Food Recall explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Regulations 5 to 8 are the working core of the Food Recall Procedure Regulations. They say how a recall starts (by the business or on direction), what records and speed the recall system needs, who must hold a written recall plan, and how the recall is communicated to the food chain and to consumers in a "Food Recall Notice".
This article reads the text as amended up to 18 January 2017 (the Regulations as notified; FSSAI lists no amendment as at 2 October 2026). FSSAI compendia and website copies are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in.
Every food business operator shall follow the recall procedure and initiate a recall under section 28 of the Act. The operator must submit the Schedule I information to the concerned Authority immediately, but not exceeding twenty-four hours from the time it comes to his notice that the food requires recall, and manufacturers, importers and wholesale suppliers must hold an up-to-date recall plan. Recall communication must be conspicuously marked "Food Recall" and "urgent", and a Food Recall Notice must carry the eight items printed in regulation 8(4). Manufacturers, importers and wholesalers carry the main duties. Support is available through FSSAI compliance support.
Regulation 5: initiation of the food recall process
| Sub-reg. | What it says |
|---|---|
| (1) | every food business operator shall follow the recall procedure, including the complete process of recall, post-recall report and follow-up action, to ensure effectiveness and prevent recurrence |
| (2) | the operator shall initiate a recall to fulfil his responsibility under section 28 of the Act |
| (3) | the CEO of FSSAI or the Commissioner of Food Safety of the State or Union territory, or both, may direct the operator to initiate the recall |
| (4) | a recall shall also be initiated on reports or complaints from any stakeholder if the operator determines there is a need; if the operator does not respond, the complainant or consumer may inform the CEO or Commissioner, who will determine the need and instruct the operator, who shall be bound |
| (5) | all operators in the food chain must implement the recall instructions; failure makes the operator liable to action under the Act or rules or regulations |
| (6) | if an operator refuses a directed recall, or the CEO or Commissioner has sufficient reasons to believe additional measures are needed, or determines the recall is ineffective, or believes unsafe food is continuing to be made, appropriate action under the Act, rules or regulations follows |
| (7) | a recall of imported food may also be initiated on reports of health and food authorities or information from them |
| (8) | initiation of a recall does not preclude further regulatory action under the Act |
Section 28 of the Act is named; nothing inside it is stated here. For the Act's responsibilities of manufacturers, see responsibilities of the food manufacturer under the FSS Act.
Regulation 6: operation of the food recall system
6(1) Distribution records. The operator shall maintain food distribution records covering the names and addresses of suppliers and customers, nature of food, date of purchase, date of delivery, lot number, batch code, pack size, brand name, date of manufacture, date of expiry and the date of minimum durability, for one year from that durability date or the expiry date, as applicable.
6(2) Alcoholic beverages. Where the declaration of the durability date is exempted under food safety regulations, records are kept for two years from the date or month of supply from the manufacturer.
6(3) Twenty-four hours. The operator shall submit the information specified in Schedule I to the concerned Authority immediately, but not exceeding twenty-four hours from the time it comes to his notice that the food requires recall, and initiate the recall exercise. The alert may go by the quickest means, including fax, e-mail and speed post. The Commissioner of Food Safety shall inform the CEO within twenty-four hours of receipt.
6(4) Stop and contact. The operator shall stop distribution of the food under recall and its production if necessary, without waiting for instructions, and shall contact everyone from the raw material vendor to the final consumer by written communication, phone, e-mail, fax or a combination, notify suppliers and any relevant retailer or trade association, and identify all required product details.
The twenty-four hours runs from the time the need for recall "comes to his notice".
Regulation 7: the recall plan
7(1) Who must have one. All operators engaged in the manufacture or importation or wholesale supply of food must have an up-to-date recall plan. Retailers are not required to have one unless they are also engaged in manufacture, importation or wholesale supply. A proviso exempts food service businesses such as restaurants, caterers and takeaway joints unless they run multi-outlet chains with an integrated manufacturing and distribution network.
7(2) Those without a plan. Retailers and food service businesses that need no plan shall remove the recalled stock from shelves and return it to the manufacturer, importer or wholesaler, and keep it separated and identified until disposal under the recall plan's instructions.
7(3) Content source. The recalling operator(s) shall formulate a detailed plan as part of their food safety management system as per guidelines that may be framed by the Food Authority from time to time.
7(4)-(5) Implementation. At the time of an actual recall the operator submits details of implementation to the CEO and the Commissioner, supervises the recall, assembles data and reports on completion, and ensures effective implementation as per the formulated plan.
An invented example: Shakti Biscuits manufactures and distributes through wholesalers. Under 7(1) it must hold an up-to-date recall plan. A corner shop that only retails its biscuits need not, but under 7(2) it removes recalled stock and returns it to the wholesaler. The Authority's 2017 recall guidelines are guidance, not law.
For a template record see our post on a food recall log and on traceability, one step forward and one step back.
Regulation 8: recall communication
8(1)-(3). The operator initiating a recall shall promptly inform food business operators in the chain, including consumers. Communication may be written, by phone, e-mail, fax, print media, electronic media (TV, Radio or Internet) or a combination; written communication shall be conspicuously marked "Food Recall" and also "urgent", and telephone or personal communication shall be confirmed by one of the above methods and documented. Every operator in the chain who receives a recall communication shall immediately carry out the instructions and extend the recall to all concerned stakeholders.
8(4) Food Recall Notice. The operator shall promptly inform consumers in the affected area through a press release, letters to concerned parties or advertisements in the media, in the form of a "Food Recall Notice", containing:
- name of the food business operator recalling the food;
- name of the food, brand name, pack size, batch and code number, date of manufacture, and the use-by or durability date;
- the contamination or violation, or the reason for the recall;
- a "do not consume message";
- health warning and action;
- the places or outlets where the food is found;
- the action to be taken by the consumer;
- a contact number for queries.
8(5) The operator shall respond to queries from the CEO and the Commissioner within twenty-four hours of receipt of the query; detailed data may be submitted subsequently.
The Schedules referred to here are covered in our article on regulations 14 to 16 and the Schedules. Schedule I is the recall information format that regulation 6(3) refers to. The FSSAI recall form is also discussed in the post on the E1 form for food recall notification; where it differs from the Schedules, the form names printed in the Schedules prevail.
What comes before and after
The scope and definitions are in the previous article, on regulations 1 to 4. Status reports and recovery follow in the article on regulations 9 to 13.
Need help with a recall plan?
A written recall plan, a rehearsed twenty-four hour alert and a ready Food Recall Notice make a real recall far smoother. Our FSSAI compliance support service helps manufacturers, importers and wholesalers draft the plan and records.
Key takeaways
- Operators initiate recalls under section 28 and may also be directed by the CEO or a Commissioner.
- Schedule I information goes to the Authority immediately, not exceeding twenty-four hours.
- Manufacturers, importers and wholesale suppliers need an up-to-date recall plan; retailers and food service businesses are exempt in the cases stated.
- Distribution records are kept for the periods in regulation 6(1) and 6(2).
- A Food Recall Notice carries eight printed items.
Read next
- Regulations 1–4: definitions, objectives and scope
- Regulations 9–13: status reports, recovery and termination
- Food recall log template
- Traceability: one step forward, one step back
Disclaimer: Based on the FSSAI regulations named above as consolidated in FSSAI's compendium versions or as published in the Gazette, with the later notifications the article names (consulted on fssai.gov.in on 2-3 October 2026). Later notifications and the Food Safety and Standards Act, 2006 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.