a Real Example of a food recall involving undeclared allergen contamination
Food recalls often appear straightforward, but in practice they can be complex, particularly when multiple suppliers and international manufacturing are involved.
This example outlines a real recall situation involving an imported food product and undeclared allergen contamination, and highlights some of the key issues that can arise
What Happened
A food product was being manufactured overseas and imported into New Zealand and other markets. Due to increasing demand, production was moved to a different facility to increase capacity.
The issue arose because the new manufacturing facility also handled products containing a high-risk allergen. This introduced a risk of cross-contamination.
The product included a precautionary allergen statement (“may contain”), which is commonly used where there is a low-level risk of cross-contact. However, this situation turned out to be more serious than initially expected.
The Problem
Testing showed that the product did not contain trace levels of the allergen—it contained significant levels.
At that point, the precautionary statement was no longer appropriate. From a food safety perspective, the product needed to be treated as if the allergen was present as an ingredient.
This created a number of issues:
- the label did not reflect the true risk
- consumers were exposed to a potentially serious allergen
- regulatory action was required
Reports of adverse reactions in another market triggered further investigation and involvement from food safety authorities.
⚠️ Key Issue
The contamination level meant the product could no longer rely on a “may contain” statement.
Regulatory Response
Food safety authorities work closely across jurisdictions and share information when risks are identified.
Once the issue was confirmed, the New Zealand importer was required to take action. This included:
- updating allergen declarations
- managing affected stock
- communicating the risk to consumers
One of the key challenges was how to communicate the change in allergen status.
Although the allergen was not intentionally added as an ingredient, the level of contamination meant the product needed to be treated as if it contained the allergen.
Authorities required:
- a clear “contains” declaration
- and, in some cases, a front-of-pack statement indicating a change in allergen status
📌 Regulatory Note
Authorities required immediate relabelling and consumer communication.
Why This Matters
This situation highlights an important point:
A “may contain” statement is only appropriate where there is a low and uncertain risk of cross-contact.
Where there is clear and significant contamination, the product must be treated differently, even if the allergen is not intentionally added.
It also shows why changes in allergen status need to be clearly communicated. Consumers may rely on previous experience and not check labels every time, particularly where they believe a product to be safe.
✅ Key Insight
Labelling must reflect actual risk — not just intended formulation.
Practical Challenges in Recalls
From the importer’s perspective, recall situations are often difficult to manage.
Common challenges include:
- incomplete or unclear information from suppliers
- difficulty verifying overseas manufacturing practices
- communication gaps between regulators, suppliers, and importers
- uncertainty about what actions are required
In many cases, it may not be possible to fully verify what has happened at a manufacturing site. Decisions often need to be made based on available evidence and risk assessment.
⚠️ Key Risk
Importers are often forced to make critical decisions without being able to fully verify what happened at the manufacturing site.
What This Means for Food Businesses
This example highlights several key points:
- Allergen risks must be properly understood and controlled
- Precautionary labelling must reflect actual risk
- Supply chains introduce additional risk, particularly where production changes
- Clear communication is critical when something goes wrong
Most importantly, it shows how quickly a situation can escalate when a product does not match its labelling.
✅ Key Insight
Most recall events are driven by breakdowns in process control, communication, or verification — not intentional decisions.
Where Mock Recalls Fit In
Situations like this are exactly why mock recalls are required.
A mock recall helps you test whether you can:
- identify affected products
- assess the risk
- communicate clearly
- and take appropriate action
Without a structured approach, these situations can become confusing and difficult to manage.
📌 Why This Tool Matters
Mock recalls allow businesses to test their response systems before a real incident occurs — reducing risk and response time.