How to run a mock recall
in a food factory, step by step.
A mock recall is a fire drill for your traceability system: pick a real batch, pretend it's contaminated, and prove, with documents, not confidence, that you can find every kilogram of it before it reaches a consumer. Here is the full procedure we use with Irish producers, including the timing targets auditors actually apply.
What a mock recall is, and what it is not
A mock recall is a documented simulation of a product recall. You select one batch (or one raw-material lot), assume it is unsafe, and then execute your traceability and recall procedures for real: identify affected production, identify every customer who received it, reconcile the quantities, and produce the paperwork, all against the clock.
It is not the same thing as a traceability test, although the two overlap and are often run together. A traceability test proves your records can connect a lot to its inputs and outputs. A mock recall additionally tests the decision-making and communication side: who convenes the recall team, who would call the customers, who would notify the FSAI, who drafts the notice. BRCGS Food Safety BRCGS traceability requirements treats these as related but distinct requirements, traceability is tested under clause 3.9, and the withdrawal/recall procedure is tested under clause 3.11.
The distinction matters in an audit. A producer who can trace a batch in twenty minutes but has no evidence of ever rehearsing the recall decision chain will still pick up a non-conformance.
How often you need to run one
BRCGS expects the traceability system to be tested at least annually, and the product withdrawal and recall procedure to be tested at least annually as well. Many retailers' own supplier standards ask for more, twice a year is a common contractual requirement for own-label suppliers, and some specify that at least one exercise per year must include a raw material or packaging lot, not just finished product.
In practice, producers who run a short mock recall quarterly find audits dramatically less stressful than those who scramble once a year. The exercise takes an afternoon when your records are in order, and exposes exactly where they are not when they aren't.
The step-by-step procedure
- 1Nominate the lot, and log the start timeHave someone other than the QA manager choose the batch: a production date and product picked semi-randomly, ideally one with multiple customers and at least one export or private-label dispatch. Write the start time down immediately, the clock is part of the evidence.
- 2Define the scenarioGive the exercise a realistic trigger: "supplier notified us that milk delivered on the 14th failed an antibiotic residue test" or "a customer complaint of foreign material in lot B-247". The scenario decides whether you trace forward from a raw material or backward from finished product, do both across the year.
- 3Trace backward (one step up)Identify every raw material and packaging lot that went into the affected batch: supplier names, delivery dates, supplier lot codes, quantities, and the goods-in records (including COAs) for each.
- 4Trace forward (one step down)Identify every dispatch that contained the affected batch: customer, delivery address or depot, dispatch date, dispatch-note number and quantity per line. Include transfers to other sites, samples sent out, and product sold at farm gate or markets, these are the ones spreadsheets miss.
- 5Reconcile the mass balanceQuantity produced must equal quantity dispatched + quantity in stock + waste/rework/samples. BRCGS expects the reconciliation to land within a tolerance your procedure defines, many producers work to ±1–2%. An unexplained gap is a failed exercise, even if every dispatch was found.
- 6Simulate the communicationsDraft (do not send) the customer notification and the FSAI notification. List the phone numbers you would call, in order. If a real recall touched retail, the FSAI expects notification without delay, Article 19 of EU food safety regulations places that duty on the food business operator, not on the retailer.
- 7Record the end time and write it upThe report should state: scenario, lot, start/finish times, quantities reconciled, percentage recovery, every document referenced, the people involved, and, critically, what did not work and the corrective action for it. A mock recall that finds no weaknesses is usually a mock recall that was not honest.
What the final report must contain
The five most common mock recall failures
Doing this in spreadsheets vs. doing it in a system
Everything above is achievable in Excel, producers pass BRCGS audits on spreadsheets every year. The cost is time and fragility: a typical spreadsheet-based mock recall takes half a day of cross-referencing goods-in books, make sheets and dispatch folders, and it depends on the person who built the spreadsheets being available and the VLOOKUPs being intact.
In Keystone, the same exercise is a single action: pick the batch, and the full chain, supplier deliveries upstream, dispatches and customer branches downstream, with quantities, renders in under 30 seconds, exportable as a signed PDF. The mass balance is computed from the same records, so the reconciliation is arithmetic, not archaeology. Producers who moved off spreadsheets typically compress the whole documented exercise from an afternoon to under 90 minutes, most of which is writing the narrative report.
- Run at least one traceability test and one recall-procedure test per year, quarterly if you supply own-label retail.
- Log start and finish times: BRCGS expects full traceability with mass balance within 4 hours.
- Mass balance must close within your stated tolerance, unexplained quantity gaps fail the exercise.
- Test both directions across the year: raw material forward, finished product backward.
- Document the gaps honestly, the corrective-action section is what auditors respect most.
Frequently asked questions
Is a mock recall the same as a traceability test?
How long should a mock recall take?
Do I have to notify the FSAI for a mock recall?
What batch should I pick for the exercise?
What does a failed mock recall mean for my audit?
See this done in software, on real production data.
Keystone runs the full chain, supplier delivery → batch → dispatch → customer, in under 30 seconds. 20-minute discovery call, no sales pitch.