Have you noticed how recall notifications have soared recently? From listeria outbreaks to undeclared allergens and even faulty condoms, it seems barely a week goes by without Aussie news headlines warning about another major recall.
Fact: Recalls are a risk for every manufacturer.
Chances are the risk of a recall or withdrawal weighs on your mind on a pretty regular basis. And who can blame that? After all, recalls affect your supply chain, your reputation, your relationships with your customers – and your bottom line.
The question is: what do you do when the unthinkable happens? What do you do when a batch of faulty products makes it out the factory door and onto retailer shelves?
Here are facts about “product recalls” and “product withdrawals” that every Australian manufacturer needs to know:
What’s difference between a product recall or withdrawal? (And why does it matter?)
The difference between a recall and withdrawal is more important than you might think. If you issue a recall notification but it’s actually a product withdrawal, you could find yourself paying for unnecessary media notices and other recall costs. On the flipside, if it’s a recall and you treat it as a withdrawal, the ramifications could extend to legal action and penalties.
Knowing the difference between a recall and withdrawal means you can handle the situation quickly and correctly, saving you valuable time, money and headaches.
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:
- A consumer recall is the most extensive recall, recovering the item from all points in the production and distribution chain, including from consumers. For example, in 2017, Rafferty’s Garden’s popular baby food “Happy Tummies Vegetable Risotto” was recalled due to fears that glass may have ended up in the packets. In this case, consumers were advised not to eat the product but to return it to the place of purchase for a full cash refund.
- A trade recall recovers food that has not been sold directly to consumers, i.e. from distribution centres, wholesalers, hospitals, restaurants or other catering establishments.
A product withdrawal is different from a recall. It involves removing the product 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 be a recall as it poses a risk to consumers.
Who recalls food in Australia?
In Australia, recalls come from the food manufacturer or are ordered by Australian states and territories. They cannot be forced or ordered by anyone else – not even Food Standards Australia New Zealand (FSANZ). The food business must first notify their customers and local food enforcement agency that a recall is required. The enforcement agencies then confirm that the recall is needed, working with the business to enact the recall and check it is done correctly. FSANZ also helps coordinate the recall with the relevant jurisdiction and food manufacturer.
For other items, such as outdoor products, kitchenware, furniture and items for babies and children, the Australian Competition and Consumer Commission (ACCC) has the sole responsibility for recalling products. In fact, the ACCC recently launchedthe new Product Safety Australia website to make it easier for consumers to check their goods are safe.
What are the main causes for a food product recall or withdrawal in Australia?
The latest statistics show that, between1 January 2008 and 31 December 2017, FSANZ co-ordinated 626 recalls. Of these, around 37% were due to undeclared allergens, 28% for microbial contamination and 17% were due to foreign matter, with the most common types being metal, plastic and glass.
One third of all undeclared allergen recalls during this period were for processed foods. In August 2018, supermarket chain Aldi has been forced to recall its popular pancake mix after discovering it contained an undeclared egg allergen. Aldi announced that consumers with an egg allergy or intolerance may have a reaction if they consume the mix.
Microbial contaminations have hit the headlines too, recently. Earlier in 2018, a listeria outbreak linked to rockmelons claimed the lives of six people. To make matters worse, it was revealed that the affected product has been exported to nine countries. Singapore has even announced a ban on all Australian rockmelons, while, here in Australia, the rockmelon industry has moved to combat food-borne illness risks on farms with new measures.
What are the legal requirements for a recall or withdrawal?
First things first: all food manufacturers, importers and wholesale suppliers must have a written food recall plan, which covers procedures, records and staff responsibilities. (FSANZ provides a useful Food Recall Plan Template).
In the event of a recall, companies are legally required to communicate recall information to state and territory government agencies and industry groups. The local food enforcement authority will confirm what level the recall should be (consumer or trade). As soon as a recall action is decided, the manufacturer must call FSANZ and provide them with information about the recall. (Check out FSANZ’s handy timeline of what to do and when.)
The business is also responsible for ensuring that the public is notified of the recall; this has become easier with social media. For example, when Rafferty’s Garden announced its risotto recall on Facebook, the post was shared more than 7,400 times and garnered more than 3,000 comments, with people tagging friends and family who may have purchased the product. Many retailers also have dedicated webpages for recall announcements – such as this one for Aldi.
However, when a company decides to voluntarily withdraw a product from the market, there are no such legal requirements. Withdrawals don’t need to be notified to authorities. That said, the company should still conduct the withdrawal with the same level of consideration, efficiency and care as if it were a mandatory recall.
Should manufacturers have different written procedures for a recall or 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 – it’s a legal requirement. Many major retailers also 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. For example, in Australia Woolworths outlines a process that suppliers must follow in the event of a recall or withdrawal.
How can different technology help avoid and manage a recall or withdrawal?
Advanced inspection systems will check, detect and respond quickly to any problems, helping avoid both recalls and withdrawals in the production line. This includes vision inspection, checkweigh, metal detection and x-ray inspection technologies. (You can find more information on three essential inspection technologies for manufacturing here.) For example, machine vision systems use camera and computer technologies to automatically inspect appearance, character and defects, 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 part is that 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.
What other resources are available to help manage recalls?
GS1 Australia (the same not-for-profit organisation that manages barcodes) has also designed a system to help manufacturers manage recalls and withdrawals. GS1 Australia’s Recall (previously called Recallnet) 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. Some retailers, including Woolworths, identify GS1 Recall as one of their preferred methods for suppliers to submit recall or withdrawal information.
You can also use Recall to conduct mock recalls for HACCP/standards certification and audits; the portal has recently been re-certified as an effective and suitable service for businesses that operate a HACCP based Food Safety Programme.
If you’re unsure whether to recall or withdraw your product, we recommend contacting government authorities in your local 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.
Interested in traceability through product labelling & coding? Or through compliant shipper coding & labelling? Or through compliant pallet labelling? You can find all that and more in Matthews’ large resource library. It has all sorts of information about business and technology and processes – and it’s all free to download.