Let’s say the unthinkable has happened: you’ve discovered a problem in your manufacturing line that affects a whole batch of products. Worse still, a full supply has already left the plant and hit the store shelves. What now? Is it a “recall” or a “withdrawal”? Does it matter? Yes, it really does — and this is why: if you issue a recall notification but it’s actually a product withdrawal, you could find yourself paying out for media notices and other recall costs for no reason. On the other hand, if it’s a recall and you treat it as a withdrawal, the ramifications could extend to legal action. Knowing the difference between a recall and withdrawal means you can handle the situation quickly and correctly, saving you valuable time, money and stress. Here’s a guide we’ve put together on the key differences between a “product recall” and a “product withdrawal” that every manufacturer and brand owner should know.
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Q1. What is the difference between a product recall and product withdrawal?
A product recall removes products from distribution, sale or consumption that present a significant health or safety threat because of a product defect or contamination. This can either be at trade or consumer level. Recalling food products can happen because of a report or complaint from manufacturers, wholesalers, retailers, government or consumers. It can also occur after the business itself has run internal tests and audits. A product withdrawal, on the other hand, is where product is removed from the supply chain — but not for health and safety reasons. For example, if something has been labelled with the wrong weight, the manufacturer may want to withdraw it. But if that same product was labelled with the wrong ingredients and allergens, this would then be a recall. Manufacturers sometimes also withdraw products as a precaution, waiting further investigation of a potential public health risk. If that risk is established, the food must be recalled.
Q2. Is a ‘voluntary product recall’ the same as a ‘product withdrawal’?
These are similar in that they’re both voluntary. Where they differ is that a recall typically involves a manufacturer removing a defective or unsafe product from the market completely — which includes calling out to customers to return their unsafe products. With a withdrawal, a company may choose to simply stop selling a product for a time — even if it is already in the market and being used by consumers. It’s worth noting that Food Standards Australia New Zealand (FSANZ) no longer uses the term “voluntary recall” because it created confusion for retailers and consumers. For instance, some thought it meant it was voluntary for them to take action in relation to recalled food.
Q3. Which industries conduct recalls and withdrawals?
Both recalls and withdrawals can relate to any product — food, beverage, toys, right up to cars, anything. Withdrawals however, are mostly associated with food and beverages.
Q4. What are the main causes for product recalls and withdrawals in Australia?
According to FSANZ, there are about five recalls a month in Australia. Around a third are due to microbiological issues, a third from labelling issues and the final third due to physical or chemical contamination. As many as 90% of labelling recalls are due to undeclared allergens — including peanuts, gluten, milk and eggs. Where the issue is physical contamination, the foreign matter usually involves metal, plastics and glass.
Q5. What are the legal requirements for recalls and withdrawals?
When it comes to recalls, companies are legally required to communicate recall information to state and territory government agencies and industry groups. The business is also responsible for ensuring that the public is notified of the recall. FSANZ helps food businesses to recall unsafe food in Australia and should be notified as soon as recall action is decided. In contrast, when a company decides to voluntarily withdraw a product from the market, there are no such legal requirements and withdrawals don’t need to be notified to authorities. That said, the company should still conduct the voluntary recall with the same level of efficiency and care as if it were a mandatory recall.
Q6. Should manufacturers have different written procedures for a recall and withdrawal?
Yes, that’s recommended. No matter how reliable your manufacturing processes are, you need a formal recall plan to ensure your customers’ safety and your brand’s reputation. Many major retailers stipulate that their suppliers must have separate written procedures identifying the difference between a product withdrawal and a product recall and how they both should be handled.
Q7. Do manufacturers need to invest in different technology to avoid and manage recalls and withdrawals?
No – advanced inspection systems that will check, detect and respond quickly to any problems can help avoid both recalls and withdrawals in the production line. This includes vision inspection, checkweigh, metal detection and x-ray inspection technologies. For example, using camera and computer technologies, machine vision systems automatically conduct appearance, character and defect inspections, without the need for human intervention. This vastly decreases the risk of an unfit or faulty product leaving your plant. This technology can check labels, barcodes, use-by dates, product formation and much more. The best thing is the system immediately notifies you of a problem, so you can fix it before the whole batch is produced and definitely before the product is shipped. (See here for five ways the vision industry decreased product recalls & packaging errors, and nine ways label inspection systems ensure zero-defect labels.)
If the unthinkable happens and you’re faced with a product recall or withdrawal, GS1 Australia has also designed a system to help manage the situation. GS1 Australia Recall is a web-based portal designed to enable faster, more complete pull back of unsafe or unsuitable products from the supply chain. It does this by simplifying and automating the exchange of information between suppliers, distributors and retailers as well as government agencies such as FSANZ and the ACCC. If you’re unsure whether to recall or withdraw your product, we recommend contacting government authorities in your home state for advice. For more on recalls and withdrawals, download the Matthews white paper, “Avoiding Recalls”. This article also explains how traceability aids in recalls and withdrawals.