Guide
Food traceability, withdrawal, and recall
Maintain food traceability records using the one step back, one step forward principle, and follow the correct procedures if you need to withdraw or recall unsafe food.
If you sell, supply, or distribute food, you must be able to trace where your ingredients came from and where your products went. This is a legal requirement under Regulation (EC) No 178/2002 (retained as assimilated law), known as the General Food Law.
Traceability is not just a record-keeping exercise. If a food safety problem arises, your traceability records determine how quickly you can identify affected products, remove them from sale, and notify the authorities. A business that cannot trace its products risks enforcement action, unlimited fines, and up to two years' imprisonment.
This guide covers what traceability records you must keep, how long to retain them, and the exact steps to follow if you need to withdraw or recall a product.
- Legal basis
- Regulation (EC) No 178/2002, Article 18 (assimilated law)
- Applies to
- All food business operators (manufacturers, wholesalers, retailers, caterers)
- Regulator
- Food Standards Agency (FSA) / local authority Environmental Health
- Maximum penalty
- Unlimited fine and/or up to 2 years imprisonment
The one step back, one step forward principle
You must be able to identify two things at all times:
- One step back: who supplied each ingredient or product to you
- One step forward: which businesses you supplied your products to
You do not need to trace every movement through the entire supply chain. Each business in the chain maintains its own one-step records, which authorities can piece together during an investigation.
Exception: You do not need to record the identity of individual consumers. If you sell direct to the public (in a shop, restaurant, or online), your 'one step forward' obligation stops at retail sale.
If your business both sources ingredients and supplies to other businesses, you should be able to link incoming batches to outgoing products. This is not strictly required by law, but it makes withdrawal and recall far faster. Without internal batch linking, you may have to withdraw entire product lines rather than specific batches.
Withdrawal versus recall: know the difference
Withdrawal means removing a product from the supply chain before it reaches consumers. You withdraw a product from sale, from distribution, or from display. Withdrawal is the first step in any food safety incident.
Recall means retrieving a product that has already reached consumers. A recall is more serious than a withdrawal because consumers may have already eaten the product, and you must take active steps to contact them or warn the public.
In practice, many incidents begin as a withdrawal. If you then discover that affected products have already been sold to consumers, the withdrawal escalates to a recall.
When to notify the authorities
You must notify the FSA and your local authority if:
- You have reason to believe food you placed on the market is unsafe or does not comply with food safety requirements
- The product has left your immediate control (reached other businesses or consumers)
- An undeclared allergen is present in a product
If the product has not left your premises, you do not need to notify the authorities, but you should still record the incident internally and take corrective action.
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1. Stop supply immediately
As soon as you identify a food safety problem, stop selling or distributing the affected product. Quarantine remaining stock and clearly label it as 'do not sell'. If the product is on display, remove it.
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2. Identify the scope of the problem
Use your traceability records to determine which batches are affected, how much product was produced, and where it was sent. Check whether any affected product has reached consumers. If you cannot identify specific batches, treat all production of that product as potentially affected.
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3. Notify the FSA and your local authority
Contact the FSA incident team and your local authority Environmental Health. In England, Wales, and Northern Ireland, report to the FSA via their online incident reporting form or call the FSA incident line. Provide details of the product, the hazard, batch numbers, quantities, and where the product was distributed.
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4. Notify businesses you supplied
Contact all businesses you supplied the affected product to. Instruct them to withdraw the product from sale and return or destroy it. Provide clear identification: product name, batch or lot numbers, best before or use-by dates.
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5. If product has reached consumers, initiate recall
If affected product has been sold to the public, issue a product recall notice. The FSA will help coordinate public communication, including publishing an allergy alert or food alert on the FSA website and social media channels. You may also need to issue point-of-sale notices and contact consumers directly if you hold their details.
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6. Cooperate with the investigation
Provide all information requested by the FSA and local authority. This includes traceability records, production records, HACCP documentation, and details of corrective actions. Keep records of all communications and actions taken during the incident.
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7. Take corrective action and review
Investigate the root cause of the problem. Update your HACCP plan and food safety procedures to prevent recurrence. Document all changes made. If the incident involved an allergen, review your allergen management system, ingredient specifications, and labelling.
FSA allergy alerts
If a product contains an undeclared allergen or incorrect allergen information, this almost always requires a product recall and publication of an allergy alert. Allergen incidents are the most common reason for food recalls in the UK.
What if you are contacted about someone else's product
If you receive a withdrawal or recall notification from a supplier or the FSA about a product you stock or have sold:
- Remove the product from sale immediately
- Check your records for the affected batch numbers
- If you supplied the product to other businesses, notify them
- Follow any instructions from the FSA or your supplier about customer notification or product return
- Keep records of your response, including quantities removed and disposal method
Preparing for incidents before they happen
Do not wait for a food safety incident to test your traceability system. The FSA recommends conducting regular traceability exercises to ensure your records are accurate and you can identify affected products quickly.
A basic traceability test: Pick a product at random. Can you identify every ingredient supplier and every business customer for that product within 4 hours? If not, your system needs improvement.
Your food incident response plan should include:
- Named person responsible for coordinating withdrawal or recall
- FSA incident reporting contact details (kept accessible, not locked in an office)
- Template communication for notifying customers
- Procedure for quarantining affected stock
- Contact details for your local authority Environmental Health team