Gather information, understand the problem

Gather information about the problem. Understanding the problem will help you to identify the affected products and batches. If there are delays in understanding the problem, you should inform your verifier or New Zealand Food Safety (see Step 2).

Ask questions

To help you understand the problem, ask questions. We've listed some questions you might ask, depending on the problem you've identified.

Undeclared allergen

• What kind of allergen is it?
• What caused the problem? Was it incorrect packaging or labelling, incorrect ingredients, incorrectly labelled ingredients, cross-contamination?
• How much allergenic protein is present in each serving?
• Do affected product labels include a ‘free-from’ or similar claim?

Note that cross-contamination can occur via changes to production scheduling, rework, or inadequate cleaning, for example.

Foreign matter

• What kind of foreign matter is it?
• What is the size and shape of the foreign matter?
• How many reports have been received?
• Was a sieve, x-ray, or other control measure present, and if it didn’t work, how long has it been malfunctioning?

Microbiological hazard

• What kind of microorganism is it?
• Could the microorganism (or any toxin it produces) make someone sick, or is there a regulatory limit in your product?
• Where could the microorganism have come from (was it ingredients, raw materials, people, equipment, environment, water, air)?
• When did the microorganism get into the product, have other products also been exposed?
• Was a heating step or other control measure present, and if it didn’t work, how long has it been malfunctioning?

Additional sampling and testing of products or environment may help determine the source and extent of the problem.

Chemical hazard

• What kind of chemical is it, is it hazardous?
• How much of it is present in your food, how much of your food would typically be eaten in one sitting?
• Where could the chemical have come from (was it ingredients, raw materials, equipment, cleaning products, environment, water)?
• When did the chemical get into the product?

Something else?

Do your own investigation. Check with your verifier or New Zealand Food Safety.

Identify which products and batches are (or might be) affected

Use your records (for example, production, inventory, sales, and distribution), lab results (if any), and information you have learned about the problem’s source, to identify which products and batches are affected, or might be affected. Consider if products or batches produced before, or after, might be affected.

Example of how affected product information can be set out [XLSX, 29 KB]

Identify where the affected products are

Use your records to determine if affected products and batches have left your premises.

If affected products have left your premises, find out where they are, and make a list of impacted businesses (sometimes called a distribution list).

Example of how a distribution list can be set out [XLSX, 27 KB]

If products have been exported, use your records to find out the destination country, date of departure, certificate numbers (if any), and if the products have been cleared into the country.

Put affected products in your control on hold

Put potentially affected products (sometimes called suspect products) on hold. This means separating them (such as physically moving them into a separate space), identifying them clearly (for example, by labelling them with the word "hold"), and letting your staff know not to move them.

Inform your verifier

A problem may indicate a breach of requirements or a critical non-compliance. Food, animal products, and wine businesses with a plan or programme are required to inform their verifier or New Zealand Food Safety of a breach or a critical non-compliance.

Tell your verifier about the problem. They may be able to help. If you don't have a verifier, tell New Zealand Food Safety:

• freephone 0800 00 83 33
• email Food.Recalls@mpi.govt.nz

If you operate a Wine Standards Management Plan, tell both your verifier and New Zealand Food Safety.

You'll need to tell us or your verifier:

• your name and phone number
• the name of your business
• the product name and its brand name
• a summary of the problem.

You will also need these details later for your risk assessment.

Food recall risk assessment form [DOCX, 741 KB]

Extra requirement for wine and animal products exporters

If there is a problem with exported wine or animal products (for human consumption), exporters are required to inform New Zealand Food Safety as soon as possible, and in any case no later than 24 hours after the event or first knowledge of the event.

Find out more about export non-conformances

Optional step: Inform logistics providers, customers, suppliers, and brand owners

You may want to tell any logistics providers (sometimes called third party logistics or 3PL), retailers, or other businesses that have received your product to also put them on hold as a precaution (sometimes called a precautionary hold). Doing this early can reduce the size of a recall later.

If the problem relates to an ingredient, tell your ingredient supplier so they can inform their other customers.

If you manufacture for other brands, tell your brand-owners about the problem early. If multiple brand-owners are involved, consider communicating to each one separately to maintain confidentiality.

If manufacturers don’t share relevant information with brand owners in a timely way, New Zealand Food Safety has regulatory powers to share information as needed.

Optional step: Begin filling in an online tool like ProductRecallNZ

If you have access to an online tool for informing businesses and New Zealand Food Safety about your recall, now is a good time to begin filling in the relevant information.

Carry out a risk assessment

Carry out an assessment of the risk to consumers. This includes documenting:

• the names of the affected products
• the type of food involved, and the intended consumer
• what batches are affected, including any "use-by" or "best-before" dates
• the time range for the issue
• where the affected products are at the current time
• a description of the hazard
• your recall decision, and the reason behind it.

New Zealand Food Safety recommends you use the food recall risk assessment form to document your risk assessment. If you don’t have all the information to complete this form, just fill in what information you have collected so far.

Food recall risk assessment form [DOCX, 741 KB]

Decide on an action

New Zealand Food Safety recommends that businesses take a cautious approach to recalls, especially where intended consumers are young, old, pregnant, or immune compromised.

The criteria you use to make a decision can vary depending on the specific situation. 

Undeclared allergen

Usually New Zealand Food Safety will recommend a recall if the:

• product contains an allergen, and the amount of allergen consumed in one sitting could cause an allergic reaction
• allergen is not indicated on the product label, or a "free-from" claim is made.

The amount of an allergen in food that could cause an allergic reaction can be as low as 0.01mg to 5mg, or less for highly sensitive people. The amount can vary depending on the allergen and the latest scientific information. New Zealand Food Safety can help you assess this.

Check other relevant criteria that may apply

Example scenario: A business reported finding 200mg/kg level of peanut allergen in its biscuits caused by a contaminated ingredient. The serving size was 20g, which resulted in 4mg peanut allergen per serve (200mg/kg x 0.020kg = 4mg). The company decided on a consumer-level recall of all batches containing the affected ingredient, New Zealand Food Safety agreed.

Foreign matter

Usually, New Zealand Food Safety will recommend a recall:

• if the foreign matter is hard or sharp
• is a size that could cause harm
• if there has been more than one report of foreign matter.

Foreign matter that falls in the range of 7mm to 25mm typically poses a high risk of harm (or smaller/larger for glass, products marketed as suitable for children or babies, or for beverages).

Check other relevant criteria that may apply

Example scenario: A business received multiple reports of hard sharp foreign matter (glass) of 8mm in length in pasta. The business identified one batch of affected ingredients and decided on a consumer-level recall of all batches containing that ingredient. New Zealand Food Safety agreed.

Microbiological hazard

Usually New Zealand Food Safety will recommend a recall:

• If the product contains microorganisms that could make someone sick.

Or:

• If a business’s process to manage a microbiological hazard critical control point has been out of control.
  There are some regulatory limits for the allowable level of microorganism in products, in some cases the microorganism must be absent (not detectable). Examples of regulatory limits are in Schedule 27 of the Australia New Zealand Food Standards Code

Check other relevant criteria that may apply

Listeria monocytogenes

• The regulatory limit for Listeria monocytogenes depends on whether listeria can grow to unsafe levels in your product.

Generally, Listeria monocytogenes can grow to unsafe levels in ready-to-eat, chilled products with:

• a water activity of greater than 0.92, and
• a pH of greater than 4.4.

If Listeria monocytogenes cannot grow in your ready-to-eat product, the regulatory maximum is 100 colony forming units/gram in five 25g samples. If Listeria monocytogenes can grow in your ready-to-eat product, the regulatory maximum is zero in five 25g samples.

Find out more about Listeria

Example scenario: A business received a presumptive positive lab result of listeria species detected in salad. After considering its environmental monitoring programme and product testing, as a precaution, the company decided on a consumer-level recall of all products containing the same ingredients and all products packaged on the same packing line following the salad for that day. New Zealand Food Safety agreed.

Chemical hazard

New Zealand Food Safety will consider:

• if the product contains a chemical that could cause harm
• if the amount in one serving is at a level that could cause harm.

New Zealand Food Safety will also consider if the chemical poses an acute (immediate) or chronic (gradual) harm risk. If the chemical poses an acute risk, New Zealand Food Safety is more likely to recommend a consumer-level recall. If the chemical poses a chronic risk, New Zealand Food Safety is more likely to recommend a trade-level recall.

The amount of a chemical that could cause harm varies, New Zealand Food Safety can help you assess this.

Check other relevant criteria that may apply

Example scenario: A business received multiple reports of sick consumers associated with histamine in its product. A laboratory report indicated elevated histamine of 220mg/kg of product (above the regulatory limit of 200mg/kg). Business records indicated elevated temperature in the packing room on a single day, possibly due to unusually hot weather. The business decided to undertake a consumer-level recall of all product susceptible to histamine contamination processed on that day. New Zealand Food Safety agreed.

Schedule 19 of the Australia New Zealand Food Standards Code

Other problems

Do your own assessment and check with New Zealand Food Safety.

Other criteria that may apply

Examples of other criteria that New Zealand Food Safety consider:

• Shelf-life: If there is no, or minimal shelf-life remaining on your product (e.g. one or two days) New Zealand Food Safety is less likely to recommend a consumer-level recall (but may still recommend a trade-level recall).
• Further processing: If your product is not yet in trade or sold to consumers, and you intend to process it further to control risk to consumers, a recall isn’t necessary. If you expect the product to be cooked, or treated in some other way by consumers to control risk, New Zealand Food Safety may still recommend a recall.

How many products and batches?

Your risk assessment should describe the reasons why you think specific batches are affected, and not others. If it is unclear which products or batches are affected, New Zealand Food Safety recommends you take a cautious approach by including more batches and products.

Consumer-level recall or trade-level recall?

Generally, New Zealand Food Safety will recommend a:

• consumer-level if your product has a food safety problem and has been sold to consumers, unless the product has no or minimal shelf-life, or for some chemical hazards.
• trade-level if your product has not been sold to consumers or it has a suitability problem.

Watch this video for further information on what suitable food is – YouTube

If the problem is neither a food safety nor a suitability problem, businesses can remove product from trade without any New Zealand Food Safety involvement (often called a withdrawal). Wrong colour bottle caps, for example.

Tell us about your risk assessment and recall decision

Businesses with a food control plan or national programme must tell New Zealand Food Safety as soon as practicable after making the recall decision but no later than 24 hours after making the decision. From 1 July 2022, this also applies to animal products and wine businesses with a plan or programme, and to importers and exporters.

You can do this by emailing your risk assessment (for example, RA Form) to Food.Recalls@mpi.govt.nz

Don’t worry if you can’t fill in every field, just send what you can (you can send an updated version later if needed). Or you can call New Zealand Food Safety on freephone 0800 00 83 33 and ask to speak to a food coordinator.

New Zealand Food Safety may assign a case officer to assist you.

New Zealand Food Safety has lots of experience doing recalls. Telling New Zealand Food Safety early can help your recall go more smoothly and can sometimes avoid the need for a recall altogether.

If there is a disagreement between you and New Zealand Food Safety about whether to do a recall, the level, the scope, or the reason behind the recall, New Zealand Food Safety will work with you to try to reach an agreement.

If an agreement still can't be reached, New Zealand Food Safety can direct the recall.

Imports and exports

• Imports: New Zealand Food Safety will share information with overseas authorities as required. You should also tell the business you imported the product from.
• Exports: tell New Zealand Food Safety and your verifier the destination market, exporter name, vessel name or flight ID, and the dates of departure. If the product has an export certificate, provide the certificate numbers.

Check your plans for recalled products

Tell your case officer what your plans are for the recalled product (sometimes called product management or disposition). Your case officer may ask for evidence of product management or disposal (for example, a receipt, certificate, or photographs).

The following is a general guide but requirements can vary depending on the specific situation.

Food and wine businesses

Options available: Retailers commonly destroy affected product via landfill, but re-processing, re-labelling, or re-purposing may be other options.

Evidence of product management or disposal: Generally, New Zealand Food Safety doesn’t expect nationwide supermarkets to collect evidence of disposal to landfill, given their plans and programmes in place.

Generally, New Zealand Food Safety does expect manufacturers and importers to collect evidence about what they did with recalled product. e.g. a receipt or certificate from a waste disposal provider.

In all other cases, talk with New Zealand Food Safety (e.g. case officer).

For alcoholic beverages, New Zealand Customs may need to be advised.

Animal products businesses (human consumption):

Depending on the type of animal product and the nature of the problem, you may need approval from either your verifier or New Zealand Food Safety to destroy, re-process, re-label, or re-purpose recalled products.

Your verifier may be able to provide more information.

If you are seeking return of recalled product from retail and distribution, in general this should be completed before retail shelves are re-stocked with unaffected product.

Prepare and distribute a point-of sale notice (consumer-level recall)

For a consumer-level recall, prepare point-of-sale notices, and distribute them to retailers to display to consumers.

New Zealand Food Safety is available to prepare these for you. If you prepare one yourself, please check it with New Zealand Food Safety before distributing it.

Recall reason

Point-of-sale notices will usually contain a "recall reason". The examples below are a general guide, but can vary depending on the specific situation:

[Business name] is recalling the above product due to:

Allergen: the possible presence of an undeclared allergen [type]

Foreign matter: the possible presence of [colour and/or type] foreign matter

Microbiological hazard: the possible presence of [name of microbiological hazard]

Chemical hazard: the possible presence of [name of chemical] contamination

Other: a lack of process control, a packaging fault, which may lead to a potential risk of [foreign matter/microbiological/chemical] contamination

Communicate to businesses that have received your product (consumer and trade)

Let other impacted business customers (for example, retailers and manufacturers) know about the recall (for example, email or a digital tool like GS1’s ProductRecallNZ application)

Tell your business customers what you want done with affected product (for example, disposal or return), and what level of evidence to collect (if any).

Communicate to consumers (consumer-level recall)

For a consumer-level recall, you have a responsibility to let all consumers of your product know.

Consider who typically consumes your product and how best to reach them:

• What is their age group, and how do they interact with media? For example, elderly consumers typically read the newspaper and listen to radio, while young people typically read social media via devices such as phones and tablets.
• Often businesses put out a media release, provide information on their website and social media pages, or contact consumers directly if their contact details are known. Some businesses advertise in print media or online, especially for high-risk product recalls, or for nationally distributed product recalls.

New Zealand Food Safety may add a notification to its website. New Zealand Food Safety may issue a media release for microbiological hazard recalls and for recalls of products marketed to young, old, immunocompromised, or pregnant consumers.

If New Zealand Food Safety considers you haven’t adequately advertised the recall, New Zealand Food Safety will work with you to try to reach an agreement. If an agreement still can’t be reached, New Zealand Food Safety can take other actions.

Examples of consumer communication

If you undertake a baby food recall, New Zealand Food Safety recommends advertising in mainstream media, as well as magazines and newsletters targeted to new parents (due to the serious consequences if babies were to become ill).

If you undertake a recall for presence (or possible presence) of Listeria monocytogenes, consider advertising in mainstream media, as well as media targeted to new parents, pregnant women, the elderly (via newspapers and radio), and immunocompromised people.

New Zealand Food Safety will communicate with overseas authorities

If recalled product has been exported, New Zealand Food Safety will manage communications with authorities in the importing countries. Businesses will need to inform importers and provide information on how to manage the product.

Check how much product was returned

After a recall, collect the following information (this process is sometimes called reconciliation):

• amount of affected product produced/imported;
• amount on hold;
• amount for quality control samples;
• amount claimed for/returned by trade customers;
• amount returned by consumers; and
• amount unaccounted for.

If you have access to one, you can use a digital tool to reconcile affected product (for example, GS1’s ProductRecallNZ application).

Example of how reconciliation information can be set out [XLSX, 22 KB]

Review and identify corrective/preventative actions

• Review what went well and not so well with the recall.
• Identify any corrective/preventative actions to manage the risk of the problem happening again, identify who will do them, and a timeline within which to complete them.

Inform New Zealand Food Safety how the recall went

After the recall, inform your case officer about the details of the recall. We recommend you fill out the recall audit form and email it to your case officer (or New Zealand Food Safety at Food.Recalls@mpi.govt.nz).

Your case officer may come and check your corrective actions and records.

Records

The following kinds of records may be helpful to show your case officer:

• reconciliation information;
  • identification of affected products and batches
  • distribution of affected products and batches
• customer contact information
• correspondence with supplier (for example, email)
• correspondence with your verifier and New Zealand Food Safety (for example, emails, name, day, time of phone call).
• your risk assessment
• meeting notes (for example, notes including day, time, attendance, key points).

Draft communications examples:

• point of sale notice (for a consumer-level recall) [DOCX, 83 KB]
• communications to customers like emails [DOCX, 14 KB]
• media release (for a consumer-level recall) [DOCX, 16 KB]
• advertisements and/or mock social media notifications (for a consumer-level recall) [DOCX, 13 KB]
• a timeline of your recall [DOCX, 26 KB]