How-To Guide

How to Manage Food Recalls in Your UK Food Business

Step-by-step guide to handling food recalls and withdrawals. Covers traceability under EC 178/2002, FSA notification requirements, product removal procedures, and post-recall review.

Estimated time: 3 hours

Food recalls and withdrawals are among the most high-pressure situations any food business can face. Under EC Regulation 178/2002 (retained in UK law as General Food Law), every food business operator must be able to trace all food products one step back to their supplier and one step forward to their customer. When a product is found to be unsafe or non-compliant, the Food Standards Agency coordinates the recall process nationally, but the responsibility for swift action falls directly on each business in the supply chain.

The consequences of a poorly managed recall go well beyond the immediate safety risk. Businesses that fail to withdraw affected products promptly can face enforcement action from their local authority, unlimited fines under the Food Safety Act 1990, and criminal prosecution in serious cases. Even where no prosecution occurs, reputational damage from a mishandled recall can be devastating, particularly in an era where FSA recall notices are published online and shared widely on social media.

This guide walks you through establishing a recall procedure before you need one, setting up the traceability systems that make rapid response possible, and executing a recall effectively when the situation demands it.

Step by Step

6 steps to complete

Establish a documented recall procedure

Create a written food recall and withdrawal procedure before you ever need to use it. Your procedure should define the roles and responsibilities of key staff, the decision-making process for determining whether a product requires withdrawal (removal from sale) or full recall (retrieval from consumers), contact details for your local authority environmental health team and the FSA incident reporting line, communication templates for notifying customers and suppliers, and a clear step-by-step action plan. Assign a recall coordinator who has the authority to initiate a withdrawal immediately without waiting for senior management approval. In a genuine food safety emergency, delays cost lives.

Set up a robust traceability system

Under EC 178/2002, you must be able to identify every supplier of every ingredient or product you use, and every business or customer you have supplied. At minimum, record the product name and description, supplier details and contact information, batch or lot numbers, date of receipt, quantity received, and use-by or best-before dates. For products you supply onwards, record who you supplied, the date, and the quantity. Your traceability records must allow you to identify all affected products within four hours of a recall being initiated. If your current system cannot achieve this, it is not fit for purpose.

Identify affected products quickly

When you receive a recall notification from a supplier, the FSA, or your local authority, immediately cross-reference the affected batch numbers, date codes, or product descriptions against your stock records and traceability logs. Check all storage areas: dry stores, fridges, freezers, prep areas, and any satellite locations. Identify whether any affected product has already been used in dishes served to customers, incorporated into other products, or supplied to other businesses. Speed is critical here. The FSA categorises food incidents by risk level, and a Category 1 incident (where food poses a serious risk to health) requires action within hours, not days.

Notify authorities and customers

Report the incident to your local authority environmental health team immediately. If you are a food manufacturer, distributor, or retailer and the product has reached consumers, you must also notify the FSA directly via their online incident reporting system. For products supplied to other businesses, contact each customer business individually with full details of the affected products, batch numbers, and the reason for the recall. If you need to issue a public recall notice (because affected products have reached consumers and cannot be traced individually), the FSA provides standard templates and guidance. Include clear instructions on what consumers should do: return the product, dispose of it, or seek medical attention if they have consumed it.

Remove and segregate affected products

Physically remove all identified affected products from sale, storage, and use immediately. Do not simply move them to a different shelf or mark them as not for sale. Segregate recalled products in a clearly marked, separate area that all staff understand is quarantine. Label the segregated products with the reason for recall, the date of quarantine, and a clear "DO NOT USE" instruction. Do not dispose of recalled products until you have confirmed with your local authority or the FSA whether they need to be retained as evidence. Maintain a written record of every product removed, including the quantity, batch number, location it was found, and the date and time of removal.

Document the recall and conduct a post-incident review

Keep a complete written record of the entire recall process: the initial notification, every action taken, all communications sent, the products identified and removed, the timeline of events, and the final outcome. Once the immediate crisis has passed, conduct a thorough post-incident review. Assess how quickly you were able to identify affected products (did your traceability system perform?), whether your recall procedure worked as planned, what communication challenges arose, and what improvements are needed. Update your recall procedure based on the lessons learned. The FSA and your local authority may request your recall documentation as evidence of due diligence, and thorough records demonstrate responsible management.

Expert Advice

Tips for success

Subscribe to FSA food alerts and allergy alerts at food.gov.uk/news-alerts so you receive recall notifications as soon as they are published, rather than relying on suppliers to contact you.

Run a mock recall exercise at least once a year. Pick a random product from your stock, and test whether your team can trace every batch, identify all affected locations, and complete the removal process within your target timeframe.

Store supplier contact details (including out-of-hours emergency numbers) in a readily accessible location so you can reach them immediately when a recall is initiated, even outside normal business hours.

Photograph your quarantine area and segregated products during a recall. Visual evidence of your response is powerful documentation if you later need to demonstrate due diligence to an inspector or in legal proceedings.

Build recall awareness into your staff induction process. Every team member should know what a food recall is, where the recall procedure is kept, and who the recall coordinator is.

Watch Out

Common mistakes to avoid

Waiting for a supplier to confirm before taking action

If you have reasonable grounds to believe a product is unsafe, act first and confirm later. Under the Food Safety Act 1990, you have a duty to remove unsafe food from sale immediately. Delaying while you wait for a supplier to respond could expose customers to harm and expose your business to prosecution.

Relying on memory rather than documented traceability records

Verbal assurances that you "know where everything came from" are worthless during a recall. EC 178/2002 requires documented traceability. If you cannot produce written records showing the origin, batch number, and distribution of a product, your traceability system is non-compliant and your recall will be slow and incomplete.

Disposing of recalled products before authorities confirm it is appropriate

Recalled products may be needed as evidence for investigation, sampling, or legal proceedings. Segregate and quarantine affected stock, but do not destroy it until your local authority or the FSA has confirmed that disposal is appropriate. Premature disposal can obstruct an investigation.

Not updating the recall procedure after an incident

Every recall reveals gaps in your process. If you complete a recall and do not update your procedure based on what you learned, you are likely to repeat the same mistakes. Schedule a formal post-incident review within two weeks of the recall closing and document all changes made.

FAQ

Frequently asked questions

What is the difference between a food withdrawal and a food recall?

A withdrawal removes a product from the supply chain (from shops, wholesalers, or your own stock) before it reaches the consumer. A recall goes further: it retrieves products that have already been sold to consumers. Withdrawals are typically used for quality or labelling issues, while recalls are triggered when there is a direct risk to consumer health. The FSA may require either action depending on the severity of the issue.

How quickly do I need to act on a food recall?

There is no single legal deadline, but the expectation is immediate action. The FSA categorises incidents by risk level. Category 1 incidents (serious risk to health) require you to act within hours. Even for lower-risk issues, any delay in removing affected products from sale increases your legal exposure. Your traceability system should allow you to identify all affected stock within four hours as a practical benchmark.

Am I legally required to have a recall procedure?

EC 178/2002 (General Food Law) requires food business operators to have procedures in place to withdraw food from the market where it does not satisfy food safety requirements, and to notify the competent authorities accordingly. While the regulation does not prescribe the exact format of your procedure, having a documented, rehearsed recall plan is the only practical way to meet this obligation. Inspectors will check for it.

Do I need to keep traceability records for every single ingredient?

Yes. EC 178/2002 requires traceability for all food, feed, and food-producing animals at all stages of production, processing, and distribution. In practice, this means every ingredient, product, and raw material you receive must be traceable one step back (to the supplier) and one step forward (to the business or customer you supplied). The records must include the name and address of the supplier, the nature and quantity of the products, and the date of the transaction.

What happens if the FSA issues a recall for a product I stock?

When the FSA issues a product recall notice, it will include the product name, brand, batch codes, use-by dates, and the reason for the recall. You must immediately check your stock for the affected products, remove any you find from sale, segregate them securely, and follow the instructions in the recall notice (which may include contacting consumers, displaying point-of-sale notices, or returning stock to the supplier). You should also notify your local authority if you have sold affected products to consumers.

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