such recall;
- “do not consume message”;
- Health warnings and actions
- The places or outlets where the food is found;
- The action to be taken by the consumer;
- Contact number for queries.
The FBO must:-
- complete the press release within two hours after being notified of the recall
- submit a draft of the proposed Press Release, if required, to the concerned Authority for approval
- arrange for translation of the press release for concerned region
Keeping accurate distribution records allows to limit the recall to the specific accounts that received the product being recalled. Using the distribution record system, produce a product and lot code specific distribution list which:
- identifies the accounts that received the recalled product
- lists the accounts names and addresses, contact names and telephone numbers
- identifies the type of account e.g., manufacturer, distributor, retailer
The food business operator should determine whether the recall is progressing effectively and submit periodic status reports to the concerned authority to inform the progress of the recall. FBO shall submit the periodic recall status report once in a week or as otherwise specified by the concerned authority
To conduct an effective recall, the FBO should maintain the food distribution records which include Name and address of suppliers and distributors, date of purchase of raw material, batch code, lot number and complete traceability from Raw material to finished goods.
The FBO must;
- verify that all accounts have stopped distributing and selling the recalled product(s) product(s)
- verify that the recalled product(s) have been returned to the
The product is to be recovered to a central site, or in the case of widely distributed product, to major recovery sites. The recovered product must be stored in an area which is separated from any other food product. Accurate records are to be kept of the amount of recovered product and the batch codes of the product recovered.
- It is the responsibility of the FBO to ensure that recalled products do not re-enter the market.
- separate and clearly identify recalled product(s)
- reconcile quantities and monitor returned product(s)
- record the recalled product(s) in Recalled Product Records document
After recovery, products may be corrected or reprocessed before release to the market if it is fit for human consumption. Otherwise the product is to be destroyed. The action to be taken on the recalled product should be approved by the competent Authority
- decide on the action to be taken on the recalled product e.g., correction, re-export, destruction
- find out if the Authority wants to witness/verify that the action has been taken
- verify that the action has been effective
- record the action taken for each product in your Recalled Product Records document
As the manufacturing firm that produced the unsafe product, it is your responsibility for ensuring that all reasonable steps are taken to prevent similar recalls in the future.
- put controls in place or revise existing controls to prevent similar problems in the future
By following these steps, FBOs can effectively manage food recalls, ensuring public health protection and maintaining consumer trust in the food supply chain. The information was sourced from GUIDELINES FOR FOOD RECALL.
Would you like to get your FSSAI license? Hurry up! Legal Terminus can provide valuable assistance in smoothly and efficiently handling the registration process. Our experts ensure a hassle-free and timely transition, helping you fulfill your legal and regulatory obligations effectively. Reach out to us now to take advantage of our expert services and free consultation.
This document is intended for informational purposes and provides a general overview of the Food Safety and Standards (Food Recall Procedures) regulation, 2017. It should not be construed as legal advice. Entities and individuals must consult legal experts to ensure compliance with the specific legal requirements and interpretations of the Act.
Prepared by
Mr. Smruti Ranjan Sahoo
(B. Com., LL.B)
