Imported Food and Food Recall Information: Voluntary Recall Reporting System and Recall Procedures
Interlink編集部Imported Foods and Food Recall Information
Imported foods and food recall information refer to cases where, after food, food additives, utensils, containers, or packaging have been imported into Japan and entered domestic distribution, violations or suspected violations of the Food Sanitation Act or the Food Labeling Act are identified, and businesses handling such foods initiate voluntary recalls, notifying the authorities and making this information public.
In Japan, from June 1, 2021, the Food Voluntary Recall Reporting System based on the Food Sanitation Act and the Food Labeling Act has been introduced.
Regarding imported foods, problems may be identified even after importers receive Import Permits from customs following inspections and assessments by Quarantine Stations, through voluntary testing in Japan, notifications from overseas manufacturers, label verifications, consumer complaints, or inspections by business partners.
Therefore, importers need to establish a system to track the relevant lots, domestic inventory, sales destinations, cargo in transit, recall quantities, and disposal or return statuses even after Import Permit issuance, and to manage administrative reporting, consumer responses, and cause investigation and claims with overseas manufacturers.
Scope Covered in This Article
| Item | Contents Covered in This Article | Items Requiring Individual Confirmation |
|---|---|---|
| Food Voluntary Recall Reporting System | Purpose of the system, scope, notifying parties, submission destination, timing | Whether individual cases fall under mandatory notification |
| Imported Food | Response when problems are identified after domestic distribution | Responsibility allocation among importer, seller, and manufacturer |
| Food Sanitation Act | Foods violating or suspected of violating regulations | Individual standards and hazard assessment |
| Food Labeling Act | Omissions or errors in safety-related labeling | Whether labeling violations require notification |
| Recall Classification | Hazard severity categories Class I, II, III | Individual classification by local governments |
| Food Sanitation Application System | Registration, publication, changes, and completion reports of recall cases | Account management, operations, and local government usage |
| Recall Procedures | Shipment suspension, inventory isolation, recall, disposal, and return shipment | Specific recall and disposal methods |
| Logistics Operators | Warehouse stock, cargo in transit, lot tracking | Entrustment contracts and authority for instructions |
| Overseas Manufacturers | Cause investigation, improvements, cost bearing, indemnification | Governing law, contracts, evidence |
| Insurance | Marine cargo insurance, liability insurance, recall insurance separation | Individual policy conditions and payment eligibility |
| Relations with Cases of Imported Food Violations | Division of roles between import stage and post-domestic distribution | Scope delegated to related articles |
Division of Roles with "Import Food Violation Cases at the Time of Import"
This article focuses on the post-domestic distribution voluntary recall system and recall practices to avoid overlap with the existing article "Import Food Violation Cases at the Time of Import."
| Comparison Item | Import Food Violation Cases at the Time of Import | Imported Food and Food Recall Information | Main Responsible Phase |
|---|---|---|---|
| Focus Timing | Import Notification Review and Inspection at Import | After Import Permit and Post-Domestic Distribution | Divided before and after import |
| Primary System | Food Import Notification, Inspection Orders, Monitoring Inspections | Food Voluntary Recall Reporting System | Handled separately by Quarantine Stations and local governments |
| Key Information | Violation Cases Confirmed at Import | Voluntary Recall Cases Initiated by Businesses | Different public information |
| Cargo Condition | In Bonded Area or Under Import Procedures | Distributed to Warehouses, Wholesalers, Retailers, and Consumers | Different tracking scope |
| Main Measures | Import Denial, Disposal, Return to Origin, Inspection | Shipment Suspension, Inventory Quarantine, Recall, Notification, Completion Report | Domestic recall network required |
| Logistics Challenges | Bonded Storage, Waiting for Inspection, Container Returns | Tracking Sales Destinations, Recall Transportation, Return Consolidation, Disposal | Focus on domestic logistics information |
Details of the inspection system, inspection orders, and food import notification at import are covered in "Import Food Violation Cases at the Time of Import," while this article concentrates on responses after domestic distribution.
Items to Check in Food Recall Information
| Item to Confirm | Practical Meaning | Internal Documents for Cross-Reference |
|---|---|---|
| Product Name | Identify the target product | Product Master, Invoice |
| Notifier, Seller, Importer | Identify stakeholders in the commercial flow | Importer Ledger, Customer Ledger |
| JAN Code | Differentiates similar products | Product Code List |
| Lot / Serial Number | Limits the scope of the recall target | In-Out Records, Manufacturing Records |
| Best Before / Expiration Date | Identifies the packaging unit | Inventory List, Label Records |
| Sales Area / Sales Destinations | Understands the distribution range | Delivery Records, Distribution Performance |
| Recall Reason | Judges the hazard and required measures | Inspection Results, Complaints, Manufacturer Notifications |
| Recall Method | Confirms return destination, refund, and notification method | Recall Plan, Customer Notices |
| Recall Status | Manages unreturned quantities and completion judgment | Recall Ledger, Disposal Records |
Differences Between the Food Sanitation Act and the Food Labeling Act
| Category | Main Issue | Typical Examples | Points to Note for Imported Food |
|---|---|---|---|
| Food Sanitation Act | Food safety and sanitary hazards | Microbial contamination, harmful substances, pesticide residues, additive violations, foreign matter contamination | Confirm differences between overseas standards and Japanese standards |
| Food Labeling Act | Omissions or errors in safety-related labeling | Allergens, expiration dates, storage instructions, heating requirements | Check Japanese labels, translations, and labeling lots |
| Relevant to Both Laws | Problems with both the food itself and its labeling | Violations of raw material standards and simultaneous omission of allergen labeling | Organize reporting based on both laws |
A violation of labeling is not necessarily minor, nor is a violation of the Food Sanitation Act always serious by definition. Omission of allergen labeling could cause severe health damage to consumers with related allergies.
Cases Likely to Require Notification
| Type of Issue | Typical Examples | Main Verification Documents | Initial Actions |
|---|---|---|---|
| Pathogenic Microorganisms | Enterohemorrhagic E. coli, Botulinum toxin, etc. | Test results, production records | Immediately stop shipment and identify affected items |
| Harmful/Toxic Substances | Aflatoxin, toxic fish, toxic plants | Analysis reports, raw material information | Halt sales and notify authorities |
| Hard Foreign Objects | Glass shards, hard plastic fragments, etc. | Complaint products, process records, photos | Confirm same production line and lot |
| Spoilage / Deterioration | Seal defects, swelling, off odors, etc. | Packing records, temperature logs | Isolate affected distribution lots |
| Pesticide Residues / Additives | Exceeding standards, unauthorized additives, improper usage | Analysis certificates, formulation sheets | Trace target raw materials and products |
| Allergen Labeling | Omission of specified allergenic ingredients, incorrect labels | Formulation sheets, label masters | Alert sales outlets and consumers |
| Expiration / Storage Labeling | Errors in expiration dates, storage instructions, heating conditions | Labels, manufacturing instructions, application records | Assess potential hazards |
| Equipment / Packaging Materials | Non-compliance with material standards, violation of elution limits | Material certificates, test results | Confirm the scope of affected food and packaging |
Recall Classification
Reported recall cases are classified by public health centers and other authorities into Class I, Class II, or Class III based on the potential health risks posed by the food.
| Class | Basic Concept | Typical Examples | Practical Response |
|---|---|---|---|
| Class I | High likelihood of causing serious health damage or death if consumed | Pathogenic microorganisms, toxic substances, carcinogens, hard foreign objects, etc. | Immediate shipment suspension, broad notification, swift recall |
| Class II | Low likelihood of causing serious health damage or death | Non-compliance with standards for general bacterial counts, coliform groups, etc. | Identify affected scope, conduct planned and prompt recall |
| Class III | Minimal likelihood of health damage from consumption | Violations of certain additive usage standards, residual limits not exceeding acute reference doses, etc. | Recall and public announcement according to administrative judgment |
In general, Class II is the basic classification, with Class I applied when there is a high risk of serious health damage, and Class III considered when there is almost no risk of health damage.
Who Reports, When, and To Whom
| Procedure Item | Basic Handling | Practical Handling for Imported Foods |
|---|---|---|
| Reporting Entity | Business operator or food business operator who has initiated voluntary recall | The party responsible for the recall among importers, manufacturers, sellers, etc. |
| Reporting Timing | Report without delay after starting the recall | Do not wait to confirm total quantity; submit initial report based on available information |
| Report Recipient | Prefectural governor or equivalent | Generally, the public health center overseeing the recall division |
| Reporting Method | Principally use the Food Sanitation Application System or similar system | Follow the local government’s procedure; confirm if paper-based filing is required |
| Change Report | Report promptly if there are changes to important details | Update relevant lot numbers, sales destinations, quantities, health damage reports, etc. |
| Completion Report | Report completion without delay after recall ends | Summarize recall quantities, uncollected amounts, disposal or reloading, and recurrence prevention measures |
If the recall division is located in a different prefecture than the head office, reporting to the local government that oversees the recall division is acceptable.
Even if the importer is still investigating the cause with the overseas manufacturer, once domestic recall has begun, the report must not be delayed pending overseas response.
Key Information to Organize at the Time of Notification
| Information Category | Main Details | Verification Materials for Imported Food |
|---|---|---|
| Notifier Information | Name, Address, Representative, Contact Details | Corporate Information, Importer Ledger |
| Recall Responsible Department | Department, Person in Charge, Contact Details | Internal Recall Structure Chart |
| Product Information | Product Name, Designation, Image, Packaging Form | Product Master Data, Labels |
| Specific Information | JAN Code, Lot Number, Serial Number, Expiration Date | Warehouse Receipt Records, Production Records |
| Recall Reason | Violation Details, Risk of Violation, Discovery Process | Inspection Results, Complaints, Manufacturer Notifications |
| Sales Information | Sales Destinations, Sales Period, Sales Volume, Sales Area | Order, Shipping, Delivery Records |
| Recall Method | Return Address, Refunds, Announcements, Contact for Inquiries | Recall Plan, Consumer Notification Draft |
| Health Damage | Presence or Absence of Damage, Details, Number of Cases | Complaint Records, Medical Information |
| Recall Status | Quantity Recalled, Recall Rate, Quantity Not Recalled | Recall Ledger, Inventory Records |
Positioning of the Food Sanitation Application System
The Food Sanitation Application System is an online system managed by the Ministry of Health, Labour and Welfare. Food-related businesses can use it for business permits and notifications as well as for registering voluntary food recall cases, updating recall status, and registering recall completion.
| System / Procedure | Main Usage | Position in This Article |
|---|---|---|
| Food Sanitation Application System | Food business procedures; registration, publication, and status updating of food recalls | Voluntary recall notification after domestic circulation |
| NACCS | Import/export and port-related procedures; import declarations; collaboration with other regulatory checks | Import customs clearance stage |
| Food Import Notification | Quarantine Station procedures when importing food products for sale or business purposes | Import stage |
| Public Recall Case Search | Search for publicly disclosed recall cases | Information confirmation for consumers, business partners, and businesses |
The Food Sanitation Application System does not manage NACCS examination categories or other regulatory codes.
Basic Flow When a Recall Occurs
- Receive the issue information and report it to the responsible person within the company.
- Temporarily suspend sales and shipments.
- Identify the product name, JAN code, lot number, and expiration date.
- Check for products using the same raw materials or production line.
- Isolate warehouse inventory and prevent outbound shipments.
- Instruct to stop delivery and hold receipt of goods in transit.
- Aggregate information on sales destinations, sales quantities, stock levels, and consumer reach.
- Confirm presence or absence of health hazards and severity of risk.
- Contact the competent local government and report without delay after starting the recall.
- Finalize notifications for business partners and consumers.
- Start accepting returns, collecting recalled products, processing refunds, and handling inquiries.
- Request the overseas manufacturer to investigate causes and suspend shipments.
- Update quantities recalled, quantities not yet recalled, and status of destruction or return shipments.
- Confirm the cause and measures to prevent recurrence.
- Submit a completion report promptly after the recall ends.
Reports on Changes During Recall and Completion Reports
| Reporting Stage | Content of Report | Notes for Imported Food |
|---|---|---|
| Initiation | Product, reason, sales destination, recall method, identified quantity, etc. | Start based on available information even before receiving response from overseas manufacturer |
| Change | Target lot, sales area, quantity, health hazards, recall method, etc. | Communicate expansions or reductions of target scope simultaneously to business partners |
| Progress | Recalled quantity, recall rate, unrecalled quantity, consumer response | Consolidate figures from warehouses and sales outlets into a single source |
| Completion | Recall results, disposition method, unrecalled quantity, recurrence prevention measures | Explain disposal certificates, return-to-origin certificates, and any quantity discrepancies |
Before submitting the completion report, confirm consistency among recall target quantity, sales quantity, inventory quantity, recalled quantity, and disposed/returned quantity.
Role of Freight Forwarders and Warehouse Companies
| Tasks | Actions Taken | Actions Normally Not Taken | Required Records |
|---|---|---|---|
| Inventory Confirmation | Confirm storage location and quantity of the targeted lot | Legal determination of recall target | Inventory ledger, location data |
| Shipment Suspension | Hold the targeted inventory in WMS or similar system | Decision on sales suspension policy | Suspension instructions, operation logs |
| Delivery Suspension | Stop cargo in transit and arrange for receipt hold | Decision on consumer notification | Delivery status, transportation instructions |
| Return Aggregation | Coordinate return destination and acceptance of recalled items | Legal judgment on disposal or reloading | Return slips, acceptance records |
| Lot Matching | Link B/L, Invoice, receipt date, and lot information | Evaluation of food safety | B/L, Invoice, lot tables |
| Disposal Logistics | Arrange waste contractor, reloading, and storage | Final decision on cost bearer | Disposal certificates, reloading documents |
Organization Based on the Standard Five Classifications of Freight Forwarders
The following Standard Five Classifications are not established categories under laws or industry-wide standards but serve as an analytical framework in this series to organize the scope of freight forwarders’ involvement.
| Standard Five Classifications | Tasks Performed in Food Recall | Decisions/Guarantees Usually Excluded | Reference Documents | Practical Points to Note |
|---|---|---|---|---|
| Simple Intermediary | Convey recall notices, shipment suspension instructions, inventory responses | Determining recall targets and classes | Email, operational instructions | Record reception and forwarding times |
| Cargo Transportation Service Provider | Arrange delivery suspension, return transport, disposal, and transshipment | Judgment on food safety or reporting obligations | Contract of carriage, transport records | Separate normal transport and recall transport |
| NVOCC / House B/L Issuer | Identify import lots, House B/L, and consolidated cargo | Final determination of domestic sales lots | House B/L, Master B/L | Connection with domestic lot information is required |
| Door-to-Door Single Contractor | Track location and process from import to domestic delivery | Guarantee of product regulatory compliance | Door-to-Door contract, delivery records | Distinguish transport liability from product liability |
| Agent / Coordinator for Specific Operations | Coordinate inventory isolation, return consolidation, disposal, and transshipment | Administrative and legal decisions beyond delegation scope | Power of attorney, recall instructions | Document who gave the instructions for execution |
Contracting Carrier and Actual Carrier refer to positions under the transport contract and do not replace the Standard Five Classifications.
Individual tasks such as inventory verification, delivery suspension, return consolidation, and disposal or transshipment arrangements do not themselves constitute a sixth classification.
Contacting Overseas Manufacturers and Exporters and Claim Procedures
| Item to Confirm | Requests to Overseas Parties | Claim Documentation |
|---|---|---|
| Cause | Investigation of raw materials, processes, labeling, inspections, and change history | Cause Investigation Report |
| Scope | Manufacturing dates, production lines, lots, shipment countries | Manufacturing and Shipping Records |
| Shipment Suspension | Halt of unsent products, Japan-bound items, and related products | Suspension Instructions and Confirmation Documents |
| Improvements | Corrective actions, recurrence prevention, re-inspections | Improvement Reports and Audit Materials |
| Cost Responsibility | Recall, storage, disposal, re-shipment, inspections, notification expenses | Invoices and Cost Summary |
| Substitutes | Re-manufacturing, substitute shipments, delivery schedules | Substitute Product Contracts and Transport Documents |
Relationship with Cargo Insurance and Liability Insurance
| System / Insurance | Main Coverage / Role | Notes for Food Recalls |
|---|---|---|
| Cargo Insurance | Physical damage caused by accidental incidents during transportation | Recall costs are not automatically covered |
| Carrier / Warehouse Operator Liability | Damage due to breach of management obligations | Check for temperature deviations, delivery errors, and violations of shipment halt instructions |
| Product Liability Insurance | Third-party bodily injury or property damage caused by product accidents | Pure recall expenses may be treated separately |
| Recall Insurance | Covered recall costs, notifications, disposal, etc. | Confirm covered incidents, cost items, deductibles, and sublimits |
| Warranty under Sales Contracts | Seller’s guarantee of regulatory compliance, indemnity, and right of recourse | Check contract terms regardless of insurance presence |
Common Practical Problem Cases
| Case | Main Issues | Initial Checks | Logistics Measures | Main Documents |
|---|---|---|---|---|
| Missing allergen labeling on imported confectionery | Discrepancy between Japanese label and formulation | Identify affected label and lot | Halt shipments, recall from stores | Formulation sheet, label proofs |
| Residue pesticide standard violation from frozen foods | Test results after domestic distribution | Confirm sales destinations, inventory, and test samples | Isolate frozen items, consolidate recall | Analysis reports, shipment records |
| Global simultaneous recall by overseas manufacturer | Applicability to Japan-bound lots | Match serial numbers and shipment countries | Stop cargo in transit as well | Manufacturer notice, B/L |
| Microbial violations found in self-inspection after import | Compliant at import but violation discovered later | Confirm same production line and lot | Stop sales, initiate returns and recall | Inspection results, production records |
| Warehouse mistakenly ships recalled lots | Poor management after halt instructions | Check instruction and shipment times | Emergency stop of deliveries | WMS logs, emails |
| Same product name but different relevant expiration dates | Excessive recall or misses target lots | Verify expiration date, JAN code, and lot | Isolate only targeted products | Inventory lists, labels |
| Overseas manufacturer refuses to bear recall costs | Lack of contract, cause, or evidence | Confirm warranty clauses and cause | Record costs by item category | Contracts, invoices, reports |
| Recall quantity does not match sales quantity | Consumed items, location unknown, duplicate counting | Analyze quantity discrepancies | Continue managing unrecalled items | Recall ledger, sales ledger |
Example 1: Allergen Labeling Omission on Imported Confectionery
The importer created Japanese labels based on the ingredient list provided by the overseas manufacturer. After sales began, it was discovered that allergens contained in the compound ingredients were missing from the Japanese labeling.
The importer identified the lots using the affected labels, halted warehouse shipments, and informed retailers to stop sales. Meanwhile, after initiating the recall, the importer notified the relevant local government and issued consumer warnings.
In this case, it was necessary to verify responsibility not only for the overseas manufacturer’s ingredient information but also for the processes involved in creating and approving the Japanese labels.
Example 2: Case of Receiving a Worldwide Simultaneous Recall Notice from an Overseas Manufacturer
A notification was received from an overseas manufacturer indicating a risk of foreign substance contamination in products from a specific production date. The product name was common worldwide, but it was unclear from the notice alone whether the lot destined for Japan was included.
The importer cross-checked manufacturing numbers, export dates, invoices, Bills of Lading, and domestic warehouse lots to identify products already sold within Japan. Subsequent lots still in maritime transport were also withheld from domestic distribution.
In this case, a system was required to link overseas recall information with Japan’s import and sales data.
Example 3: Case Where a Violation Was Discovered After Monitoring Inspection
Food subject to monitoring inspection at import was granted Import Permit before the inspection results were known and was distributed domestically. Later, when the violation was confirmed, the importer tracked the sales destinations and inventory and initiated a voluntary recall.
Because the sales lot records were incomplete and the target quantity could not be precisely identified, the recall scope had to be set broadly.
In this case, Import Permit and domestic safety management after distribution are separate issues, and lot traceability determined the extent of the recall.
Example 4: Case of Delay in Warehouse Shipment Suspension Processing
The importer instructed the warehouse company by email to suspend shipment of the affected lot. However, the withholding process in the warehouse management system (WMS) was delayed, and some products were shipped after the instruction.
The importer and the warehouse company confirmed the email receipt time, WMS operation time, picking time, and shipment time to determine the additional recall scope.
In this case, a procedure to mutually confirm that the suspension of shipment was effectively in place was necessary, not just communication alone.
Example 5: Case of Temperature Deviation During Transportation Combined with a Recall
For imported refrigerated food, a temperature deviation during inland delivery was confirmed, and complaints of quality abnormalities from the same lot also occurred.
The importer prioritized a voluntary recall and reviewed temperature records, delivery logs, warehouse records, cargo insurance, and transportation contracts.
In this case, recall measures for consumer protection were prioritized, and determination of liability and insurance coverage needed to be made after verifying the evidence.
Common Misunderstandings
| Misunderstanding | Actual Understanding | Practical Notes |
|---|---|---|
| If an Import Permit is granted, the product will not be subject to recall | Violations or mislabeling may be discovered after domestic distribution | Continue monitoring after import |
| Since it is a voluntary recall, administrative notification is optional | Certain voluntary recalls require mandatory notification | Confirm without delay after starting the recall |
| It is sufficient to report only after the total quantity is determined | Initial notification can be updated with changes and progress | Do not delay notification |
| Labeling violations are unrelated to health hazards | Allergens and others can cause serious health harm | Evaluate labeling content from a hazard perspective |
| No recall action is needed for Class III cases | Even if health hazard likelihood is low, procedural response is required by the system | Follow administrative classification |
| Food sanitation application systems are part of NACCS | They are domestic food administration systems separate from NACCS | Differ import customs clearance and recall procedures |
| Notifying the warehouse company by email completes the shipment stop | Confirm that shipment has actually stopped in WMS or similar systems | Receive completion report |
| If product names match, all items are subject to recall | Specifically identify scope by JAN code, lot, expiry, packaging, etc. | Avoid excessive recalls |
| If the overseas manufacturer recalls, the same response applies in Japan | Check Japan-specific lots and domestic laws separately | Decide on domestic notification accordingly |
| The freight forwarder decides on administrative notification | Confirm that the notification party is the administration; logistics providers support execution | Clarify authority |
| Food recall costs are automatically covered by marine cargo insurance | Physical damage during transport and recall expenses are judged separately | Check Clause wording and cause |
| After collecting the product, the process is complete | Updates on recall status and final reporting are required | Organize quantities, disposal, and recurrence prevention |
| Cost lists alone suffice for claims against overseas manufacturers | Cause, contract breach, causation, and evidence are necessary | Preserve investigation documents |
Practical Decision-Making Checklist
| Timing of Check | Party / Documents for Confirmation | Items to Confirm | Actions if Issues Are Found |
|---|---|---|---|
| At Product Adoption | Manufacturer, Specification Sheet | Raw materials, Labeling, Change management | Finalize specifications for Japan market |
| Before Import | Lot Control Sheet | Link between import lot and domestic product code | Add tracking items |
| At Domestic Warehouse Receipt | Warehouse, WMS | JAN code, Lot number, Expiry date, Quantity | Isolate unidentified lots |
| At Problem Recognition | Inspection results, Complaints, Notifications | Hazard, Affected products, Accuracy of information | Temporarily suspend shipment |
| At Recall Decision | Government authorities, Quality control department | Whether notification is required, Recall Classification, Scope of affected items | Consult with relevant local government |
| At Recall Initiation | Food Sanitation Application System, etc. | Notifier, Product, Reason, Sales information | Submit notification promptly with confirmed information |
| At Logistics Suspension | Warehouse, Delivery company | Inventory isolation, Shipment suspension, Cargo in transit | Confirm completion time |
| At Announcement | Sales destinations, Consumer service window | Identification of affected products, Health impact, Return procedure | Revise to avoid misunderstandings |
| During Recall | Recall ledger | Quantity recalled, Outstanding recalls, Sales destinations | Update changes and progress |
| When Making Overseas Inquiries | Manufacturer, Exporter | Cause, Target countries, Manufacturing lots | Request shipment suspension and corrective action |
| At Insurance / Recovery Claim | Contract, Insurance policy | Cause, Coverage, Costs, Responsibility | Consult experts |
| At Completion | Government authorities, Recall ledger | Recall results, Disposal, Discrepancies, Recurrence prevention | Report completion promptly |
Situations When Consulting Experts Is Advisable
- When it is unclear whether a voluntary recall notification applies
- When it is difficult to assess the hazard level as Class I, II, or III
- When both the Food Sanitation Act and the Food Labeling Act are involved
- When health impact evaluation is required for allergens, microorganisms, or harmful substances
- When the overseas manufacturer's recall scope does not match the lot bound for Japan
- When recall target quantities, sales quantities, and inventory quantities do not align
- When legal permissibility of disposal, return to origin, or change of use needs to be confirmed
- When reimbursement amounts or liability with the overseas manufacturer are disputed
- When the causes of transport accidents and manufacturing defects overlap
- When allocation between marine cargo insurance, product liability insurance, and recall insurance is necessary
- When health damage to consumers has occurred
- When the criteria for concluding the recall and the content of the final report are unclear
Practical Points to Note
- An Import Permit does not guarantee food safety after domestic distribution.
- This article focuses mainly on voluntary recalls after domestic distribution; import inspections are covered in a separate article.
- Food recall information should be verified not only by product name but also by JAN code, lot number, and expiration date.
- After initiating a recall, report promptly without waiting for all information to be finalized.
- If the scope or quantity of the recall changes after reporting, update the notification and provide progress reports accordingly.
- A completion report should be submitted after the recall is finished.
- Recall Classification is based on the potential for health hazards.
- Do not confuse the Food Sanitation Application system with NACCS.
- Shipment stoppage requires confirmation not only by email transmission but also through completion of processing in systems such as WMS.
- Connect overseas recall information to Japanese import and sales lots.
- Maintain records of returned, isolated, disposed, or reloaded recall products.
- Be prepared to explain any discrepancies between recalled quantities and sold quantities.
- Claims against overseas manufacturers require evidence of cause, contractual terms, and costs.
- Food recalls cannot always be handled solely through marine cargo insurance.
- Consumer protection in recall responses should take precedence over judgments on responsibility or claims.
Summary
- Imported food and food recall information primarily concern the practical handling of reporting under the Food Voluntary Recall Reporting System and related public information after domestic distribution.
- Since June 1, 2021, submission of notifications to authorities is mandatory for certain voluntary food recalls.
- Food import notifications and inspection orders at import are covered under “Import Food Violation Cases at the Time of Import,” while this article addresses post-distribution responses within Japan.
- Violations or suspected violations of the Food Sanitation Act, safety-related violations of the Food Labeling Act, and similar matters are subject to notification requirements.
- Under the Recall Classification, recall incidents are classified into Class I, Class II, and Class III based on the potential for health hazards.
- Business operators and food business operators that start a recall must submit the notification without delay after initiating the recall.
- The notification destination is the prefectural governor or equivalent authority, usually the health center responsible for the recall department.
- In the Food Sanitation Application System, recall cases can be registered, published, updated, tracked, and completed.
- The Food Sanitation Application System is a separate system from NACCS.
- The target product is identified not only by product name but also by JAN code, lot number, expiration date, importer, seller, and packaging form.
- In the initial response, shipment suspension, inventory segregation, delivery halt, tracing of sales destinations, and confirmation of health damage are conducted concurrently.
- If the scope or quantity of the recall changes after notification, the updates and progress reports must be submitted.
- After completing the recall, the recall results, uncollected items, disposal, and recurrence prevention measures should be organized and reported.
- Importers link recall information from overseas manufacturers to the Japanese import lots and domestic sales lots.
- Freight forwarders and warehouse companies are not the final administrative decision-makers but support cargo location management, shipment suspension, and recall logistics.
- Under the Standard Five Classifications, involvement is organized as Simple Intermediary, Cargo Transportation Service Provider, NVOCC / House B/L issuer, Door-to-Door Single Contractor, and Agent / Coordinator for Specific Operations.
- Contracting Carrier and Actual Carrier refer to transport contract statuses and do not replace the Standard Five Classifications.
- Stock verification, delivery suspension, consolidated returns, disposal, and reloading arrangements do not constitute a sixth classification by themselves.
- Claims for reimbursement from overseas manufacturers require evidence of cause, contract violation, relevant lots, costs, and causal relationship.
- Recall costs are generally not covered by standard marine cargo insurance but should be organized including product liability insurance, recall insurance, sales contracts, and related arrangements.
Management of imported food does not end with Quarantine Station inspection and customs Import Permit. Establish a system to monitor post-distribution problem information and promptly trace the relevant lots.
Once a voluntary recall is initiated, submit notifications to the competent local authority without delay, coordinating as needed without waiting for final responses from overseas manufacturers or confirmation of total quantities.
Food recalls prioritize shipment suspension and recall for consumer protection, followed by organizing cause, liability, insurance, and claims against overseas manufacturers based on evidence.
This article provides general information on imported foods, food recall information, the Food Voluntary Recall Reporting System, Recall Classification, the Food Sanitation Application System, recall logistics, cargo insurance, and freight forwarder practices. It does not determine notification obligations, Recall Classification, recall scope, health damage, disposal or reloading methods, insurance payments, claims, or legal liability of parties in individual cases. Actual responses should be confirmed based on the relevant provisions of the Food Sanitation Act, Food Labeling Act, related laws and regulations at the time of response, the latest information from the Ministry of Health, Labour and Welfare, the Consumer Affairs Agency, local authorities, product materials, inspection results, sales and inventory records, contracts, insurance terms, and expert judgment.
