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When to alert certification body about a recall?

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Karpenter1

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Posted 01 February 2021 - 10:17 AM

Hello all, when performing a recall you need to alert your certification body, but when is a recall an actual recall? We have a product with a problem with pesticide. The product currently in stock at our customers (Industry not consumers or retail) needs to be blocked and must be send back to us or destroyed. Is this already a recall or is this only a recall when the final consumer must be informed?



pHruit

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Posted 01 February 2021 - 10:50 AM

You've posted this in the BRC section, so that's the standard I presume is of relevance for you?

BRC defines this in the Glossary in Appendix 9:

 

Product recall - Any measures aimed at achieving the return of an unfit product from customers and final consumers.

Product withdrawal - Any measures aimed at achieving the return of out-of-specification or unfit product from business customers, but not from final consumers. 

 

To me it sounds very much like your situation is therefore a withdrawal, rather than a recall.



BrianMatthews

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Posted 01 February 2021 - 02:13 PM

It will be classed as a withdrawal not a recall if it has not reached consumers or retail. 

 

To answer the question: For BRC see clause - 3.11.4,  In the event of a significant food safety incident, you must notify your certification body within 3 working days.

 

this should be out-lined in your recall/withdrawal procedure.

 

 



Charles.C

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Posted 01 February 2021 - 03:11 PM

It will be classed as a withdrawal not a recall if it has not reached consumers or retail. 

 

To answer the question: For BRC see clause - 3.11.4,  In the event of a significant food safety incident, you must notify your certification body within 3 working days.

 

this should be out-lined in your recall/withdrawal procedure.

 

Hi Brian,

 

Thks for input.

 

Does "retail" exclude "business customers" ? (cf Post 2). Possibly just UK-ambiguous semantics.

 

PS - this appears to be the UK legal situation as of 2019 (ie pre-Brexit)(I note OP is in USA??) -

 

Attached File  food withdrawal-recall.png   203.15KB   1 downloads

Attached File  FSA,2019,food-traceability-withdrawals-and-recalls-guidance.pdf   1.1MB   28 downloads


Edited by Charles.C, 01 February 2021 - 04:00 PM.
edited

Kind Regards,

 

Charles.C


Leila Burin

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Posted 02 February 2021 - 03:55 PM

Hello,

you shall advise within 3 days that you KNOW of the situation, NOT when the actual logistics starts,

best regards,

Leila





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