Anatomy of a Food Recall

Convenience retailers need a plan to address food and beverage product recalls.

Anatomy of a Food Recall

March 2024   minute read

By: Shawn K. Stevens Esq. , Elizabeth Presnell Esq. , Jay L. E. Ellingson Ph.D.

In the United States, product recalls happen almost daily.

There were about 550 product recalls in 2023, according to the Food Industry Counsel’s Food Recall Reporter, a robust, searchable database of FDA and USDA food product recalls.

In the convenience store space, it’s a good idea to have a plan in place and a team that can take immediate action on recalls. By executing a recall well, retailers can build trust with their customers and show they are looking out for them when it comes to potentially unsafe products.

Part One: Why Products Are Recalled

Food recalls are intended to remove a food or beverage product from the market that may present a food safety risk.

Examples of dangers found in the food include a pathogen (e.g. E. coli, salmonella or listeria); one of the “big nine” undeclared allergens (milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soy, sesame); or a foreign object such as metal or plastic.

Product recalls address safety concerns that could injure consumers, while a product withdrawal is less formal and is used to address product quality concerns.

Product withdrawals are typically used to address product quality concerns such as harmless mold or an off color; rancidity or other off flavor notes; minor labeling errors; and variations in sensory attributes. Product withdrawals are often conducted to the wholesale level and do not affect retailers and consumers.

If a manufacturer does not cover recall expenses and losses, a company’s recall insurance may provide some coverage.

Just about any food can be subject to a recall—from leafy greens to peanut butter and everything in between. Recalls also have the potential to expand. For example, shelf-stable granola bar products have recently been affected by a recall process due to products potentially contaminated with salmonella, according to the maker and the FDA.

When this recall was first issued, it largely included granola bars and granola cereals but later expanded to include more products, such as additional cereal products and snack mixes. When any recall involves food products used for human consumption, it takes a tremendous amount of time, resources and clear communication (including working with both the company and regulatory officials) to resolve these recalls.

The FDA’s New Era of Smarter Food Safety blueprint, announced in July 2020, outlines four core elements that are intended to create a safer and more digital, traceable food system:

• Tech-enabled traceability

• Smarter tools and approaches for prevention and outbreak response

• New business models and retail modernization

• Food safety culture

To download the FDA’s blueprint, go to

Who Initiates a Recall?

As part of greater food safety awareness and national surveillance, more convenience retailers may find themselves a part of product recalls. Recalls and product withdrawals are typically initiated by the manufacturer, following a determination that a safety or quality issue may exist.

However, in some circumstances, the FDA and USDA may require a retailer to initiate a recall if a product manufacturer does not conduct a voluntary recall on its own.

Once it’s determined a recall or withdrawal is appropriate, the manufacturer is typically responsible for identifying who received the recalled product and for providing notice of the recall or withdrawal to those recipients.

Then, those recipients must, in most circumstances, carry the recall or withdrawal further downstream. In most cases, a retailer will learn about the existence of a recall from its distributor or suppliers.

Part Two: Putting Your Recall Plan Into Action

If you don’t currently have a recall team in place or your recall plan hasn’t been revisited in some time, start by identifying the stakeholders who would need to be involved if a recall were to happen.

Your recall team should be composed of the relevant internal stakeholders and external consultants as necessary (food safety experts and attorneys, for example), to ensure all areas of the business are involved. External stakeholders may also include federal, state and local regulatory officials. If a gap is identified within the recall team, external resources should be vetted and onboarded to ensure all team members are knowledgeable about the company and its recall process.

The company should consider its approach to unaffected but related product.

The recall plan should include the company’s decision-making framework, including what factors are considered when decisions are made and which team members must approve any decisions prior to execution. For example, the company’s executive leadership may not be involved in most actions in advance of a recall but must be consulted for final approval once a decision to recall a product is made.

Some companies may have more sophisticated plans than others, depending on store count and the foodservice program—and that’s OK. Companies will often have different decision-making frameworks and different triggers for involving certain team members.

Ideally, the recall team should meet outside of a recall scenario to develop a framework for managing any potential future recalls and to ensure team members are trained on their individual responsibilities in the event of a recall.

After developing an initial recall plan, which includes all information about how recall decisions are made and executed, the recall team should conduct a realistic mock recall, where the full process is tested in a fictional scenario. Many companies will work with their food safety lawyers or consultants to develop mock recall crisis scenarios. After completing the mock recall scenario, the recall plan should be updated to include learnings and process updates.

In addition, recall team alternates should be identified to ensure each role is represented if the primary recall team member is unavailable. These recall team alternates should be trained the same as the primary team member and should participate in mock recalls to ensure consistency in the company’s recall response.

Federal, state and local regulators can also be a valuable resource when conducting a product recall. However, these relationships should be developed outside of a recall situation to best allow for collaboration with regulators if a recall becomes necessary.

You’ve Been Notified of a Recall—Now What?

If you’ve been notified of a product recall affecting product in your control, you should immediately convene your recall team.

Once the recall team has been convened, it should carefully assess the food safety risk (if any) associated with the recall, as well as the status of the product within the company’s supply chain. Often, product that has not yet reached store shelves can be more easily contained and controlled than product that’s been on shelves for consumers to purchase and consume.

Once the food safety risk is understood and the potentially affected product is identified, the recall team should ensure that the product is pulled from distribution and store shelves. In addition, if the recalled product was processed or repackaged by the company, a press release and notification to FDA is typically necessary to communicate the recall to the public.

As product is removed from distribution and store shelves, inventory should be maintained of all actions taken. Specifically, any disposal or destruction of recalled product should be documented comprehensively, as well as the total cost impact of the recall.

In many circumstances, the manufacturer will reimburse affected downstream purchasers of recalled product for costs associated with the recall. This typically requires strong documentation of the company’s actions and losses. If a manufacturer does not cover recall expenses and losses, a company’s recall insurance may provide some coverage.

In addition, regulatory agencies may require documentation confirming that the company took appropriate action after notification of the product recall and destroyed all implicated product. This often is provided to the manufacturer through a recall effectiveness check. If you receive an effectiveness check, ensure that it is carefully and accurately completed and returned to the manufacturer.

Addressing Unaffected Related Product

Often, a manufacturer will only recall a limited amount of product, such as a single lot or product with a single expiration date. However, in many circumstances, a retailer may have other lots or expiration dates of the recalled product or other products from the same manufacturer.

During a recall, management of these unaffected products should be considered. Typically, this will be a case-by-case determination by the recall team. When considering unaffected related product, the evaluation should consider the risk to the company’s brand from continuing to sell these products, any potential food safety risk associated with the products, the brand’s risk tolerance and the ease or difficulty of pulling only select lots.

It’s a good practice to have the recall team discuss these considerations well in advance of a recall scenario so the brand has a framework for appropriate decision-making when a recall does occur.

Communicating to Customers

In addition to pulling recalled products from distribution and store shelves, when should retailers communicate what’s going on to their customers? There are voluntary communications that the recall team should consider.

First, unless the product is processed or repackaged by the company, a press release issued by the retailer is typically not necessary—that will be generated by the product manufacturer. Second, in-store signage, website communications and/or direct customer notifications (i.e., notices provided to loyalty program members) can help ensure that consumers who may have purchased the product are aware of the recall.

Well in advance of a recall scenario, the recall team should discuss the decision framework for when communications are used. Why? So that when an actual recall occurs, the process is managed seamlessly.

Beyond proactive communications, the company should also be prepared to respond to media questions and customer inquiries and complaints. When addressing inquiries from the media:

• Designate a single point of contact who can field questions.

• Ask for the questions to be submitted via email.

• Work with the recall team to prepare appropriate responses.

Customer contacts might happen through the company’s corporate contact information as well as at the store level when a customer learns a product is not available. Typically, customers can be referred to the product’s manufacturer for questions, but the recall team should determine how in-store associates should respond to any inquiries.

Manufacturers often direct consumers to return recalled product to the point of purchase for a refund. Retailers should therefore ensure that in-store associates are trained and prepared to dispose or return product and issue any recall-related refunds. Further, retailers should consider an appropriate refund method that accurately tracks the refunds so the amount can be recovered from the manufacturer.

Part Three: Kwik Trip Case Study

By Dr. Jay Ellingson

At Kwik Trip, we strive to always do what is right.

Everyone has a role to play in keeping food safe. If you are in the business of production, distribution and/or the sale of food products through foodservice, there are always possibilities of risks within your food system.

If we’re in doubt about a certain product, especially if the recall has the potential to expand, we will pull it.

How you decide to mitigate those food risks should be part of your company’s mission, culture and leadership strategies. With inherent risks in the food supply chain (especially after Covid) comes the possibilities of either formal recalls or quality withdrawals.

First, formalize a recall team that comprises all aspects of your organization through internal and external resources as necessary, ensuring each business operation is represented: legal, procurement, production, distribution, transportation, customer relations, communications and retail, as applicable.

Second, build strong relationships with your local, state and federal regulatory agencies. These relationships are a critical part of your recall program—if these agencies understand your food system and how you mitigate risk prior to any formal recall or quality withdrawal events, they are in better position to collaborate with your company during times of food emergencies or recalls.

At Kwik Trip Inc., our recall team maintains strong relationships with our local, state and federal regulatory officials and public health teams. Our teamwork approach allows us, through education and collaboration, to maximize opportunities that proactively mitigate risks within our food supply chain. By being proactive, we have strengthened our recall team and our recall and withdrawal plans, especially when events happen in the food supply chain.

We have experienced both recalls and withdrawals in the areas of raw produce, undeclared allergens and foreign materials in food ingredients and finished products. Through these experiences, we have learned the right thing to do when confronted with a recall or withdrawal event. The process that takes place for a recall issued by a vendor to Kwik Trip generally looks like this:

• Upon notification of a recall, the recall team meets, and Kwik Trip begins the process of initiating our internal process using our recall plan.

• The ingredient, raw material or food products involved in the recall notification are removed from retail stores immediately through an alert system. The internal recall alert notice sent to all Kwik Trip retail stores includes key instructions on how to destroy the recalled products, document the destroyed product and confirm the recalled product is removed by all retail stores.

• Product in our distribution center is immediately quarantined, documented and disposed of following both vendor and federal regulatory guidelines. It’s also worth noting that if we’re in doubt about a certain product, especially if the recall has the potential to expand, we will pull it. Customer safety is paramount.

• On the same day of the recall notification, we connect directly with the appropriate federal (FDA/USDA) and state regulatory agencies to coordinate a nationally publicized, detailed press release for consumers who may still have the recalled product. This press release gives all the necessary information and photos to the consumer to identify the affected product.

• The press release is also sent to the local, state and federal agencies and to the appropriate press with the request to release this information to the public immediately. Details of our recall can then be found on the appropriate state and federal websites for the customers to review.

• Customers who return products to Kwik Trip (or Kwik Star, in Iowa) stores are given a full refund, and products are recorded and destroyed according to the vendor and federal guidelines.

When it comes to the protection of public health and mitigating risks to your food supply chain and brand, it is best to have a recall team, a tested recall plan and leadership that takes the approach to always do what is right. Open and transparent communication during recall events leads to trust with your regulatory officials and, ultimately, to the customers you serve.

And finally, always doing what is right protects public health, your teams and your brand.

Part Four: Returning to Normal Operations

As soon as companies act on a recall, stores can return to normal operations—minus the affected products that have been removed from store shelves.

At this stage, retailers should continue to anticipate questions from customers. The communications work the team has done earlier will still be valuable.

The return to normal inventory of the recalled product can often take several days or weeks, depending on the scope of the initial recall. Often, if a manufacturer recalls only a single lot of products, other lots can be available within days.

On the other hand, if the recall encompasses a large amount of product involving multiple production days, additional replacement inventory may be difficult to obtain, and stores could be without product for several weeks.

As previously discussed, the company should consider its approach to unaffected but related product. The company may decide to avoid selling any lots of the recalled product, even if not directly affected by the recall, for a set period to ensure that the recall will not be further expanded.

Similarly, a company may decide to stop sales of products from the recalling manufacturer, even if unaffected, for a period of time, until a supplier assessment can occur to better understand the cause of the recall and any related food safety risk associated with the manufacturer.

Support from regulators and external food safety experts may also be appropriate in determining when to restart any sales of a recalled product.


Even though product recalls happen routinely, each product recall creates unique challenges and considerations for a company. To help ensure that your company is prepared to manage any product recall, two immediate steps you can take are to convene a recall team and develop a recall plan.

By consistently revisiting your company’s recall plan, your teams will have a strong and thoughtful approach to any recall that may occur.

Where to Find Recall Information

There are multiple ways to access timely food and beverage product recall alerts:

• The Centers for Disease Control and Prevention offers a recall widget that can be added to your company’s intranet

• The FDA’s recall information

USDA’s Food Safety and Inspection Service recall information

• The Food Industry Counsel’s Food Recall Reporter

Shawn K. Stevens Esq.

Shawn K. Stevens Esq.

Shawn K. Stevens Esq. is the founder of Food Industry Counsel LLC. He can be reached at [email protected].

Elizabeth Presnell Esq.

Elizabeth Presnell Esq.

Elizabeth Presnell Esq. is a food industry consultant and lawyer with the Food Industry Counsel LLC. She can be reached at [email protected].

Jay L. E. Ellingson Ph.D.

Jay L. E. Ellingson Ph.D.

Jay Ellingson Ph.D. is the chief science officer at Kwik Trip Inc. He can be reached at [email protected].

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