Guide · Traceability & recall

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.

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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 Issue 9 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 Issue 9 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 4-hour benchmark: BRCGS Issue 9 expects the traceability test — from the moment the lot is nominated to full reconciliation — to be achievable within 4 hours. Most retailer technical teams apply the same benchmark to mock recalls. If your last exercise took two days of spreadsheet archaeology, that is the finding an auditor will write up.

The step-by-step procedure

Nominate the lot — and log the start time — Have 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.
Define the scenario — Give 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.
Trace 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.
Trace 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.
Reconcile the mass balance — Quantity 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.
Simulate the communications — Draft (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 Regulation 178/2002 places that duty on the food business operator, not on the retailer.
Record the end time and write it up — The 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

Scenario and scope — Trigger, product, lot code(s), production date(s), and whether the trace ran forward, backward or both.
Timing evidence — Start time, time full traceability was achieved, time mass balance closed. Auditors compare this against the 4-hour expectation.
Mass balance table — Produced vs dispatched vs stock vs waste/samples, with the % reconciliation and your tolerance.
Customer list — Every customer and depot that received the lot, with quantities and dispatch-note references.
Document trail — Goods-in records, batch/make-day records, QC results, dispatch notes — referenced by number so an auditor can pull any of them.
Gaps and corrective actions — Anything slow, missing or ambiguous, with an owner and a due date. This section is what turns the exercise from a box-tick into a system improvement.

The five most common mock recall failures

1 · Rework and samples ignored — The batch went 96% to customers and 4% into next week's rework — and the rework path is untracked. Mass balance never closes.
2 · Private-label codes untraceable — The retailer's own SKU code appears on the dispatch note, your internal code appears in production records, and no document links the two.
3 · One person holds the map — The exercise works only when the production manager is in the building. Auditors increasingly test this by asking someone else to run the trace.
4 · Timing not recorded — The trace was done, but nobody wrote down how long it took — so there is no evidence the 4-hour expectation is met.
5 · No test of the recall decision chain — Traceability worked, but there is no record of who would decide, who would call the FSAI, or what the customer notice would say.

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.

Key takeaways

In one glance.

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 Issue 9 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.

FAQs

Frequently asked.

Is a mock recall the same as a traceability test?

No. A traceability test proves your records connect a lot to its inputs and outputs. A mock recall also rehearses the recall decision-making and communications — who convenes the team, who notifies customers and the FSAI. BRCGS Issue 9 covers them under separate clauses (3.9 and 3.11) and expects both to be tested at least annually.

How long should a mock recall take?

BRCGS Issue 9 expects full traceability, including a mass balance, to be achievable within 4 hours. Well-run exercises on good records finish comfortably inside that; system-based producers routinely finish the trace itself in minutes.

Do I have to notify the FSAI for a mock recall?

No — a mock recall is internal and nothing is sent externally. You draft the notifications as evidence. In a real event, Article 19 of EU Regulation 178/2002 requires you to notify the competent authority without delay if unsafe food has left your control.

What batch should I pick for the exercise?

One that stresses the system: multiple customers, ideally an export or private-label dispatch, and at least one complication such as rework or a split pallet. Have someone other than the QA manager nominate it so the exercise is credible.

What does a failed mock recall mean for my audit?

A documented exercise that found gaps and closed them with corrective actions is good evidence, not bad. What fails audits is no exercise, no timing evidence, or a mass balance that silently does not add up.