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Recall Procedures For Food Distributor/Broker

Recall Broker Distributor Australia

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Posted 22 September 2017 - 05:44 AM

Hi Everyone,


I am currently trying to develop a Recall plan for our company which is a distributor/broker of food ingredients. We import goods from around the world and distribute them within Australia and New Zealand. All our goods are sold as is, under no circumstance would they be opened.


Being the middle man in the supply chain can be difficult as we need to support the strict safety regulations of our large suppliers and customers but understanding our responsibilities and requirements can be a very grey area. Most food recall plans have a focus from a food manufacturing perspective, so when we are asked to create a recall plan or be HACCP certified, things can easily become very over-complicated. We as food brokers are a vital link in traceability and efficient food recalls however there are not many resources that detail our responsibility and requirements. 


Are we allowed to initiate a food recall? or is this the authority of our supplier/manufacturer? What is our role/responsibility in a food recall? 


If anyone has any experience in this area or good resources please link them below, I would greatly appreciate it.


Thanks in advance.


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Posted 22 September 2017 - 01:42 PM

Hi Zowie

To initiate a recall there must be a reason. From what you have said in your post if you only distribute goods that are prepackaged the only way you can initiate a recall is if the products at storage were adulterated (Temperature abuse, pest presence, etc.). Even at that point you might not have purchased the total batch so the recall will be limited (Which makes it a bit harder to issue a recall in my opinion). 

The only other way I think that you will be involved in a recall is if your suppliers inform you of a product that did not meet specifications and it entered commerce. 

In general a recall is required when the product is being considered adulterated. If the product was adulterated at your facility then you will have to notify your customers of the issue, and issue a recall.

Hope the above helps


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Posted 23 September 2017 - 02:56 AM

Hi zowie,


If you are directly procuring from manufacturer, you may assess the traceability / recall system of your manufacturer through questionnaire. At times you shall test your manufacturer to provide traceability summary for any particular lot code you chose. 


If you import your goods through a middle agent, you shall ask your middle agent to provide traceability details of their manufacturer.




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Posted 02 October 2017 - 01:19 AM

As the other posters have said, a recall is required if you become aware of a problem with your product that could make it dangerous to consumers.  For example, if your supplier informed you of a food safety problem with one of their products, you should initiate a recall to remove the food from the marketplace.  If someone else finds a problem with one of your products, then the authorities may contact you to ask you to conduct a recall. 


For Australia, FSANZ (Food Standards Australia and New Zealand) provides excellent guidance and help. FSANZ has a national recall coordinator who you can telephone any time (24/7).  If you think you might need to initiate a recall they will help you decide if a recall is necessary and how to get started.  They liaise with you every step of the way.  


There is lots of very good information on this page:  http://www.foodstand...es/default.aspx


As for recall plans, you can download a template from that web page.  Your responsibilities and the actions you will need to take in a recall are the same as for a food manufacturer so the template on the FSANZ page is perfectly suitable for distributors and brokers.  The sections about identifying food safety hazards and actions taken to mitigate food safety risks would be completed with the help of your suppliers, or customer/s - depending on who identified the problem -  and in consultation with the food safety authority in your home state.


Your responsibilities in a recall vary, depending on who initiated the recall and the level of the recall (trade level or consumer level), but essentially your job will be to (help) make sure that no affected product reaches a consumer.  The aim is to ensure that all affected product is found, isolated, completely removed from the supply chain, destroyed securely and that these actions are properly documented. 


Karen Constable


Food Fraud Prevention (VACCP) Programs | Food Fraud Training |

Consulting | Advisory | Compliance

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Posted 21 November 2017 - 12:20 AM

Hi Zowie, 


As Karen mentioned, FSANZ is very helpful in the event of a food recall and they provide a basic outline of a recall plan. Unfortunately that plan won't give much guidance on how to conduct a risk assessment, developing a strategy or creating an effective communication plan but as you said, you want to get it simple. I am assuming from your description that you are supplying other food manufacturers, not a retail product?


I have a few B2B ingredient suppliers as clients and sounds like from your description that you are not the brand owner for the finished product. Apart from anything you can glean through a physical inspection as it passes through your DC and your transport provider, it lis unlikely that you will be the one to first identify a problem. It will either be your suppliers letting you know or your customers identifying a problem as they use your ingredient in their production, or worse case it gets through the production system and retailer and it is identified by a consumer. 


As you are not the brand owner at retail level, it is unlikely that you will be the organisation conducting any consumer level actions. That is generally the retailer and/or final manufacturer/brand owner, although there have been a few instances of ingredient suppliers conducting a consumer level recall. If the final product(s) have not got into the consumer market, you may need to conduct a trade recall (if a safety hazard exists) or withdrawal (quality problem, no safety hazard).


That doesn't lessen your role in the process. If for example you supply to brand owner X who identifies the problem, but you also supply to others, you have a responsibility to all your customers to notify and work with them, have an investigation completed generally by your supplier but you may also need to have local testing done depending on the nature of the problem. Your customers will want to know as much information as possible about the problem so they can conduct their own assessment. For example if the problem is some kind of contaminant, your customers processing may reduce the risk through a filtering process or a cooking process for example. You probably won't have a good understanding of those processes so your role is to get as much information to them as you can as fast as you can so your customer can make that assessment. 


In addition, you may need to deal with product returned from your customer depending on the circumstances. It the final product is with retailers, they often just dump it unfortunately. Also the costs associated with the recall may come back to you so your contractual relationships with suppliers are really important and you may need to look at recall insurance to cover costs that you may not be able to get back. Covering the product costs is only part of it. If a recall needs to be conducted, there may be store costs, destruction costs, loss of profit, advertising ....


The other thing to remember is your reputation as a responsible supplier - and therefore your ongoing contracts with your key customers will depend on your approach to an incident when it happens. You need to make sure you have appropriate systems and processes in place. I've had a few calls in the past from B2B suppliers whose business depends on a key contract and that customer has told them to take their product back. When we dig into the incident, the problem almost always gets back to to how the supplier initially managed the incident not the customer being unreasonable!


If you haven't already, I would also recommend registering with GS1 Australia's recall system. It is a fast way to get notifications to all your customers, regulators and retailers quickly. 


Let me know if you need any further information. I would be happy to have a chat with you about your business and help you identify what type of recall program you need.


Regards, Steve


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Posted 19 March 2018 - 08:41 AM

Hi....  If you have any kind of help related to food distributors you can contact us on Al Maya Distribution.

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