Food recall obligations: what
manufacturers must have in place
Who needs a written recall plan, who you call first, what happens next, and how to test your plan before you need it.
4 min read
If you manufacture, wholesale or import food in Australia, Standard 3.2.2 (clause 12) requires you to have a written recall system and to follow it. If food you’ve supplied may be unsafe, call your state food enforcement agency straight away. In Victoria that’s the Department of Health. Once a recall is confirmed, the FSANZ Food Recall Coordinator helps coordinate it and notifies the ACCC for you, which covers the two-day notification required under the Australian Consumer Law.
Recall, withdrawal, trade or consumer?
Using the wrong word causes real confusion with customers. Only a safety risk makes it a recall.
| Term | When it applies | Government notified? |
|---|---|---|
| Trade recall | Unsafe food has gone to other businesses (distributors, wholesalers, manufacturers, or food service for immediate eating) but not to the general public | Yes |
| Consumer recall | Unsafe food has, or may have, reached the general public. Stock is recovered from every point, including shoppers’ homes | Yes |
| Withdrawal | Food is pulled for a quality problem, such as a cosmetic defect or underweight packs, with no safety risk | No. Don’t call it a recall |
Common reasons for recalls include undeclared allergens, microbial contamination, foreign matter, chemical contamination, labelling errors and packaging faults. Source: FSANZ Food Industry Recall Protocol (May 2023).
A recall, step by step
The sequence set out in the FSANZ protocol. Your written plan should name who does each step.
Stop and hold
Stop dispatch of the affected product, quarantine stock on site, and identify the batches and dates involved.
Call your state agency
Phone your home state’s food enforcement agency. They’ll help you decide whether it’s a recall and at what level. If you’re licensed by Safe Food Victoria, contact them too.
Contact the FSANZ Food Recall Coordinator
FSANZ coordinates the recall nationally and notifies the ACCC on your behalf, meeting the two-day requirement.
Tell your customers
Notify every customer who received the product. Retailers will have their own recall procedures in your supplier agreement. For a consumer recall, you’ll also need public notices.
Recover and account for stock
Track how much was made, sold, recovered and destroyed. This is where traceability records earn their keep.
Interim report
Send FSANZ an interim report showing customers were notified and what you’ve done.
Final report
Stock accountability, disposal, root cause and the corrective action that stops it happening again.
What a recall plan should cover
- How you decide: who assesses the risk and who has authority to start a recall.
- Your recall team: names, roles, and after-hours phone numbers, kept current.
- Who you notify: your state agency, FSANZ, your customers, and how you’d reach consumers.
- Traceability: how you link raw materials to batches, and batches to customers.
- Retrieval and disposal: how stock comes back, where it’s held, and how it’s destroyed and recorded.
- Corrective action and reporting: root cause, fixes, and the interim and final reports.
FSANZ publishes a free recall plan template and report templates. Start there rather than writing from scratch.
Test your plan once a year
FSANZ recommends a mock recall every year. If you’re certified to SQF, BRCGS or FSSC 22000, you’ll test traceability and recall at least yearly anyway, and the auditor will ask for the results.
- Pick a real finished batch from a few weeks ago.
- Trace it back to every raw material lot and supplier, and forward to every customer.
- Do a mass balance: product made versus product dispatched, in stock and wasted.
- Time it, check your contact list actually works, and record what slowed you down.
- Raise corrective actions for every gap, and close them.
Traceability records you can find in minutes
A recall is only as fast as your records. EthicalHub keeps supplier approvals, certificates, delivery logs and corrective actions in one place, so a trace starts with a search, not a filing cabinet. Your mock recall results go straight into your audit pack.
How quickly could you trace a batch?
The free assessment and 59-point checklist cover traceability and recall alongside the rest of your audit records.
Food recalls: common questions
Who needs a food recall plan in Australia?
Who do I notify about a food recall?
What is the difference between a recall and a withdrawal?
How often should I test my recall plan?
Trace any batch, fast.
See how EthicalHub keeps the records a recall depends on.