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This article applies to selling in: India

Food Recall Execution – Seller policy

Purpose of the Policy

The guidelines for the Food recall is laid down in Food Safety and Standards (Food Recall Procedure) Regulations, 2017.

Reference

This Food Recall Policy (“Policy”) intends to lay down the purpose and procedure of Amazon Seller Service Pvt. Ltd. (“ASSPL”) to recall products/items from the food chain, including in the event of any such product/item being declared as unsafe. For the purpose of this policy, the word “unsafe food” shall have the same meaning as mentioned in the Food Safety and Standard Act, 2006. For the purpose of this Policy, food business operator (“Seller”) shall mean and include the associate operators who sell food products on ASSPL’s platform.

Initiation of the food recall process:


  1. The Seller shall follow food recall procedure including complete process of recall, post-recall report, and follow-up action in order to ensure the effectiveness of the recall and prevent recurrence.
  2. The Seller shall initiate a recall process to fulfil his responsibility in accordance with section 28 of the Food Safety and Standard Act.
  3. The Chief Executive Officer, Food Safety and Standards Authority of India or the Commissioner of Food Safety of the State or Union territory, or both, or ASSPL may direct the Seller to initiate the recall process.
  4. The recall process shall also be initiated as a result of reports or complaints referred to the Seller from any stakeholder and if food business operator determines that there is a need to recall.
  5. It is the responsibility of all the Seller in the entire food chain to implement the instructions relating to food recall. Failure to do so shall render the Seller liable to action as provided under the Act or the rules or regulations made thereunder.

Roles and responsibilities:

The responsibilities of the Seller shall include the following:

  1. The Seller shall have procedures and systems in place to identify the food businesses to whom they have supplied their food.
  2. The Seller shall collaborate with ASSPL and the Commissioner of Food Safety of the State or Union territory or the Food Authority on action taken to avoid or reduce risks posed by the specific batch or lot or code of food, which they supply or have supplied.
  3. The Seller shall remove the food from sale or distribution, when requested by ASSPL or the Commissioner of Food Safety of the State or Union territory or the Food Authority, as the case may be. Please refer to Appendix II for format to share product details to food businesses.
  4. It is the sole responsibility of the Seller to maintain the food distribution records which include the names and addresses of suppliers and customers, nature of food, date of purchase, date of delivery, lot number, batch code, pack size, brand name, date of manufacture, date of expiry and best before date, and shall maintain such records for a period of one year from best before date or the expiry date, as applicable. The chart mentioned in Annexure – I contains the responsibility and accountability of ASSPL and the Seller during the food recall execution.
  5. The Seller shall also maintain and implement a step-wise process for recalling food products declared as unsafe. The formulated plan shall be in accordance with the Food safety management guidelines as laid down by the Food Safety and Standards Authority of India (“FSSAI”). The Seller shall co-ordinate and share the recall plan with ASSPL and relevant statutory authorities.
  6. Recall Communication: The Seller shall ensure that the recall communication is shared in the appropriate manner with others involved in the food chain and with the customers. The Recall Communication shall be through written communication, phone, e-mail, fax, print media, electronic media (TV or Radio or Internet or combination) or a combination thereof and in case of written communication it shall be conspicuously marked “Food Recall”. The communication shall also be marked “urgent” and telephone calls or other personal communication shall be confirmed by one of the above methods and documented in an appropriate manner.
  7. Recall Report: If the food product is considered ‘unsafe’ and if the product is recalled, then the Seller shall create a periodic report of the recall process under progress and shall report weekly to the statutory authorities and to ASSPL.
  8. Recovery of the food product: The Seller shall store the recovered food in an area which is separated from any other food and is identified by a label plate including prominently that “RECALLED PRODUCT NOT FIT FOR HUMAN CONSUMPTION”. The Seller shall also maintain accurate records of the recovered food including their lot number, batch code, pack size, brand name, date of manufacture, date of expiry, best before date, and all the related data. Proper recording system shall be available to ensure that recalled food is retrieved and its details are recorded.
  9. Post recall follow up: The Seller shall submit a post recall report to the FSSAI within the 30 days’ time period as stipulated in Section 13 of Food Safety and Standards (Food Recall Procedure) Regulations, 2017. The Seller shall also provide ASSPL with the post recall report within 30 days.

Annexure I - RACI* chart for food recall execution:

Activity Amazon Seller Amazon Legal
Register recall case A R C
Send Recall communication R A C
Suppress Retail and 3P offers R A I
Cancel CX orders R A I
Cancel PO R A I
Seller messaging A I C
Inventory RTV process I R/A I

*R – Responsible, A – Accountable, C – Consulted, I – Informed

Annexure II – Format of sharing Product details:

S.No. Subject Particulars
1. Name and Address of the food business operator
2.

Name, Designation and Contact details of the person who should be contacted

3. Reason for Recall
4.

Identity of the implicated food

a. Name of the food
b. Brand name
c. ASIN
d. Quantity with ASSPL
5. Date and circumstances under which need for food recall was discovered
6. Quantity of implicated product sold to the food business operator. Inventory
a. Quantity ordered from seller (as per Purchase Orders)
b. Quantity received from seller (as per Purchase Orders)
c. Quantity remaining at Fulfilment Centres (FCs)
d. Quantity at ATSPL
e. Inventory Recovery %
f. Quantity delivered to customers
7. Proposed communication and means/ proposed means of communication
8. Nature of violation of the provisions of the Act, Rules or Regulations made thereunder
9.

Name, designation, address and

telephone number of the person reporting the problem

10. Has any testing been undertaken; If yes, results thereof
11. Duration of food business for this product in Amazon
12. Action already taken and Proposed plan for recall a. Website suppression
b. Cancel customer orders
c. Cancel PO
d. Block Auto PO
e. Customer messaging
f. Seller messaging
g. Virtual Inventory reconciliation
h. Physical inventory reconciliation
i. Inventory removal and disposal

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