A recall plan is a short written document that answers four questions before anyone is panicking: who decides to recall, how you'll find the product, who calls whom and what they say, and what happens to the product that comes back. For a small producer it should run to about four pages. The filled-in example below follows the four things FDA's rule requires a recall plan to cover, and you can adapt it in an afternoon.
The short version
- Name a recall coordinator and a backup, with cell numbers. One person decides. Everyone else has a job.
- Say how you'll identify the affected product: lot codes, batch records, shipping records.
- Write the customer notice now, with blanks, so nobody is drafting it at midnight.
- Cover FDA's four: notify your direct customers, notify the public when it's warranted, check that the recall actually worked, and dispose of what comes back.
- Test it once a year with a mock recall, and update the phone numbers when you do.
Do you legally need one?
It depends on your size, and you'll probably need one either way.
Under FDA's Preventive Controls rule, a facility that has identified a hazard requiring a preventive control must have a written recall plan. Very small businesses, which FDA defines by food sales (roughly a million dollars a year, adjusted for inflation), can qualify as "qualified facilities," and the section of the rule containing the recall plan doesn't apply to them. Meat and poultry plants answer to USDA instead, which has its own requirements.
So plenty of small producers aren't required by FDA to have one. In practice the requirement arrives from a different direction: the new-vendor packet from a grocery chain or distributor has a line that says "attach recall plan," and the account doesn't move forward without it. That's the usual reason people land on this page. (It usually arrives alongside a request for lot tracking. Here's what buyers mean by that.)
This is general information, not legal advice. Your inspector, or a food safety consultant who knows your product, has the last word on what applies to you.
What FDA says a recall plan must do
The rule is refreshingly short. The written plan must include procedures, and say who's responsible, for four things:
- "Directly notify the direct consignees of the food being recalled, including how to return or dispose of the affected food."
- "Notify the public about any hazard presented by the food when appropriate to protect public health."
- "Conduct effectiveness checks to verify that the recall is carried out."
- "Appropriately dispose of recalled food," for example by reprocessing, reworking, diverting it to a safe use, or destroying it.
"Direct consignees" means the people you shipped to: your wholesale accounts and distributors. Everything in the example below hangs off those four.
The example plan
This one is written for Windward Roots, a fictional Oʻahu company that makes poi, kūlolo, bread and taro chips and sells to a grocery chain, restaurants, a gift shop, its own two shops, an online store and a farmers market. Swap in your own names and delete what doesn't apply.
1. Recall team
| Role | Person | Does what |
|---|---|---|
| Recall coordinator | Leilani Akana, owner. Cell: ___ | Decides whether to recall. Talks to regulators and press. Signs the notice |
| Backup coordinator | Marcus Tanaka, operations. Cell: ___ | Everything above when Leilani can't be reached within one hour |
| Traceability | Marcus Tanaka | Identifies affected lots and where they went. Produces the customer list |
| Customer calls | Sam Ige, purchasing | Calls and emails every wholesale account on the list. Logs each contact |
| Product hold and returns | Jordan Wong, warehouse | Tags and segregates stock on hand. Receives and counts returns |
| Outside help | Food safety consultant: ___. Insurance agent: ___. Attorney: ___ |
A two-person business has the same table with the same two names in it several times. That's fine. What matters is that nobody has to ask who's doing what.
2. When we recall, and who decides
We consider a recall when any of these happen: a supplier tells us an ingredient lot is affected; a customer complaint suggests illness, injury, a foreign object or an undeclared allergen; our own testing or an inspection finds a problem; a label is found to be wrong about allergens.
The coordinator decides within four hours of learning of it, after talking to our food safety consultant. If there's any chance someone could get sick, we stop shipping the affected product first and finish deciding second.
3. Finding the product
Every unit and case carries a lot code (date plus batch letter, like 260921A). Batch records list the supplier
lot of every ingredient. Every invoice and transfer lists the lots shipped. That chain is how food traceability works.
From a lot code or a supplier lot, the traceability lead produces, within four hours: the affected finished lots, quantities made, quantities still on hand by location, and every customer who received them with quantities and dates. We practice this once a year (here's what that drill looks like).
If you don't have lot codes yet, that's the first job. Setting them up takes an afternoon.
4. Notifying our direct customers
Within 24 hours of the decision, every wholesale account that received an affected lot gets a phone call followed by a written notice. Online customers get an email. The log records who was contacted, when, by whom, and what they said they had on hand.
The notice, ready to fill in:
URGENT: PRODUCT RECALL
[Date]
Windward Roots is recalling [product, size], lot code(s) [codes], best by [dates], because [plain reason, e.g. "it may contain sesame, which is not declared on the label"].
The lot code is printed [where on the package]. No other products or lots are affected.
What to do: Stop selling this product now. Remove it from shelves and hold it somewhere it can't be sold. Count what you have and reply to this notice with the quantity. We will [pick it up / credit you to destroy it], and we'll credit your account in full.
Our records show you received: [quantity] on [dates].
Questions: [name, phone, email]. Please confirm you've received this notice by [date and time].
Keep it that plain. The reason goes in one sentence a store clerk can repeat to a shopper.
5. Notifying the public
If the product could make someone sick and it has reached people we can't contact directly (shop counters, the farmers market), the coordinator issues a public notice: a press release to local media, a post at the top of our website and social accounts, and a sign at each of our registers and at the market table. We contact FDA's recall coordinator for our area before the release goes out, and we follow their guidance on wording.
6. Checking it worked
Three business days after the notices go out, we confirm with every wholesale account that they received the notice, pulled the product, and told us their count. Anyone who hasn't replied gets a second call. We add up quantity recovered, quantity destroyed by customers, and quantity already sold, and compare it with what we shipped. The recall is closed by the coordinator, in writing, when those numbers are accounted for.
7. What happens to the product
Returned and held product is tagged RECALLED, DO NOT SHIP, counted, and kept apart from good stock. Depending on the reason, it's destroyed (we record the date, quantity, method and a witness) or, if the consultant agrees it's safe and legal, reworked or relabeled. Nothing goes back into saleable stock without the coordinator's signature.
8. Keeping this plan alive
Reviewed every January and after every mock recall. Phone numbers are checked by actually calling them. Last reviewed: ___. Next mock recall due: ___.
Where this stops working
The plan is the easy part. Section 3 is where real recalls go wrong. "Within four hours" is a promise your records have to keep, and if the lots aren't on the invoices, or the batch sheets are in a binder at the co-packer's, the customer list you produce will be a guess. A guess means recalling everything, from everyone.
How TaroStack does it
TaroStack is the part of this plan that finds the product. Supplier lots are recorded when stock is received, the lots used are noted on every batch as it's recorded, and the lot goes on every order that ships. Section 3 becomes one report: choose a lot, and you get the batches it went into, every customer who received them with quantities, what's still on your own shelves and where, and the contacts to call. Put stock on hold and it stops counting as available, so nobody ships it by accident on day two.
You can run a timed traceability drill whenever you like, and the app logs how long it took, which is the proof section 8 asks for. It doesn't write your recall plan or decide anything for you. It makes sure the list is right. Lots, expiry and recalls are included in every plan.