What Should a Food Business Do When a Product Is Recalled?

Food recalls can move quickly.

Your business may receive a recall notice from a supplier, manufacturer, food regulator or Food Standards Australia New Zealand. You then need to confirm whether you hold the affected product and prevent it from being sold, served or used.

AIA has developed a free, editable Food Recall Response Checklist Record to help food businesses document the steps they take when responding to a recall.

What is a food recall?

A food recall is action taken by a food business to remove unsafe or potentially unsafe food from distribution, sale and consumption.

A food product may be recalled because of:

• microbial contamination;
• an undeclared allergen;
• foreign matter;
• chemical contamination;
• incorrect labelling;
• a packaging fault; or
• another issue affecting food safety.

Food Standards Australia New Zealand coordinates food recalls in Australia with food businesses and state and territory authorities. Current consumer-level recalls are published on the official Australian food recall alerts page.

What are the food recall requirements?

The exact responsibilities depend on the type of food business.

Under Standard 3.2.2 – Food Safety Practices and General Requirements, food manufacturers, importers and wholesale suppliers must:

• maintain a written food recall plan;
• use that plan when unsafe food must be recalled; and
• provide the plan to an authorised officer if requested.

All food businesses must make sure any recalled food held on their premises is clearly identified and kept separate from other food until it is dealt with.

Restaurants, cafés, caterers, retailers and other food service businesses may not be responsible for initiating a recall. However, they still need to respond promptly when they hold or have used an affected product.

1. Read the complete recall notice

Begin by reading the recall notice in full.

Check the:

• product and brand name;
• pack size or description;
• batch or lot number;
• best-before or use-by date;
• supplier or recalling business;
• areas where the product was distributed;
• reason for the recall; and
• instructions for food businesses and consumers.

Do not rely only on a social-media headline, screenshot or forwarded message. Recall information can be updated.

Use the current FSANZ recall register to check the latest official product details and instructions.

2. Stop selling, serving and using the product

Once the affected product has been identified, stop:

• selling it;
• serving it;
• preparing food with it;
• transferring it to another site; and
• using it as an ingredient.

Where there is uncertainty about whether stock is included in the recall, hold it separately while the product details are confirmed.

Do not continue using a product simply because the original packaging has been removed or the food has been transferred into another container.

3. Check every location where the product may be held

Search all relevant areas, including:

• incoming deliveries;
• dry-storage areas;
• cool rooms;
• freezers;
• preparation areas;
• ingredient containers;
• display cabinets;
• service refrigerators;
• bar and beverage areas; and
• stock transferred to another business location.

Check invoices, delivery records, stock-transfer information and supplier communications.

Good traceability makes it easier to identify affected products quickly. Businesses should retain enough information to identify where food came from and, where relevant, where it was supplied.

4. Clearly identify and isolate recalled food

Move the affected stock away from food that remains available for sale, service or use.

Clearly label it with wording such as:

RECALLED – DO NOT USE OR SELL

The product should be held in a controlled location where staff cannot accidentally use it.

Depending on the business, this may be:

• a separate marked container;
• a dedicated shelf;
• a quarantine area;
• a secure cage; or
• another suitable holding area.

Do not relabel, repurpose, donate or use recalled food.

Follow the official recall instructions before returning, disposing of or otherwise dealing with the product.

5. Check whether the product has already been used

A recall response should not stop with unopened stock.

Determine whether the recalled product has been:

• used in prepared food;
• added to sauces, fillings or menu items;
• repacked or relabelled;
• transferred to another location;
• supplied to another business;
• sold or served to customers; or
• mixed with other stock.

For example, a recalled cheese may no longer be sitting in its original packaging. It may already have been used in sandwiches, sauces, salads, pizzas or prepared meals.

The business may need to isolate or remove food containing the recalled ingredient while it confirms the required action.

6. Follow the recall instructions

The recall notice, supplier or regulator may instruct the business to:

• return the product;
• retain it for collection;
• dispose of it;
• report the quantity held;
• notify other business locations;
• notify customers;
• complete specified records; or
• take another action.

Do not automatically throw the affected product away before checking the instructions.

The supplier or regulator may require it to be retained, counted, photographed, collected or returned.

7. Notify relevant people

Make sure the appropriate people understand what has been recalled and what action they need to take.

This may include:

• the business owner or manager;
• the Food Safety Supervisor;
• kitchen staff;
• front-of-house staff;
• receiving or warehouse staff;
• staff at other locations;
• the supplier;
• the local food regulator; and
• customers, where required.

Staff should know:

• which product is affected;
• how to recognise it;
• where isolated stock is being held;
• which menu items or activities must stop; and
• who is responsible for further action.

Information provided to customers should be based on the official recall notice. Staff should not speculate about the risk or give unsupported medical advice.

8. Record what the business checked and did

A written record helps the business keep track of the response and demonstrate what action was taken.

Useful details include:

• when the recall notice was received;
• who received the notice;
• affected product details;
• locations checked;
• quantities identified;
• prepared food or menu items affected;
• how the product was isolated;
• staff, suppliers and other sites contacted;
• return, collection or disposal details;
• supporting evidence;
• corrective action; and
• management review.

AIA’s Food Recall Response Checklist Record provides an editable structure for recording this information.

The Word document can be customised with your business’s:

• name;
• ABN;
• contact details;
• address;
• logo; and
• internal responsibilities.

9. Consider whether cleaning and sanitising are required

A recall does not automatically mean every area needs to be cleaned and sanitised.

The action required depends on:

• the reason for the recall;
• whether the product leaked or spilled;
• whether it was opened or handled;
• whether equipment or food-contact surfaces were affected; and
• whether other food may have been exposed.

Where cleaning and sanitising are necessary, follow an appropriate procedure and record the action taken.

AIA’s Food Hygiene information explains broader food hygiene principles for food businesses and food handlers.

10. Review the business’s response

Once the immediate response is complete, review whether the business could:

• identify the affected product quickly;
• locate all stock;
• trace where the product had been used;
• contact the appropriate people;
• isolate the product effectively;
• follow the recall instructions; and
• retain adequate evidence.

A recall can expose weak points in receiving, traceability, stock control, internal communication and record keeping.

Corrective action might include:

• improving receiving records;
• changing stock-identification procedures;
• updating contact details;
• clarifying staff responsibilities;
• improving supplier records;
• revising the business’s recall process; or
• providing further staff instruction.

For additional food safety information and regulatory updates, visit AIA’s Food Safety News.

Download the editable Food Recall Response Checklist Record

AIA’s free Word form includes sections for:

• recall and product details;
• immediate response actions;
• affected stock and menu items;
• staff and supplier communication;
• returned, collected or disposed stock;
• corrective action;
• manager review; and
• final sign-off.

You can add your business details and logo before saving the document as part of your food safety records.

Download the free editable Word form

Important limitation

This checklist helps a food business document its response to a recall.

It does not replace:

• the official recall notice;
• supplier instructions;
• regulator directions; or
• the written food recall plan required for manufacturers, importers and wholesale suppliers.

FSANZ provides a separate Food Recall Plan Template for businesses required to establish a written recall system.

Prepare before a recall happens

Businesses should not wait for an urgent recall before deciding:

• who is responsible for coordinating the response;
• where recalled food will be held;
• how staff and other locations will be contacted;
• how supplier records will be checked;
• how customer enquiries will be handled; and
• what records and evidence will be retained.

Manufacturers, importers and wholesale suppliers should also check that their written recall plan works by conducting a practice recall. FSANZ identifies practice recalls as a useful way to test recall arrangements.

Training delivered by Australian Institute of Accreditation (RTO 45009). Upon successful completion, learners receive a Nationally Recognised Statement of Attainment for the units listed above. For details about fees, assessment requirements, and learner support, visit our website https://www.aia.edu.au/