Recall and notification for unsafe food and feed required within 4 hours

"Immediate" action is a must in case of unsafe food and feed. This open standard from European legislation (General Food Regulation (178/2002) and Implementing Regulation (931/2011)) has recently been specified in a national Policy Rule. "Immediately" means that within 4 (!) hours after there is reason to believe that a product is unsafe, a consumer recall must be initiated. Within the same 4 hours, the NVWA (Netherlands Food and Consumer Product Safety Authority) must also be notified in relation to the source of the products and in relation to the customers of the products (1 step up and 1 step further down the chain). Companies must thus have systems and procedures in place with which this information can be provided to the NVWA upon request. Although on the basis of, among others, Good Manufacturing Practice (the animal feed industry's system for guaranteeing the quality of products), it has long been the practice to act within 4 hours, it has now become a hard and strict deadline.

Food and animal feed business operators must be able to take the right actions within 4 hours at any time. So even when you are just finishing the working day, you are called out of bed in the middle of the night and even when you are having Christmas dinner. It is only under special circumstances that this rule can be deviated from. What constitutes a specials circumstance remains to be seen....

Failure to comply with the policy rules can result in the NVWA imposing an administrative fine of €795 (for companies with 50 or fewer employees), or €1590 (for companies with more than 50 employees) per violation. It is important to be up-to-date and prepared. 4 hours flies by quickly! We are happy to help you create a plan of action.

Myrna Teeuw