Trade press reports have highlighted a spate of recent recalls relating to food and drink products in the UK resulting from labeling errors. Examples include foods recalled because of salt crystals not mentioned on the packaging (which represent a potential choking hazard), chocolate drinking straws with labels not in English (with allergen information therefore not easily comprehended), and several products that contained allergens not correctly mentioned on the label. If food businesses are part of a global food supply chain, they would be well advised to be aware of what will happen when recalls are required across several countries. Their own products may need to be recalled in other jurisdictions, and they may use ingredients from other jurisdictions that have been withdrawn or recalled from the market.
Emerging global food recall trends indicate that food business operators exporting to the EU should familiarize themselves with the EU’s food notification, withdrawal, and recall laws and regulations. Food business operators also should plan for a recall before any issue is identified by developing and regularly reviewing thorough recall policies and protocols and insurance coverages. For those exporting from the US to the EU, understanding and conscientiously following these legal and practical obligations can be beneficial to anticipate the demands of European customers and to ensure that contractual documentation clearly defines the roles and responsibilities of both parties.