In short
- What the rule is
- Food for disposal, recalled food included, is kept separate and identified until it is destroyed, returned, reprocessed safely, or found to be safe (Standard 3.2.2 clause 11).
- Who it applies to
- Every food business. The recall system in clause 12 reaches only businesses engaged in the wholesale supply, manufacture or import of food.
- What you need to do
- Set aside unsafe, returned or recalled food, label it so nobody uses it, and deal with it promptly.
- What this does not require
- An ordinary restaurant or café that does not supply wholesale, manufacture or import needs no recall system.
What the rule says
Clause 11 of Standard 3.2.2 covers food for disposal. Food that is to be destroyed, returned to the supplier, reprocessed or checked before use is held apart from other food and identified, until it is destroyed, returned, reprocessed in a way that makes it safe, or established to be safe.
Recalled food is food for disposal. A venue handles a recall under clause 11, without a recall system of its own.
Clause 12 requires a recall system only of a food business engaged in the wholesale supply, manufacture or importation of food. The Standard's own note says so.
FSANZ says that for those businesses this means, in practice, a written recall plan, used when a recall is needed and shown to an authorised officer on request.
Who it applies to
Clause 11 applies to every food business. Clause 12 applies to wholesalers, manufacturers and importers, and can reach a hospitality business that also does one of those, such as a bakery supplying other businesses. Your local government can confirm where you stand.
By sector: Retail and Supermarkets, Cafés and Bakeries
What it looks like in practice
Keep a marked shelf or tub in the cool room and dry store for food on hold, away from food in use.
Label it with what it is, why it is on hold, and the date. Then throw it out, send it back or clear it, and note which.
Watch FSANZ's food recall alerts and your suppliers' notices. When a product you hold is recalled, set it aside at once and follow the supplier's instructions.
FSANZ cannot order a recall. State and territory food enforcement agencies can, and most recalls are started by the business that supplied the food.
What you are not required to do
- A written recall plan for an ordinary restaurant or café. Clause 12 reaches wholesale supply, manufacture and import only.
- A separate room for food on hold. The Code asks that it is kept apart from other food and identified.
Doing it in Hospitality Shield
A corrective action in Hospitality Shield can record what was set aside, why, and what happened to it, with a name and time on each step. A business that does supply wholesale can keep its recall plan with its other documents.
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Asked about this rule
Does my restaurant need a recall plan?
No, unless it also supplies food wholesale, manufactures it or imports it. Clause 12 of Standard 3.2.2 reaches only those businesses.
What do we do with recalled stock?
Keep it apart from other food and clearly identified until it is returned, destroyed, or established to be safe (clause 11).
Who can order a recall?
State and territory food enforcement agencies. FSANZ coordinates recalls in Australia but cannot order one.
Sources
- Standard 3.2.2 Food Safety Practices and General Requirements, Federal Register of Legislation
- Food recalls requirements, Food Standards Australia New Zealand
- Safe Food Australia: a guide to the food safety standards, Food Standards Australia New Zealand
General information about the rules in Western Australia. It is not legal advice. Your local government's environmental health officer decides how the rules apply to your premises.

