By S&S Co. Advocates & Solicitors · Published 24 September 2026 · Informational content, not legal advice — see our disclaimer
Who Must Maintain a Recall Plan
Every food business operator engaged in manufacture, import, or wholesale supply of food — as distinct from retailers — must maintain an up-to-date, written food recall plan as part of its compliance obligations under the Food Safety and Standards (Food Recall Procedure) Regulations. This obligation attaches to the business's role in the supply chain: a retailer selling directly to consumers is not the party expected to hold this documented recall capability, but the manufacturer, importer or wholesale distributor further up the chain is.
When the Duty to Recall Is Triggered
The obligation to act is self-triggering: it arises from the food business operator's own belief or knowledge that food it has manufactured, processed, distributed or imported does not comply with food safety requirements. Once that belief or knowledge arises, the operator must immediately initiate recall procedures covering the food from the point it left that operator's immediate control, and must inform the competent authority — the Food Safety Commissioner or the Designated Officer for the relevant jurisdiction.
This means an FBO cannot simply wait for FSSAI to identify a problem and direct a recall — the primary obligation to self-initiate arises the moment the operator itself becomes aware of non-compliant food, and delay in acting on that awareness is itself a compliance failure.
Recall Classification and What the Recall Plan Should Contain
Recalls are classified by hazard severity, which determines both the urgency and the depth of the recall required, and the information FSSAI expects to see in the resulting recall report. A well-constructed recall plan should identify the recall coordinator and team responsible for executing it, maintain traceability records — batch and lot numbers, distribution records — sufficient to identify precisely which units are affected and where they were sent, set out the method for communicating the recall to distributors, retailers, and, where appropriate, the public, and specify the disposal or corrective-action procedure for recalled stock.
The precise number and definition of hazard-severity classes has been described somewhat inconsistently across regulatory guidance issued over different years, so an operator building or updating its recall plan should confirm the current classification framework directly against FSSAI's currently applicable Food Recall Procedure Regulations, rather than relying on an older circular that may since have been superseded.
FSSAI's Own Oversight Role
FSSAI retains its own oversight and can itself direct or monitor a recall through the Food Safety Commissioner or Designated Officer, operating alongside — not instead of — the food business operator's independent obligation to self-initiate a recall on becoming aware of non-compliant food. Failing to recall unsafe food promptly can expose the operator to enforcement action and penalties under the Food Safety and Standards Act, 2006 in its own right, quite apart from any consequence specific to the recall failure itself, since supplying unsafe food is an offence under the Act independently of the recall obligation.
Frequently Asked Questions
Which food businesses must maintain a written recall plan?
Manufacturers, importers, and wholesale distributors of food — not retailers — under the Food Safety and Standards (Food Recall Procedure) Regulations.
What triggers a food business operator's duty to initiate a recall?
The operator's own belief or knowledge that food it manufactured, processed, distributed or imported does not comply with food safety requirements — the obligation is self-triggering and does not wait for a direction from FSSAI.
What should a food recall plan include?
A designated recall coordinator and team, traceability records (batch/lot numbers, distribution records), a method for communicating the recall to the supply chain and, where relevant, the public, and a disposal or corrective-action procedure for recalled stock.
Can FSSAI itself direct a recall?
Yes, through the Food Safety Commissioner or Designated Officer, in addition to — not instead of — the food business operator's own independent obligation to self-initiate a recall once it becomes aware of non-compliant food.
References & Further Reading
This article references the following statutory provisions. Readers should always verify current rules, fees and timelines against the applicable statute and rules as amended, since these are revised from time to time.
- Food Safety and Standards (Food Recall Procedure) Regulations, and related FSSAI guidance on recall planning.
- Food Safety and Standards Act, 2006, for the underlying offence provisions relating to unsafe food.