MSU Extension Product Center

For packaged food and beverage businesses, a product recall is one of the most challenging situations you may face — but preparation can make all the difference. One of the most effective ways to protect your business, your customers and your brand is by conducting a mock recall.

Michigan State University Extension and the MSU Product Center encourage entrepreneurs not only to develop a recall plan, but to actively test it through simulated exercises. The U.S. Food and Drug Administration (FDA) also offers industry guidance and resources on recalls.

What Is a mock recall?

A mock recall is a simulated exercise designed to test your company’s ability to quickly identify, trace and remove a product from the marketplace if a safety issue arises.

Think of it as a fire drill for your food safety system. Instead of reacting during a real crisis, a mock recall allows you to evaluate your preparedness in a controlled environment before consumer safety and your reputation are at risk.

Why mock recalls matter

The MSU Product Center emphasizes that food and beverage businesses must be prepared to respond quickly and effectively to a recall situation, and mock recalls are a key part of that preparation.

A well-designed mock recall helps your business:

• Test traceability systems: Can you track ingredients “one step back” to suppliers and “one step forward” to customers?
• Identify gaps in recordkeeping: Mock recalls often reveal missing or incomplete documentation.
• Strengthen response time: Every minute counts when removing unsafe product from the market.
• Clarify roles and communication: Your recall team must know exactly what to do and when to do it.
• Improve overall food safety readiness: Regular practice builds confidence and consistency across your team.

Key components of a strong recall plan

Before running a mock recall, make sure your business has a documented recall plan. An effective plan should include:

• A designated recall team and coordinator
• Procedures to identify the problem and affected products
• Recall classification and risk assessment
• A communication plan (internal, regulatory, customer, and public/media)
• Distribution list/consignee management
• Methods for product recovery, control and disposition
• Recordkeeping systems to track product movement
• Mock recall/recall testing
• Effectiveness checks
• Root cause investigation and corrective actions
• Recall termination procedure

What happens during a mock recall?

While each exercise can vary, most mock recalls include a few core elements:

1. Create a realistic scenario
   Example: allergen mislabeling, contamination or supplier issue.
2. Activate your recall team
   Notify team members and begin documenting actions and timelines.
3. Trace the product
• Backward to ingredient suppliers
• Forward to distributors, retailers or customers
4. Reconcile quantities
   Account for all product produced, in inventory and distributed.
5. Evaluate performance
   Identify breakdowns in traceability, communication or documentation and make improvements.

Additional record keeping requirements for high-risk foods

Some foods are considered higher risk because they have been linked to more foodborne illness outbreaks. For these foods, the FDA has created extra recordkeeping rules so that, if something goes wrong, the product can be traced and removed from the market quickly.

Which foods are high-risk? The FDA keeps a list called the Food Traceability List (FTL). Foods on this list include:

• Certain cheeses
• Shell eggs
• Nut butters
• Fresh herbs
• Leafy greens
• Fresh‑cut fruits and vegetables
• Cucumbers, melons, peppers, tomatoes
• Sprouts
• Tropical fruits
• Finfish and shellfish
• Ready‑to‑eat deli salads

If you make, process, pack or store any of these foods, the extra rules apply to you — no matter where the food came from (U.S. or imported). The goal is to help FDA quickly find and remove contaminated food before people get sick. Better records mean faster traceback, fewer illnesses and fewer deaths.

Some businesses and situations are exempt. You can find the full list in CFR 1.1305, and the FDA also provides an Online Tool to help you figure out whether the rule applies to you.

When do these rules take effect? FDA finalized the Food Traceability Rule in November 2022 (21 CFR Part 1, Subpart S). The rule became effective in January 2023, but the FDA has proposed moving the compliance date to July 20, 2028, to give businesses more time to prepare. This rule is a major part of the FDA’s “New Era of Smarter Food Safety,” which focuses on better tracking, tracing and recordkeeping across the food system.

Common implementation issues

There are many common issues that facilities run into when writing a recall plan and conducting a mock recall. When writing a recall plan, many rely on generic “fill-in-the-blank” recall plans found online, but struggle to put them into practice.

Some of the most frequent gaps include:

• Crisis response: Mock recalls that focus almost entirely on traceability, without meaningfully testing the firm’s crisis response. Key elements of a crisis response are:
  • How an issue is identified and communicated internally
  • Whether it reaches the right decision-makers
  • How quickly the team can respond who serves as backups for critical roles
  • What actions and documentation are required at each step
  • When and how regulators or the public are notified
• Accounting for all materials: Traceability exercises that do not account for all materials. Common omissions of materials include primary packaging, product inserts, food-grade chemicals, bulk items sourced through distributors or materials purchased locally for last-minute needs.
• Accounting for new materials: Failure to incorporate newly introduced raw materials/ingredients into traceability testing, leaving gaps in the system as operations evolve.
• Traceability testing: Exercises that test only one direction of traceability. Some firms conduct forward tracing from finished product to customers, while others only trace backward to raw material sources, rather than verifying both directions as part of a complete system.
• Mass balance systems: Firms may be unable to demonstrate that the quantity of finished product aligns with the raw materials used. This often stems from not tracking materials by weight at receiving or failing to fully account for rework, waste, samples or direct-to-consumer sales. This reflects a lack of systems to support mass balance (100% reconciliation).
• Depth and frequency of mock recall: Not testing the recall plan often enough — or only testing part of it — leaves the team unprepared. If you only run one mock recall a year, or you only trace ingredients but ignore packaging and other materials, your staff won’t get the practice they need to respond quickly and correctly during a real recall.

These gaps are less about having a written plan and more about ensuring the plan is realistic, practiced and fully integrated into day-to-day operations.

How often should you run a mock recall?

All food and beverage facilities are encouraged to have a written recall plan, even if they are not required to do so by the regulating agency. If your company operates under a third-party standard, follow those standards for the required frequency. Otherwise, best practice is to run a mock recall at least once per year. You should run mock recalls more frequently if you launch new products, add new suppliers or ingredients, change packaging or labeling, or experience significant business growth.

Support from the MSU Product Center

The MSU Product Center provides guidance to help Michigan food entrepreneurs build and strengthen their recall and food safety systems. The “Regulatory and Food Safety Overview” online course covers recall procedures in addition to food safety principles and regulations.

If you haven’t reviewed your recall plan recently — or have never conducted a mock recall — now is the time to start. These exercises are not just for compliance; they are a critical step in protecting public health and ensuring your business is ready to respond when it matters most.

The MSU Product Center leverages Michigan State University’s extensive expertise in food, agriculture and natural resources to help entrepreneurs define, develop and successfully launch innovative products. Through business counseling, technical assistance, educational programming and market access opportunities, the MSU Product Center plays a critical role in strengthening Michigan’s food and agriculture economy.

To learn more about the MSU Product Center and its programs, visit
canr.msu.edu/productcenter.