Key takeaways:
A recall plan is required. Testing it is not. The FDA mandates a recall plan and a Reportable Food Registry notification within 24 hours of confirming a hazard, but it doesn’t require a mock recall.
Recalls are getting more severe and more tangled. Hospitalizations and deaths from recalled food both doubled in 2024, and single contamination events now cascade across dozens of brands and hundreds of products.
Speed in the first 24 hours decides the outcome. When FSMA 204 enforcement begins in 2028, processors will need to produce full traceability records within a day. The companies that can do that already run timed mock recalls and fix the gaps those drills expose.
Hospitalizations from recalled food more than doubled in 2024, climbing to 487 from 230 the year before, and deaths rose to 19 from eight. While the total number of recalls hardly changed, they caused significantly more harm.
If a recall hit your plant tomorrow, would your team be able to fully execute the plan sitting in your binder? Most processors have a recall plan, but how many run it under pressure to see how well it works?
A plan on paper isn’t the same as a plan that works
The regulatory baseline is lower than many assume. Under the FDA’s Preventive Controls rule, a facility whose hazard analysis identifies a hazard requiring a preventive control must maintain a written recall plan, with procedures to notify consignees, alert the public when needed, run effectiveness checks, and dispose of recalled product. Once a hazard is confirmed, a responsible party must also report it to the Reportable Food Registry within 24 hours. The rule doesn’t require any test of that plan. A mock recall, the drill that reveals whether the plan works, is optional.
However, GFSI-benchmarked standards, the ones behind SQF, BRCGS, and FSSC 22000 certification, do require a full mock recall at least annually. For the many processors who hold one of those certifications, the drill is already an obligation. For those who don’t, it’s a discipline they have to choose.
A plan can name the recall team, list the notification steps, and still fall apart the first time it meets a real lot tracing problem. The only way to know whether a plan works is to run it before the stakes are real. The written document is the starting point, not the finish line.
Untested plans aren’t ready for ingredient-driven recalls
The case for testing the plan grows stronger as recalls grow more tangled. In 2024, a Listeria-related recall of frozen waffles and pancakes spread across more than 40 brands and 240 products, because the same contaminated input fed dozens of downstream labels. A Salmonella outbreak tied to cucumbers cascaded into several additional recalls of other brands and products that used them.
An untested plan is no match for this kind of scenario. Shared ingredient contamination causes recall scopes to explode across customers and co-manufacturers instantly. Plans assuming single-SKU recalls fail when faced with dozens of products and retail customers. Only processors who have rehearsed multi-product, ingredient-driven scenarios can effectively navigate this chaos.
The first 24 hours is everything
The first day determines internal coordination, customer communication, and regulator confidence for the entire event. The work of that day is identifying every affected lot, locating on-hand inventory, and generating the list of customers who received the product.
This is also where regulation is heading. Under FSMA 204, set to take effect in July 2028, companies handling foods on the FDA’s Food Traceability List will need to produce full traceability records, the key data elements tied to each critical tracking event, within 24 hours of a request. A plant that can’t trace a lot quickly today will be a plant out of compliance then. The mock recall is where that 24-hour capability is refined and proven.
The most common failures these drills expose include broken links between ingredient lots and finished goods, inconsistent lot coding across facilities, and trace records that stop at the dock when a distributor renames a SKU or drops lot information.
What a recall drill must test
A mock recall earns its place only if it’s realistic, timed, and documented against clear success criteria. A drill that everyone knows is coming and that targets an easy single product proves little. The ones that build real readiness:
Trace in both directions. Test backward from a finished product to its ingredients and suppliers, and forward from a raw material to every product, customer, and location it reached. Recalls travel both ways.
Time it, and account for everything. Set a target for completing the trace, and require 100% lot accountability. Locating 95% of a batch means there’s a gap that a real recall would expose as missing product on a shelf.
Rotate the scenario. Alternate ingredient-driven, customer-driven, and finished-product-driven drills so you test different parts of the system rather than the same easy path each year.
Test the communication tree. Verify that contact information for the recall team, suppliers, and customers is current, because a perfect trace is worthless if the calls don’t go through.
Document the gaps and fix them. The output of a drill is a list of what broke and a plan to repair it before the next one. A mock recall that finds nothing wrong probably wasn’t challenging enough.
Readiness is a brand decision
The cost of an untested plan isn’t only regulatory. Consumers remember. In a 2025 survey commissioned by GS1 US, 59% of consumers said they’re hesitant to buy the same brand again after a recall, rising to 65% among millennials and 64% among Gen Z. Another 60% said they’ve avoided an entire food category after a recall. A slow, visibly chaotic recall costs more than the product pulled from shelves; it costs the customer relationships that took years to build.
A recall is one of the few crises a food company can rehearse before it happens. The plan in the binder is the easy part. Proving it works, on a clock, against a realistic scenario, with the gaps written down and fixed, is what stands between a contained incident and a brand-defining failure.
