A comparative analysis of national food recall systems

摘要

Food recall and withdrawal is a fundamental tool for risk management and different countries stated the mandatory application of a system for food; the present work is an analysis of different systems applied in different countries. The main objective of analysed systems is the consumer’s health protection through an audit system and the application of system to rapidly recall/withdraw food on the part of producers. The comparative analysis of different national systems [i.e. European Union (EU), Australia, Canada, US and China] shows differences both of the terminological and legal aspects; the words recall and withdrawal have different meaning in EU legislation than in other counties’ legislations; from a legal point of view, two main recall/withdrawal systems could be identified: a mandatory one (EU and China) and a voluntary one (USA, Canada and Australia); all the investigated systems have a co-operative approach between authority and food business operator, but different functions on their respective roles could be identified.