What Do Shops Have to Do When Food Is Recalled or Withdrawn?
Take the affected product off sale at once, keep it apart from other stock, and help whoever is running the recall. Under Article 19(2) of assimilated Regulation (EC) No 178/2002, a shop that only resells food must, “within the limits of its respective activities”, start procedures to withdraw non-compliant products from the market and cooperate with producers and the authorities. The duty to tell consumers and recall food rests mainly on the business that produced, imported or distributed it, but the FSA also expects shops to display the recall notice and take returns. If you make or pack food yourself, the full duty is yours.
On this page
- 1What is the difference between a food withdrawal and a food recall?
- 2What does the law say shops and food businesses must do?
- 3What does “within the limits of its respective activities” mean for a shop?
- 4What records does a shop need to keep so a recall can work?
- 5Is it a criminal offence if a shop does not withdraw or recall unsafe food?
- 6What are the rules in Northern Ireland and Scotland?
- 7What are the FSA alert types, and how do shops get them?
- 8What should a shop do, step by step, when a recall notice arrives?
- 9What should a point-of-sale recall notice say?
- 10Can a shop sell, serve or donate recalled food?
- 11What usually causes food recalls?
- 12How do allergen recalls and Natasha’s Law fit together?
- 13What about small shops, market traders and online sellers?
- 14How can a shop prepare before a recall happens?
- 15Which training helps shops and food businesses handle recalls?
- 16Frequently asked questions
- A withdrawal is not a recall. A withdrawal removes unsafe food before it reaches consumers; a recall also asks consumers to act.
- Shops have a defined duty. Article 19(2) requires retailers, within the limits of their activities, to withdraw non-compliant products and cooperate with producers and authorities.
- Failing to act is an offence. Breaching Article 19 is a criminal offence in every UK nation, with up to two years in prison on conviction on indictment.
- Recalled food cannot be sold or donated. Placing on the market includes free transfers, so stock must be quarantined, then returned or disposed of.
This guide is for shop owners, managers, counter staff, market traders and anyone selling food to the public. It follows the law and Food Standards Agency (FSA) guidance as at 29 October 2026, with notes on Scotland and Northern Ireland. For use-by and best-before dates, see our food labelling guide.
What is the difference between a food withdrawal and a food recall?
The FSA’s incidents guidance says: “A withdrawal is when unsafe food is removed from the supply chain before it has reached consumers. A recall is when unsafe food is removed from the supply chain and consumers are advised to take appropriate action, for example to return or dispose of the unsafe food.”
In a shop the two overlap: packs on your shelves are withdrawn; packs in customers’ kitchens are recalled. The FSA’s decision tree puts withdrawal first, with a recall only if the food has reached consumers and withdrawal alone is not enough to protect public health. Its retailer table (paragraph 51 of the guidance) splits the shop’s actions like this:
| Shop action (FSA guidance) | Withdrawal | Recall |
|---|---|---|
| Remove all affected food from sale and store it separately | Yes | Yes |
| Return it to the supplier or dispose of it as directed | Yes | Yes |
| Issue the point-of-sale recall notice and help consumers return the food | Not applicable | Yes |
| Accept returns from customers and store them separately | Not applicable | Yes, if appropriate |
What does the law say shops and food businesses must do?
The core rules are in Article 19 of Regulation (EC) No 178/2002, which is assimilated law in Great Britain. Legislation.gov.uk records no outstanding changes to it. In summary:
- Article 19(1), producers and suppliers. A business that “considers or has reason to believe” that food it “imported, produced, processed, manufactured or distributed” is not in compliance with food safety requirements “shall immediately initiate procedures to withdraw the food in question from the market”, and inform the competent authorities. Where it may have reached consumers, the business must “effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers products already supplied to them when other measures are not sufficient to achieve a high level of health protection”.
- Article 19(2), retailers. A business responsible for “retail or distribution activities which do not affect the packaging, labelling, safety or integrity of the food shall, within the limits of its respective activities, initiate procedures to withdraw from the market products not in compliance with the food-safety requirements” and must pass on “relevant information necessary to trace a food” and cooperate “in the action taken by producers, processors, manufacturers and/or the competent authorities”.
- Article 19(3), telling the authorities. Any food business must “immediately inform the competent authorities if it considers or has reason to believe that a food which it has placed on the market may be injurious to human health”, and say what action it has taken.
Two definitions explain why you cannot wait. Under Article 3(8), “placing on the market” includes “the holding of food or feed for the purpose of sale”, so unsold stock in your chiller or stockroom still counts. And Article 14(6) says that where unsafe food is part of a batch, “it shall be presumed that all the food in that batch, lot or consignment is also unsafe”, unless a detailed assessment shows otherwise. That is why batch codes matter: they help limit what is withdrawn.
What does “within the limits of its respective activities” mean for a shop?
The retailer duty in Article 19(2) is narrower than the producer duty, and it applies only to a business whose activities do not affect the “packaging, labelling, safety or integrity” of the food. The wording in force in Great Britain says “its”, not “their”. The FSA guidance describes retailers in this section as those whose “activity is limited to purchasing food products and selling them directly to the consumer”, and says they “should co-operate as necessary with the FBO responsible for the management of the incident”.
Our reading of how that works in practice, which your local authority may refine:
| What the shop does with the food | Likely position |
|---|---|
| Resells sealed, labelled packs bought from a supplier | Article 19(2): withdraw, pass on trace information, cooperate |
| Cooks, slices, mixes or assembles food (in-store bakery, sandwiches, deli counter) | Likely the producer of that food, so Article 19(1) applies in full |
| Packs and labels food on site (prepacked for direct sale) | You wrote the label, so a wrong allergen label is likely your recall |
| Imports food yourself | Article 19(1) names food a business has “imported” |
Even a pure reseller carries Article 19(3): if you believe food you sold may harm health, tell your local authority.
What records does a shop need to keep so a recall can work?
Article 18 requires operators to “be able to identify any person from whom they have been supplied with a food” and to “have in place systems and procedures to identify the other businesses to which their products have been supplied”, with the information available to the authorities “on demand”. The Regulation does not use the phrase “one step back and one step forward”; that is the FSA’s shorthand, in its guidance, for the same duty.
Three practical points from the FSA guidance:
- Consumers are exempt. Retailers “are not required to keep traceability information relating to sales to the final consumer”. If you sell to another food business, such as a café, you must keep records of that sale.
- What to keep. Supplier or customer name and address, a description and quantity of the product, and the date of the transaction. Invoices and delivery notes can do the job if you can find them quickly.
- How long. The law sets no general period for retailers. The FSA calls shelf life plus 12 months “as a minimum” best practice for prepacked food. Meat, fish, dairy and other food of animal origin carry extra record rules (Annexe C).
Is it a criminal offence if a shop does not withdraw or recall unsafe food?
Yes. The offence sits in different instruments depending on where you trade:
| Nation | Offence created by |
|---|---|
| England | Food Safety and Hygiene (England) Regulations 2013, reg 19(1), with Schedule 2 listing Articles 18(2)-(3) and 19 |
| Wales and Scotland | General Food Regulations 2004, reg 4(d) and (e) |
| Northern Ireland | General Food Regulations (Northern Ireland) 2004, reg 4(d) and (e) |
The 2013 Regulations revoked regulations 3 to 7 and 6A of the 2004 Regulations for England only, which is why England differs. The footnotes to regulation 4 on legislation.gov.uk record revocation for England only, and the FSA guidance footnote names the 2004 Regulations for Scotland and Wales. England’s regulation 19(1) says that “any person who contravenes or fails to comply with any of the specified EU provisions commits an offence”. On conviction on indictment the maximum is two years’ imprisonment, a fine or both in England and, under regulation 5 of the 2004 Regulations, in Wales, Scotland and Northern Ireland.
There is a defence. The England Regulations say it is a defence to prove “all reasonable precautions” were taken and “all due diligence” exercised (reg 12). Enforcement is by local authorities. The FSA guidance says they can order a withdrawal or recall where a business fails its duties. Under section 9 of the Food Safety Act 1990, an authorised officer can inspect food, serve a notice that it “is not to be used for human consumption”, or seize it.
What are the rules in Northern Ireland and Scotland?
Northern Ireland
For food law, Northern Ireland follows EU law rather than assimilated law. The FSA’s general food law page says: “In Northern Ireland under The Windsor Framework, EU food law continues to apply.” Regulation 178/2002 therefore applies in NI as EU law, and the Article 19 offence is in regulation 4(e) of the 2004 Northern Ireland Regulations. The FSA’s withdrawals and recalls guidance applies to England, Wales and Northern Ireland alike.
Scotland
Food Standards Scotland (FSS) publishes the same joint UK guidance, dated 12 March 2019 on its guidance page. Its incidents page says a food business is legally required to inform the local authority, inform FSS where relevant, withdraw a product that has not reached the consumer, recall one that has, and notify the local authority of the action. FSS adds that a product that is safe but breaches labelling or quality rules may still be withdrawn “to avoid the risk of prosecution”. FSS issues its own alerts, with a free email and text service.
What are the FSA alert types, and how do shops get them?
On its alerts site the FSA uses three notice types, which we checked against live notices:
| Notice | What it is, per the FSA |
|---|---|
| Allergy Alert | Issued “when there is a food allergy risk”, for example where allergy labelling is missing or incorrect |
| Product Recall Information Notice | Issued “to let consumers and local authorities know about problems associated with food” |
| Food Alert for Action | Sometimes issued so that it “provides local authorities with details of specific action to be taken on behalf of consumers” |
On the alerts site, the second and third types both appear under the label “Food Alert”. A recent Food Alert for Action, on shell eggs carrying a particular producer code, told businesses to stop selling them, withdraw them and, where sold, recall them.
The FSA’s sign-up page says you can get alerts by email. Do not rely on one person’s inbox: use a shared shop address. Suppliers and wholesalers will often contact you directly too. Your duty starts when you “consider or have reason to believe” food is unsafe, not when an alert reaches you.
What should a shop do, step by step, when a recall notice arrives?
The legal minimum is in Article 19. These steps combine it with the FSA guidance’s retailer actions and best practice.
- Read the notice closely. Note the product name, pack size, batch codes, use-by or best-before dates and barcode. Compare each pack against the listed codes.
- Stop selling. Check shelves, chillers, freezers, stockrooms, counters, delivery vehicles and online listings. If your tills allow it, block the barcode.
- Quarantine. The FSA guidance suggests storing the food “away from non-affected food in a quarantined area”, labelling it, and keeping “accurate traceability and disposal records”.
- Record what you did. Log quantities, times, names and batches. The FSA has an example key decision log.
- Display the notice. Put the point-of-sale notice where customers will see it (see the next section), and on your website if you sell online.
- Take returns. Accept affected food from customers and store it separately. Notices usually tell customers to return food “for a full refund”; follow the recalling business’s instructions on refunds and ask how you will be reimbursed.
- Tell the supplier and follow its instructions. Return or dispose of the food as directed. If you also supplied another food business, tell it.
- Tell the authorities when required. Article 19(3) applies if you believe food you sold may harm health, and if you made the food yourself you are the one who must notify.
What should a point-of-sale recall notice say?
Annexe H of the FSA guidance says point-of-sale notices are “a key way” of reaching consumers. It recommends a notice that is clear, bright, concisely worded and placed where it is “prominent and visible”, “in colour” and “eye-level”, for example at the tills or customer service desk. The recommended content is:
- the reason for the recall, in plain language;
- brand, product name, pack size, durability dates and batch codes;
- where to find the code on the pack, with a clear picture;
- what to do: do not eat it, return it to the shop, how to get a refund;
- a contact number for more information.
Editable FSA templates for both a product recall and an allergy alert are on the incidents guidance page. The guidance also suggests the retailer’s website, social media and loyalty-card messages, and, for allergen recalls, telling allergy support organisations.
Can a shop sell, serve or donate recalled food?
No. Article 14(1) says unsafe food “shall not be placed on the market”, and Article 3(8) defines placing on the market to include any transfer “whether free of charge or not”. That covers handing it to staff, a food bank or a neighbour, as well as selling it. The same logic applies to waste: the FSA guidance says that if unsafe food cannot be made safe, “it must be treated as food waste”. Re-working or relabelling previously recalled food is allowed only with the enforcement authority’s agreement.
One caveat: we searched the FSA guidance and the 2024 WRAP/FSA surplus food redistribution guidance for any sentence about donating recalled food and found none. The conclusion rests on the legal wording, not an explicit FSA statement. In the egg alert above, the FSA told businesses not to divert the eggs to further processing and to dispose of them safely.
What usually causes food recalls?
On 29 October 2026 the FSA alerts site, whose date filter starts in January 2022, listed 705 alerts: 373 Allergy Alerts and 332 Food Alerts. Allergy Alerts were therefore about 53% of notices. Among the 373 Allergy Alerts, milk was tagged on 131, peanuts on 84 and gluten on 72. A notice can carry several allergen tags, so these figures overlap. England, Northern Ireland and Wales alerts are listed there; Scotland has its own.
Recent notices, also listed on the FSS alerts page, show other causes: possible glass in a pudding, Salmonella in shell eggs, Listeria in salmon and prawn products, a wrong use-by date on a tuna pâté, and poor temperature control for an oat drink. The FSA also publishes a single-point lesson on undeclared allergens from its root cause analysis work.
How do allergen recalls and Natasha’s Law fit together?
The FSA’s Allergy Alert wording says foods may have to be withdrawn or recalled “if the allergy labelling is missing or incorrect”. Since 1 October 2021, food prepacked for direct sale must carry its ingredients and allergens on the label, under the changes known as Natasha’s Law. If your shop makes sandwiches or salads and gets the label wrong, you are the producer and the recall is yours. Staff should know the 14 allergens well enough to check a notice and answer a customer who asks.
What about small shops, market traders and online sellers?
The law is the same. A “food business” is “any undertaking, whether for profit or not and whether public or private” carrying out food activities (Article 3(2)), and the FSA guidance counts e-commerce sellers and mobile vendors as retailers and caterers. Keep it simple:
- Records. Keep supplier invoices and a one-page supplier contact list, with out-of-hours numbers.
- Market stalls. Check alerts before each trading day, and keep recalled stock in a labelled box.
- Online. Remove the listing, pause click-and-collect and post the notice on your site.
- Not sure? The FSA guidance suggests asking your enforcement authority, and a Primary or Home Authority where you have one, whether your system is appropriate.
How can a shop prepare before a recall happens?
The FSA guidance recommends a written plan, a contacts list (its Annexe Ei), a named person and deputy for recall communications, and a decision log. It suggests reviewing the plan and traceability yearly, ideally with a mock exercise. After an incident, the FSA recommends a root cause analysis to find out why it happened. Recall readiness also fits inside a HACCP-based system; see our HACCP explained guide. Treat it with care: the PDF is dated March 2019, its review date of March 2020 has passed, and it cites pre-Brexit EU law.
Which training helps shops and food businesses handle recalls?
Nexis CPD courses are CPD-accredited awareness training, not Ofqual-regulated qualifications, and they support rather than replace your procedures, your local authority’s advice and practical supervision. We do not offer a Level 3 food safety course. They are general food safety training, not a course on running a recall, which belongs in your own written plan. If your employer or council asks for a specific qualification, check what it accepts before you enrol. Three courses fit most shops:
Together they cost £18 rather than £27 under the pay-for-2-get-3 offer. If you train 5 or more staff, team places cost £6 a course place, with places lasting 12 months.
Food Safety and Hygiene (Retail) Level 2
100% online, at your own pace. Pass the assessment and your verifiable certificate is emailed instantly.
Frequently asked questions
What is the difference between a food recall and a withdrawal?
A withdrawal removes unsafe food from the supply chain before it reaches consumers. A recall also asks consumers to act, for example to return or dispose of the food. Shops withdraw stock still on shelves, and take part in a recall when packs have already been sold.
Do shops have to put up a recall notice?
Article 19(1) puts the duty to inform consumers on the business that produced, imported or distributed the food. The FSA guidance lists issuing the point-of-sale notice and helping consumers return food as a retailer action in a recall, so display it where the recalling business or supplier asks.
Can a shop sell recalled food if it is still in date?
No. A date does not make food safe. Article 14(6) presumes the whole batch unsafe, and holding food for sale counts as placing it on the market. Remove every pack with an affected batch code and keep it apart.
Do I have to tell the local authority when I withdraw a product?
Article 19(3) requires any food business to inform the competent authorities immediately if it believes food it placed on the market may be injurious to health. If you are simply acting on a supplier’s recall, the recalling business normally notifies, but ask your local authority.
Do I have to keep a record of what customers bought?
No. The FSA guidance says retailers are not required to keep traceability information about sales to final consumers. You must record suppliers and any other food businesses you supply, so you can identify them on demand.
Can I give recalled food to a food bank?
No. Unsafe food must not be placed on the market, and placing on the market includes transfers free of charge. The FSA guidance says unsafe food that cannot be made safe must be treated as food waste.
How do I get food recall alerts?
The FSA’s sign-up page offers email alerts for food and allergy notices. In Scotland, Food Standards Scotland runs its own free email and text alert service. Use a shared shop address, so one person’s absence does not delay action.
General information, not legal advice — check with your local authority’s food safety team. Based on assimilated Regulation (EC) No 178/2002, the Food Safety and Hygiene (England) Regulations 2013, the General Food Regulations 2004 and the Northern Ireland equivalent, the Food Safety Act 1990, the FSA and FSS withdrawals and recalls guidance (March 2019) and the FSA alerts site, as checked on 29 October 2026. Nexis CPD courses are CPD-accredited awareness training: they are not Ofqual-regulated qualifications and do not replace your own food safety procedures, your local authority’s advice or practical supervision.