How to Run a Mock Recall. It's Been Required Since July 2023

Since 1 July 2023, food businesses in New Zealand with a plan or programme under the Food Act have been required to conduct at least one mock recall per year. Despite this, a significant number of food businesses either don’t know about the requirement or haven’t got around to doing one.

Important: if your business only sells food for immediate consumption (restaurants, cafes, takeaways), you are exempt from the mock recall requirement. The requirement applies to businesses that sell packaged food, wholesale food, or have a mixed scope (for example, a cafe that also sells packaged coffee beans). If any part of your operation involves food that isn’t consumed immediately on your premises, the requirement applies to you.

If the requirement does apply, your verifier will ask about it. If you can’t show evidence of a mock recall in the past 12 months, that’s a problem.

Why Mock Recalls Matter

A real recall is a high-pressure situation. You need to trace a product through your supply chain, identify where it went, and get it off shelves, often within hours. A mock recall tests whether your traceability systems actually work before you’re under that pressure.

MPI requires mock recalls because paper-based traceability records often have gaps that only become apparent when someone tries to use them. A supplier invoice might be missing, a batch number might not link to a dispatch record, or your contact list for customers might be out of date.

How to Run a Mock Recall

Step 1: Pick a Product

Choose a specific product and batch. It doesn’t have to be a product with any actual issue. You’re testing the process, not responding to a real problem. Select something you’ve produced or handled recently so the records are current.

Step 2: Trace Forward

Starting from that batch, trace where the product went. Which customers received it? What quantities? When was it dispatched? Can you identify every recipient?

For FCP businesses, you need to be able to trace one step forward (who you supplied to) and one step back (where your ingredients came from).

Step 3: Trace Backward

Take the same product and trace its ingredients back to your suppliers. Can you identify the supplier, the batch or lot numbers of incoming ingredients, and when you received them?

Step 4: Time It

Record how long the trace takes. MPI’s expectation is that you can complete a trace within four hours during business hours. If it takes you two days to dig through paper files, your system needs work.

Step 5: Document Everything

Record the results of your mock recall:

• Date of the exercise
• Product and batch selected
• Forward trace results, including who received the product, quantities, and dates
• Backward trace results, including supplier details, ingredient batches, and receipt dates
• Time taken to complete the trace
• Gaps identified, such as anything you couldn’t trace or took too long to find
• Corrective actions, covering what you’ll fix before the next mock recall

Step 6: Fix the Gaps

The point of a mock recall isn’t to produce a perfect result. It’s to find the holes in your system and fix them. If you couldn’t trace an ingredient back to a supplier, that’s a traceability gap you need to close. If your customer contact list was wrong, update it.

Common Mistakes

• Not doing one at all. The most common issue. If you haven’t done a mock recall in the past 12 months, schedule one now.
• Picking an easy product. Choose something with multiple ingredients and multiple customers. Testing your simplest product doesn’t stress-test your systems.
• Not recording the results. A mock recall you can’t prove happened is the same as one that didn’t happen. Document it.
• Not fixing the gaps. Finding problems is only useful if you address them. Your verifier will want to see corrective actions, not just a list of issues.

What Your Verifier Wants to See

At your next verification visit, your verifier may ask to see evidence of your most recent mock recall. They’ll want to see:

• That you conducted one within the past 12 months
• The documented results (product, traces, time taken)
• Any gaps identified and the corrective actions you took

If you’re using Verify, mock recall records are built into the system. If you’re paper-based, keep the documentation in your FCP folder where your verifier can find it.