RASFF (Rapid Alert System for Food and Feed in Europe)

RASFF (Rapid Alert System for Food and Feed)

RASFF (Rapid Alert System for Food and Feed) is a system for the rapid sharing of information regarding health risks arising from food, feed, and food contact materials among EU member states and other network participants.

Notifications may be issued through RASFF in cases where residues of pesticides, pathogenic microorganisms, mycotoxins, undeclared allergens, foreign substances, prohibited substances, heavy metals, migration of substances from food contact materials, or import inspection non-compliances are identified.

RASFF is not merely a list of food recalls.

It is a system that distinguishes and shares cases that require urgent responses for products already on the market, cases requiring additional verification by other countries, cases limited to the notifying country, cargo rejected at the border before entering the EU, cases with unconfirmed information or unidentified products, and more.

For Japanese importers, exporters, freight forwarders, warehouse operators, customs brokers, and insurance practitioners, RASFF serves as an information source not only for food safety in the EU market but also for cargo in transit, cargo rejected in the EU, warehouse inventory, identical lots destined for Japan, marine cargo insurance, and liability considerations.

However, the mere fact that a RASFF notification is registered does not automatically determine sales suspension, recall, disposal, return shipment, insurance payment, or liability within Japan.

Scope Covered in This Article

Item	Contents Covered in This Article	Items Requiring Separate Confirmation
RASFF Institutional Structure	Information sharing between competent authorities of EU member states and the European Commission	Administrative organization and domestic laws of each member state
Notification Types	Differences among Alert, Information, Border Rejection, and News	Latest status of individual notifications
Information Sub-classifications	Differences between Information for follow-up and Information for attention	Actual distribution destinations and market residue status
Notification Authorities	Roles of competent authorities, contact points, and the European Commission	Inspection bodies and decision authorities for individual cases
Border Rejection	Meaning of cargo rejected before entering the EU territory and risks of reshipment	Individual measures such as disposal, reshipment, special handling
RASFF Window	Search of public information and confirmation items	Non-public information, company names, internal official documents
Cargo for Japan	Verification of products, lots, country of origin, manufacturer, packaging, etc.	Official determination by manufacturers on target products
In-transit and Warehouse Inventory	Confirmation procedures for holding, isolation, customs clearance, return, disposal, etc.	Official instructions from cargo owners and authorities
Japan’s Voluntary Recall System	Relation to voluntary recall notifications under the Food Sanitation Act and Food Labeling Act	Necessity of notification for individual products
Cargo Insurance	Distinction between transport accidents and manufacturing, labeling, and regulatory issues	Individual insurance policies, cause of the incident, insurer’s judgment
Liability	Roles of manufacturers, importers, freight forwarders, warehouse operators, etc.	Individual contracts, negligence, causality, damage amount

Institutional Positioning of RASFF

RASFF is a rapid alert network for food and feed safety information established under Regulation (EC) No 178/2002, which sets out the basic framework of EU food law.

Currently, RASFF operates as part of the Alert and Cooperation Network, which also includes administrative support and cooperation networks, as well as the Food Fraud Network, facilitating information exchange through the iRASFF platform.

The purpose of RASFF is to quickly share risks related to food and feed among network members, enabling product traceability, market withdrawal, recall, consumer notification, import rejection, enhanced inspections, and other appropriate responses.

It is important to note that a RASFF notification itself does not constitute a uniform recall order applicable to all countries.

Actual market actions, administrative measures, recall orders, sales suspensions, import refusals, and similar enforcement actions are carried out by the competent authorities of each country based on their applicable laws and regulations.

Main Stakeholders in the RASFF Network

Stakeholder	Main Role	Position in Notification Practice	Notes
Competent Authorities of EU Member States	Market surveillance, border inspection, food incident investigation, business operator response	Confirm risks and measures, consolidate information at their national contact point	Food safety administrative structures differ by country
National RASFF Contact Points	Verify domestic information and issue notifications via iRASFF	Official notification portal into the network	The local authority conducting inspections may not be the same as the notification contact point
European Commission	Manages the network and shares notifications with members	Handles notification circulation, liaises with third countries, operates the system	The European Commission does not directly detect all incidents
EFSA	Conducts scientific assessments of food and feed risks	Participates in risk assessments as needed	Does not conduct individual evaluations for all notifications
Other Network Members	Participating bodies from EEA, EFTA, etc.	Receive, monitor, and handle notifications involving their countries	Their status is not always identical to that of EU member states
Competent Authorities of Third Countries	Investigate causes and implement corrective actions as country of origin or dispatch	May receive information on related notifications from the European Commission	Third countries are generally not members of the EU internal network
Food Business Operators	Manufacturing, importing, selling, recalling, cause investigation, etc.	Company inspections or voluntary recall information may trigger official notifications	There is no system for operators to notify the entire RASFF network directly

Who Issues RASFF Notifications?

RASFF notifications are typically shared by the competent authorities of each country, who register confirmed information into iRASFF through their respective national RASFF contact points.

The origin of a notification varies by case and may include border inspections, random market sampling, food business operators' voluntary testing, consumer reports, food poisoning investigations, company-led recalls, information from other countries, and more.

Information Origin	Main Discoverer	Connection to RASFF	Practical Confirmation Points
Border Inspection	Competent authorities at Border Control Posts, etc.	May be notified as border rejection, etc.	Confirm inspection location, importer, lot, and measures taken
Market Surveillance Inspection	National or local food safety authorities	May be classified as Alert or Information	Confirm market distribution range and recall status
Company Voluntary Testing	Manufacturers, importers, retailers, etc.	May initiate RASFF notification after reporting to authorities	Differ between company announcements and official notifications
Consumer Complaints / Health Issues	Consumers, medical institutions, authorities	May be notified after investigation	Confirm causal relationship between health damage and targeted products
Food Poisoning Investigation	Health authorities, testing agencies, etc.	Tracking information on related products may be shared	Avoid confusing patient information with cargo lot numbers
Unofficial Information	Media, third-party sources, unverified reports, etc.	May appear as News notification	Clearly indicate that information is unverified

Notification and Legal Measures Are Not the Same

Item	Main Meaning	Decision Authority	Practical Notes
RASFF Notification	Sharing information on risks, distribution, inspection results, and measures	Network contact point	Do not determine legal obligations based solely on the notification classification
Voluntary Recall by Company	Food business operator voluntarily recalls from the market	Manufacturer, importer, seller, etc.	Confirm whether it is a regulatory order or voluntary action
Regulatory Recall / Sales Suspension Order	Ordering measures to the operator based on legislation	Competent authority of each country	Confirm applicable regions and legal basis
Border Rejection	Refusal of cargo entry/import into the EU territory	Authority in charge of border control	Confirm follow-up actions such as destruction, re-dispatch, or processing
Enhanced Inspection	Strengthening control for the same country of origin, item, etc.	EU and national authorities	Check impact on other lots and subsequent cargo

RASFF Notification Types

Notification Type	Main Meaning within the System	Typical Distribution Status	Initial Response in Japan
Alert Notification	Notification indicating a serious direct or indirect risk from food or feed that requires rapid action or may require rapid action by other network members	Already distributed to multiple countries or possibly present in other countries' markets	Prioritize verification of the same lot, sales destinations, stock, and cargo in transit
Information for Follow-up	Notification that does not require immediate action by other network members but indicates the product is or may be present in other countries' markets	Distributed to other countries or still possibly distributable	Continue verifying links with own cargo and update additional information
Information for Attention	Notification that the product is limited to the notifying country, has not yet been placed on the market, or has already been removed from the market	Limited to notifying country, pre-market placement, fully withdrawn, or consumed	Confirm whether the same lot is intended for Japan and avoid excessive full suspension
Border Rejection Notification	Notification indicating that a batch, container, or cargo of food/feed was rejected at an EU border due to risk	Cargo before officially entering the EU market	Check return/reshipment destination, other destinations for the same lot, and exporter inventory
News Notification	Unofficial or unconfirmed information, or risk information regarding unidentified products	Product, lot, and distribution range not yet determined	Separate confirmed facts from unconfirmed information and monitor for updates to official notifications

Criteria for Distinguishing Alert and Information

The difference between Alert and Information should not be simply understood as "hazardous" and "minor."

The main criteria include the nature of the risk, whether other network members need to take prompt action, whether the product is circulating in other countries' markets, and whether there is still a possibility of circulation.

Criteria	Alert	Information for Follow-up	Information for Attention
Urgent response by other countries	Required or likely to be required	Not immediately required but follow-up necessary	Generally, urgent response in other countries is unlikely
Market circulation	Often already circulating in other countries' markets	Circulating or possible to circulate in other countries' markets	Limited to notifying country, before market release, or no longer on the market
Response in Japan	Priority review of stock, distribution, and transport	Continued confirmation of updated information and distribution destinations	Check presence or absence of distribution to Japan and limit response scope
Common misunderstandings	Does not necessarily mean a blanket recall order across the entire EU	Does not mean safe or no response needed	Does not mean no health risk exists

RASFF Does Not Have Classifications Equivalent to FDA's Class I, II, or III

The FDA's food recalls are categorized by health risk into Class I, Class II, and Class III; however, RASFF notifications such as Alert, Information, and Border Rejection do not correspond directly to the FDA's Class classifications.

RASFF notification categories reflect not only the presence of risk but also factors such as the product’s distribution status, the need for rapid response in other countries, and border refusals.

Therefore, Alert should not be mechanically equated to FDA Class I, nor Information to FDA Class II or III.

What is a Border Rejection Notification

A Border Rejection Notification indicates that a batch, container, or cargo of food, feed, or food contact materials has been rejected either before entering the EU territory or at the import control stage due to health risks or other reasons.

Unlike product recalls of items already circulating in the market, a key characteristic is that the affected cargo has not officially entered the EU market.

Item to Confirm	Details to Check	Impact on Japanese Practice	Main Reference Materials
Border Inspection Point	Which port, airport, or Border Control Post issued the rejection	Identify the transport route and inspection authority	RASFF notification, border inspection documents
Reason for Rejection	Residue pesticides, microorganisms, mycotoxins, documentation deficiencies, etc.	Confirm subsequent shipments of the same product and origin	Inspection results, notification reasons
Country of Origin	Country where production or manufacturing occurred	Check relation to same producer/factory for shipments to Japan	Origin documents, manufacturer information
Dispatching Country	Country from which the cargo was shipped to the EU	If different from origin, confirm re-export or transshipment transactions	B/L, Invoice, export documents
Affected Lot	Lot, batch, container, expiration date, etc.	Assess identity with shipments destined for Japan	Labels, packing list, inspection certificates
Subsequent Measures	Disposal, reshipment, special treatment, change of use, etc.	Confirm final handling destination of rejected cargo	Official orders, exporter responses, transport records

Border-Rejected Cargo Is Not Always Disposed Of

For cargo rejected at EU borders, depending on the case, measures such as disposal, reshipment outside the EU, special handling, or other actions may be ordered.

Therefore, it should not be assumed that "cargo rejected in the EU has already been disposed of."

After being returned to the exporting country, cargo may be sent back to the manufacturer's warehouse, processed for shipment to another third country, or undergo re-sorting or reprocessing.

When Japanese parties handle the same manufacturer or lot, the final handling of the cargo concerned, the return destination, and whether reshipment will occur should be confirmed in writing.

Logistics Documents to Check After Border Rejection

Document	Items to Check	Purpose of Check
Commercial Invoice	Seller, buyer, product, lot, amount	Confirm contractual relationships of rejected cargo
Packing List	Packing, quantity, lot, batch, best before date	Verify identity with cargo destined for Japan
B/L, Sea Waybill, AWB	Shipper, consignee, notify party, loading port, discharge port	Trace return or reshipment route
Border Inspection Documents	Inspection results, reasons for rejection, actions by authorities	Verify official basis for rejection
Inspection Report	Analysis target, detected values, standard values, inspection methods	Use for risk assessment of identical products
Return / Reshipment Instructions	Return destination, final destination, disposal method	Confirm risks of movement to alternative markets
Manufacturer Response	Same production date, same raw materials, shipments to other countries	Confirm impact scope for cargo destined for Japan

Information Available in the RASFF Window

Item	Main Content	Practical Use
Notification number	Unique notification identification number	Used as an identifier for updates and inquiries to manufacturers
Notification date	Date the notification was registered	Records the status and timeline of the case at the time of review
Notification type	Alert, Information, Border rejection, News, etc.	Assess urgency and distribution status
Product category	Classification such as food, feed, food contact materials	Cross-check with in-house product master data
Product	Name of the affected product or raw material	Match against invoice, labels, and product specifications
Hazard	Microorganisms, pesticides, mycotoxins, allergens, etc.	Used for investigation, insurance, and administrative response
Notifying country	Network member country that registered the notification	Do not confuse with country of origin
Country of origin	Country of origin of the product or raw material	Verify relation to the same factory, producer, or raw materials
Distribution status	Regions where the product was distributed, or if distribution info is unknown	Assess the possibility of distribution to Japan
Action taken	Recall, withdrawal, disposal, border rejection, etc.	Differentiates measures already implemented and future responses

Limitations of Publicly Available Information

Information published on the RASFF Window is useful for verifying food safety; however, not all information contained in the notifications is made publicly available.

Details such as the names of businesses, trading partners, specific distribution routes, and communications between authorities may be restricted from disclosure due to professional confidentiality or investigative reasons.

If the relationship to your own cargo cannot be confirmed based on the publicly available information alone, additional information should be obtained from manufacturers, exporters, importers, local business contacts, or the competent authorities.

Key Items to Confirm in RASFF Notifications

Item to Confirm	Details to Check	Points of Caution
Food / Feed Name	Official Name, Product Classification, Ingredient Names	Cannot identify the subject by generic names alone
Brand	Sales Brand, Private Brand (PB), Commercial Use Products, etc.	Manufacturer and brand owner may differ
Manufacturer / Producer	Manufacturing Factory, Producer, Processor	Business names may not be disclosed
Country of Origin	Country of Production / Manufacture	May differ from country of dispatch or notification
Country of Dispatch	Country that shipped the cargo to the EU	Confirm transshipment involving third countries
Lot / Expiry Date	Lot, Batch, Best Before, Use By, etc.	If details are not public, inquire with the manufacturer
Hazard Details	Residue Pesticides, Bacteria, Mycotoxins, Foreign Objects, Allergens, etc.	Distinguish between standard exceedance and actual health hazards
Distribution Destination	EU Member States, Third Countries, Online Distribution, etc.	Check updates if information is not yet confirmed
Measures Taken	Market Withdrawal, Consumer Recall, Disposal, Border Refusal, etc.	Do not confuse notification with legal orders
Status Updates	Follow-up, Additional Distribution Destinations, Case Closure, etc.	Do not finalize conclusions based on initial information alone

Situations Where RASFF Is Used in Import Procedures for Japan

• When importing into Japan products of the same brand notified within the EU
• When using raw materials from the same country of origin, factory, or producer
• When purchasing products from exporters whose cargo was denied entry at the EU border
• When rejected cargo is returned to the exporting country and may be reshipped
• When raw materials transported via Europe are destined for Japan
• When the same lot may be included in cargo in transit or bonded warehouse inventory
• When the shipper or importer requests investigation of overseas food safety information
• When transport incidents such as temperature deviations and RASFF notifications emerge simultaneously
• When confirming whether notification to marine cargo insurance or liability insurance is required

Situations for Use in Export Operations to the EU

Businesses exporting food, feed, food ingredients, and similar items from Japan to the EU should review not only their own product information but also RASFF notifications related to the same product category and country of origin.

Trends in RASFF	Items to Check Before Export	Main Responses
Frequent notifications on pesticide residues	EU residue standards, pesticides used, analysis results	Enhance pre-export testing and producer management
Frequent notifications on mycotoxins	Storage and drying conditions, lot inspection	Confirm sampling methods and inspection certificates
Notifications on allergen labeling	EU labeling requirements, cross-contact, raw material specifications	Reconfirm labels and manufacturing processes
Notifications on pathogenic microorganisms	Hygiene management, heating, refrigeration, testing	Confirm HACCP management and microbiological testing
Increase in border rejection cases	Inspection certificates, import conditions, origin and facility registration	Confirm necessary documents in advance with EU importers
Notifications related to food contact materials	Material composition, migration testing, conformity declarations	Prepare certification documents for packaging materials and containers

Confirmation of the System on the Japanese Side

RASFF is an EU administrative information-sharing system and does not itself directly decide on sales suspension, disposal, voluntary recall, import prohibition, or similar measures within Japan.

If there is a possibility of involvement with cargo destined for Japan, the importer should check the Food Sanitation Act, Food Labeling Act, imported food monitoring, domestic voluntary recall information, and related matters.

Since June 1, 2021, Japan has implemented a notification system to administrative agencies for certain voluntary recalls subject to the Food Sanitation Act or Food Labeling Act.

Confirmation Source	Details to Confirm	Practical Meaning
Ministry of Health, Labour and Welfare	Imported food monitoring, food sanitation, voluntary recall information	Check for issues under the Food Sanitation Act
Food Sanitation Application System	Notification and publication of voluntary recalls of food, etc.	Confirm whether the same product is recalled domestically
Consumer Affairs Agency	Food labeling, voluntary recall, violation information	Confirm allergens, expiration date labeling, etc.
Local Government / Health Center	Specific consultation with importers and sellers	Confirm notification, isolation, recall response, etc.
Quarantine Station / Customs Broker	Pre-clearance cargo, food import notification, inspection	Confirm hold or inspection response at ports and airports
Importer / Seller	Domestic inventory, sales destinations, recall policy	Central role in domestic response

Basic Flow from RASFF Notification to Response in Japan

1. Record the RASFF notification number, URL, confirmation date and time, and notification type.
2. Check the notifying country, country of origin, dispatching country, and hazard details.
3. Confirm whether the notification is an Alert, Information for follow-up, Information for attention, Border rejection, or News.
4. In the case of Border rejection, verify the rejection location and subsequent measures.
5. Extract product name, brand, manufacturer, lot number, expiration date, and packaging format.
6. Search your company’s cargo under transportation, cargo under customs clearance, warehouse inventory, and delivered goods.
7. Cross-check with Invoice, Packing List, B/L, AWB, labels, and inventory ledger.
8. If there is a possible match, share the information with the shipper/importer.
9. Temporarily suspend shipment, delivery, and customs clearance until formal instructions are received, if necessary.
10. Request written confirmation from the manufacturer or exporter regarding the applicability to cargo bound for Japan.
11. If there is return or reshipment of rejected cargo, confirm the final destination.
12. Verify relevant Japanese government information, voluntary recall information, and quarantine/food hygiene procedures.
13. Obtain formal instructions regarding inspection, sales suspension, return, disposal, re-export, etc.
14. Confirm whether accident notification to marine cargo insurance and liability insurance is required.
15. Retain records of verification results, communication logs, photos, work instructions, and shipment suspension records.

Documents Used for Lot Verification

Document	Verification Items	Notes
Commercial Invoice	Product, Manufacturer, Exporter, Importer, Quantity	Lot numbers may not be indicated
Packing List	Lot, Batch, Packaging Unit, Best Before Date	Confirm consistency with labels
B/L・AWB	Transport Segment, Container, Shipper, Consignee	Not documents that directly prove food safety relevance
Product / Case Label	Brand, UPC, Lot, Best Before, Factory Number	Central document for identifying targeted shipments
Inventory Ledger / WMS	Current Inventory, Storage Location, Quantity Shipped Out, Delivery Destination	Confirm if tracking by lot is possible
Manufacturer Response	Target Factory, Lot, Raw Materials, Shipping Area	Should be obtained in writing, not orally
Inspection Certificate	Analysis Items, Results, Inspection Lot	Confirm correspondence with the RASFF target lot
Return / Reshipment Records	Destination after Rejection, Transport Documents, Disposal Location	Verify possibility of redistribution to third countries

Relation to Cargo in Transit

Transport Stage	Main Points to Confirm	Practical Measures
Export Warehouse / Pre-Shipment	Target lot, shipment suspension, replacement products	Hold shipment and confirm with manufacturer
During Sea or Air Transport	Vessel or flight, expected arrival, changeable destination	Prepare for hold, inspection, or return after arrival
After Arrival at Port or Airport	Before/after customs clearance, food import notification, inspection status	Share information with importer, customs broker, and quarantine office
While Stored in Bonded Warehouse	Target quantity, location, planned release	Implement isolation, stop release, and verify labels
After Customs Clearance / Before Delivery	Release instructions, delivery vehicle, delivery destination	Confirm instructions to hold release and delivery
Returned Cargo from the EU	Return reason, RASFF number, purpose of reimportation	Confirm Japan-side import, storage, and disposal procedures

Relationship with Warehouse Inventory and Delivered Cargo

Status	Items to Confirm	Main Actions
In Warehouse Storage	Subject lot, quantity, location	Isolation, shipment suspension, photo and quantity records
Preparing for Shipment	Picking and loading status	Stop operations and return to inventory
In Transit	Vehicle, delivery destination, before/after delivery	Halt delivery, arrange return of cargo
Delivered	Delivery destination, quantity, sales status	Provide tracking information to importer and seller
Sold	Buyer, consumer, quantity sold	Confirm voluntary recall and consumer response

Relationship with Cargo Insurance

Being subject to a RASFF notification does not automatically qualify as an insured event under marine cargo insurance.

Cargo insurance distinguishes between physical damage caused by accidental incidents during transport or storage and issues related to manufacturing-stage quality problems, non-compliance with food hygiene standards, labeling deficiencies, residues, administrative regulations, or mere unsellability.

Cause / Condition	Main Issue	Verification under Cargo Insurance	Main Documentation
Temperature deviation during transport	Quality deterioration of frozen or refrigerated food	Confirm accidental incident, temperature variation coverage, and causal relationship	Temperature logs, equipment records, survey report
Water damage during transport	Packaging damage, mold, contamination	Check water damage risk, insurance period, and cause of damage	Photographs, container records, warehouse entry records
Damage during cargo handling	Container damage, leakage, foreign matter contamination	Confirm physical damage caused by cargo handling accident	Work records, photographs, accident report
Bacterial contamination at manufacturing stage	Salmonella, Listeria, etc.	Verify the possibility of manufacturing quality issues or inherent defects	RASFF, manufacturer reports, inspection results
Excess pesticide residues	Non-compliance with EU standards	Likely production or regulatory issue rather than transport accident	Inspection results, pesticide usage records
Mycotoxin detection	Excess levels of aflatoxin, etc.	Confirm at which stage—production, storage, or transport—the contamination occurred	Inspection reports, storage records, humidity data
Undisclosed allergens	Omission or incorrect labeling	Likely an issue of labeling compliance rather than physical damage	Labels, ingredient lists, manufacturing specifications
Prohibited or unapproved substances	Regulatory non-compliance, unsellability	Check administrative regulations and product compliance issues	RASFF, legislation, analysis results
Border rejection	Import refusal, return, storage costs	Rejection alone does not necessarily result in physical damage	Rejection notices, transport records, cost details
Recall costs	Notification, recall, re-delivery, disposal	Confirm recall cost or liability insurance separate from regular cargo insurance	Insurance policy, recall plan, cost details

Cases Where Transport Incidents and Food Safety Issues Coexist

For the same cargo, there may be instances where the cause in the RASFF notification and transport-related issues such as temperature deviations during transit, water damage, or handling damage are confirmed simultaneously.

In such cases, the reason for the cargo becoming unsellable should not be processed as a single RASFF notification. Instead, the issues related to manufacturing, labeling, and regulations should be separated from the physical damage that occurred during transportation.

Items to Confirm	Food Safety Issues	Transport Incident
Occurrence Timing	Manufacturing, processing, labeling stages, etc.	During transport, storage, or handling
Main Evidence	RASFF, manufacturer reports, analytical results	Temperature logs, photos, survey reports
Main Responsible Parties	Manufacturer, importer, label creator, etc.	Carrier, warehouse, handling operator, etc.
Insurance Considerations	Issues of quality, labeling, and regulatory compliance	Accidental physical damage and covered risks
Damage Amount	Recall, unsellable goods, regulatory compliance costs, etc.	Physical damage, repairs, replacement procurement, etc.

Relationship with Liability for Compensation

Cause	Main Responsible Parties	Points to Confirm	Main Documents
Contamination during manufacturing stage	Manufacturer, contract manufacturer	Process stage, quality control, shipment decision	Manufacturing records, inspection reports
Residual pesticides and mycotoxins	Producer, processor, importer, etc.	Raw material control, inspection obligations, contract specifications	Analysis results, specifications, sales contracts
Missing labeling	Manufacturer, importer, label preparer	Persons deciding and approving labeling content	Label approval records, formulation sheets
Temperature incidents during transport	Carrier, freight forwarder, cargo owner, etc.	Set temperature, instructions, equipment malfunction	Booking details, temperature logs, incident reports
Warehouse shipping errors	Warehouse operator, instruction giver, etc.	Shipping hold instructions and operation timestamps	Emails, WMS records, shipping logs
Unauthorized resale of rejected cargo	Cargo owner, seller, reseller, etc.	Handling instructions after rejection, explanations, contracts	Return records, sales documents, notification records
Unauthorized disposal or return	Person(s) deciding and executing disposal	Official instructions and authority from owner	Work instructions, disposal certificates, contracts

Roles and Responsibilities of Stakeholders

Stakeholder	Main Role	Points to Note
Importer	Verify affected lots, consult with Japanese authorities, decide on sales suspension and voluntary recalls	Acts as the central point for response within Japan
Manufacturer / Exporter	Provide explanations regarding the affected factory, lots, causes, distribution destinations, and returned cargo	Obtain formal responses in writing
Freight Forwarder	Identify cargo in transit, confirm transportation status, notify relevant parties	Should not independently make final judgments on food safety
Warehouse Operator	Inventory reconciliation, quarantine, suspension of outgoing shipments, record retention	Do not discard or return goods without formal instructions
Customs Broker	Confirm customs clearance status, food import notification, and quarantine procedures	Share status before and after customs clearance with related parties
Seller	Trace downstream distributors, remove products from shelves, respond to consumers	Coordinate with importer and administrative policies
Insurance Company	Confirm coverage under cargo insurance and liability insurance	Do not consider an incident an insurance claim based solely on RASFF notifications
Surveyor / Inspection Company	Verify cargo condition, causes, and damage extent	Distinguish between food safety inspections and cargo damage investigations

Scope of Responsibility for Freight Forwarders

The fact that a freight forwarder has checked RASFF information, forwarded it to the cargo owner, or assisted in identifying the relevant cargo does not guarantee food safety, legal compliance, insurance applicability, or the necessity of a voluntary recall.

The scope of responsibility is determined based on the contracted tasks, contractual status, information received, timing of information transmission, documents issued by the forwarder, and work instructions provided.

Issue	Main Responsible Party	Freight Forwarder Involvement	Reference Documents
Final Judgment on Food Safety	Manufacturer, Importer, Competent Authorities, etc.	Typically not the final decision-maker	Inspection Results, Manufacturer Replies, Administrative Instructions
Lot Identification	Manufacturer, Cargo Owner, Importer	Supports identification using transport documents and inventory information	Invoice, Packing List, B/L
Transport Suspension	Cargo Owner, Importer, etc.	Adjusts booking and delivery based on instructions	Email, Work Instructions
Return or Re-export	Cargo Owner, Importer, Administrative Authorities	Arranges transport based on formal instructions	Return Instructions, Customs Clearance Documents
Disposal	Cargo Owner, Importer, Administrative Authorities, etc.	May arrange disposal contractor and transport	Disposal Approval, Certificates
Insurance Claim Application	Insurance Company	Supports notification of accidents and submission of documentation	Insurance Policy, Incident Documentation

Organization by Freight Forwarder’s Standard Five Classifications

The following Standard Five Classifications are not established by law or the entire industry but serve as an analytical framework in this series to organize the scope of freight forwarder involvement.

Standard Five Classifications	Possible Tasks Related to RASFF	Judgments Usually Not Included	Reference Documents for Confirming Responsibility Scope	Practical Notes
Simple Intermediary	Transmission of RASFF information, shipper instructions, manufacturer responses, etc.	Final decisions on food safety, recall obligations, and insurance applicability	Email, quotations, work instructions	Accurately convey information content and any unresolved issues
Cargo Transportation Service Provider	Identification of cargo in transit, suspension of delivery, arrangements for return or re-export	Guarantee of manufacturing quality or compliance with EU/Japanese law	Transport contracts, bookings, work instructions	Clearly define transport sections contracted by yourself
NVOCC / House B/L Issuer	Tracking cargo using House B/L, container, and transport information	Scientific judgment of lots, determination of recall scope	House B/L, Master B/L, cargo details	Do not finalize applicability based solely on B/L information
Door-to-Door Single Contractor	Comprehensive coordination of collection, ocean transport, customs clearance, storage, and delivery stages	Final decisions under food administration, unauthorized disposal, guarantee of insurance payment	Door-to-Door contract, transport clauses, instruction records	Distinguish between a single-contract transport arrangement and food safety responsibility
Agent / Coordinator for Specific Operations	Lot verification, inquiries to manufacturers/authorities, progress management of insurance notifications, etc.	Legal judgments beyond delegation scope, confirmation of insurance applicability	Powers of attorney, work instructions, confirmation reports	Differentiate between confirmation support and final judgment

Contracting Carrier and Actual Carrier are concepts indicating legal or contractual positions and do not replace the Standard Five Classifications.

Individual operations such as forwarding RASFF information, lot verification, suspension of shipment notifications, manufacturer inquiries, and insurance notifications do not themselves constitute a sixth classification.

Common Problematic Cases in Practice

Case	Main Issue	Key Points for Judgment	Initial Response	Main Documents
A lot rejected at the EU border is reshipped to Japan	Circulation of rejected cargo on a different market	Whether the returned/reshipped cargo is identical to the Japan-bound cargo	Inquire with the exporter about the final disposal destination	RASFF, B/L, labels, return records
Alert product matches stock in Japan	Need for domestic distribution suspension and voluntary recall	Whether factory, lot, expiration date, and packaging match	Isolate stock, notify importer, confirm with authorities	RASFF, stock ledger, manufacturer's response
Only the product name in "Information for attention" matches	Risk of suspending unaffected stock	Whether the notification country is limited and Japan-bound distribution exists	Check with manufacturer about the distribution range	Notification, shipment records, labels
News notifications spread on social media	Overreaction due to unverified information	Whether product and lot numbers have been identified	Explicitly mark as unconfirmed and await official updates	RASFF, company announcements, authority information
Temperature deviation notification coincides with microbiological alert	Distinguishing between manufacturing causes and transport causes	Which cause caused the product quality deterioration	Preserve survey reports, inspection results, and temperature records	Temperature logs, test results, RASFF
Shipment dispatched from warehouse before suspension notice	Mistaken shipment and expanded recall scope	Notification time, instruction time, shipment time	Stop delivery, recall shipment, preserve records	Email, WMS, delivery records
Discarding cargo based only on RASFF notification	Unauthorized disposal	Whether formal instructions from owner, importer, or authorities exist	Halt operations and obtain written instructions	Contracts, instruction documents, disposal quotations
Claiming border rejection costs under marine cargo insurance	Regulatory costs without physical damage	Correlation between insured event and rejection costs	Notify insurer separately about cause and costs	Insurance policy, rejection notification, cost breakdown

Specific Example 1: Nuts Rejected at the EU Border and Subsequently Reshipped to Japan

For nuts from a third country, mycotoxin levels exceeded the standard during an EU border inspection, resulting in the registration of a Border Rejection Notification.

Since the Japanese importer planned to purchase from the same exporter, they confirmed the situation and found that the rejected cargo had been reloaded back to the export country.

Initially, the exporter explained that a different lot would be shipped to Japan; however, upon checking case labels, container numbers, and expiration dates, it was revealed that part of the cargo may belong to the same production batch as the rejected goods.

The importer put the shipment on hold and requested the exporter provide inspection reports, disposal records, and analytical certificates for the lot intended for Japan.

Although a Border Rejection is a measure applied before distribution within the EU market, since rejected cargo is not necessarily destroyed, tracking the cargo after it is returned is essential.

Specific Example 2: When Alert-Targeted Products Match Warehouse Inventory in Japan

An Alert notification was registered within the EU region due to undeclared allergens.

When the Japanese importer checked the warehouse inventory, the product name, manufacturer, production factory, lot number, and expiration date matched those specified in the notification.

Based on the importer's official instructions, the warehouse operator isolated the relevant lot, recorded the suspension of shipment, saved inventory quantity data, and took photos of the labels.

The importer confirmed with the manufacturer regarding ingredient and labeling issues for products destined for Japan and investigated whether the same allergen omission appeared on the Japanese labeling.

Since an EU Alert alone does not automatically establish a product recall obligation within Japan, the importer consulted the relevant domestic regulatory agency to determine whether a voluntary recall notification was required.

Specific Example 3: Mistaking "Information for Attention" for an Alert

A European trading partner informed us of an RASFF notification concerning handled products.

Upon verification, the notification was classified as Information for Attention, the affected products circulated only domestically within the notified country, and all had already been withdrawn from the market.

The Japanese products were from a different factory and different lot, and the manufacturer confirmed that shipments bound for Japan were not subject to the notification.

If the notification category is not checked and all products are discarded or shipment suspended, damage could unnecessarily extend to unaffected products.

In Japan, shipment was temporarily held until confirmation from the manufacturer was obtained, then resumed after verifying that the products were unaffected.

Specific Example 4: When Temperature Deviations and RASFF Notifications Are Identified Simultaneously

For refrigerated food products, a RASFF notification based on pathogenic microorganisms was registered in the EU.

At the same time, temperature increases in reefer containers were confirmed for cargo bound for Japan.

To determine whether the microbial issue existed already at the manufacturing stage or if microbial growth and quality deterioration occurred due to the temperature deviation, shipment pre-inspections, temperature logs, arrival inspections, and manufacturer investigation results were cross-checked.

In marine cargo insurance, the circumstance of being subject to a RASFF notification was distinguished from the presence and extent of physical damage caused by temperature-related incidents during transportation.

The freight forwarder did not finalize insurance coverage but submitted temperature data, booking terms, and incident records to the insurance company.

Common Misconceptions

Misconception	Actual Understanding	Practical Notes
All RASFF notifications are directly discovered and mandated by the European Commission	National competent authorities verify and share information through their national contact points	Confirm the notifying country and the decision-making authority for measures
An Alert means a uniform recall order across the entire EU	It is critical risk information requiring prompt action; specific measures are taken by each country and operator	Confirm the distribution country and actual response measures
Information notification means the product is safe	A risk exists, but it does not require urgent response from other countries	Differ between Follow-up and Attention notifications
Information for attention means no confirmation is needed on the Japan side	Even if limited to the notifying country, confirm separately whether the same production lot has been shipped to Japan	Inquire with manufacturers about distribution to Japan
News notification indicates a confirmed food incident	It is unofficial, unverified information or a notification for unidentified products	Make clear that this information is unconfirmed
Border rejection means a recall from the EU market	It is notification that cargo was rejected before entering the EU territory	Distinguish from market distribution cases
Cargo rejected at the border is always destroyed	There may be re-shipment or special handling depending on circumstances	Confirm the final disposition location
The country of origin and notifying country are the same	The notifying country is where inspection and measures were taken; it may differ from the country of origin	Confirm the dispatch country and country of origin
If the product name is the same, all are subject to the alert	Restriction may apply by factory, lot, expiration date, packaging, etc.	Do not discard solely based on product name
If it is subject to RASFF, Japan automatically has recall obligations	Check for violations under Japanese law, domestic distribution status, and administrative decisions separately	Verify relevant provisions under the Food Sanitation Act and Food Labeling Act
If it is subject to RASFF, it is covered by cargo insurance	Determination depends on cause of incident, physical damage, and insurance clause conditions	Delineate manufacturing cause from transport damage
Freight forwarders make the final judgment on food safety	They are responsible for cargo identification and information sharing but may not be the final decision makers	Coordinate with importers, manufacturers, and authorities
Warehouse operators can immediately dispose of cargo upon seeing the notification	Disposal should not be performed without formal instructions from the cargo owner or relevant parties	Distinguish between isolation/holding and unauthorized disposal

Checklist for Decision Making

Confirmation Stage	Counterpart / Reference	Items to Confirm	Actions if Issues Arise
When Acquiring Information	RASFF Window	Notification number, confirmation date and time, notification type	Save the screen and data
When Confirming Notification Type	RASFF Notification	Alert, Information, Border Rejection, News	Set priority according to the type
When Confirming Notification Source	Notifying country, authority information	Notifying country, inspection point, country implementing measures	Clarify differences with the country of origin
When Confirming Border Rejection	Exporter, authority documents	Reason for rejection, return destination, disposal or reshipment, etc.	Obtain written confirmation of the final processing destination
When Checking Product Details	Label, Invoice, Packing List	Product, brand, factory, lot, expiration date	Submit an official inquiry to the manufacturer
When Confirming Transportation Status	B/L, AWB, Arrival Notice	Current location, before or after customs clearance, whether return cargo	Temporarily suspend customs clearance and delivery
When Checking Warehouse Status	WMS, inventory ledger	Quantity, location, planned shipment, already shipped	Isolate and stop shipments
When Confirming Distribution	Manufacturer, importer, distributor	Shipments to Japan, sales destination, same raw materials	Expand tracking scope
When Confirming Japanese Regulations	Ministry of Health, Labour and Welfare, Consumer Affairs Agency, local government	Legal violations, voluntary recall notifications, administrative consultation	Importer should consult the competent authority
When Inspecting	Inspection company, manufacturer	Inspection items, samples, lot correspondence	Confirm representativeness and inspection methods
When Confirming Insurance	Insurance company, insurance agent	Physical damage, accident cause, insurance period, deductibles	Report the incident according to the cause
When Confirming Responsibility	Contracts, instruction records	Identify cause in manufacturing, labeling, transportation, or storage	Organize damages and costs by cause
During Disposal	Cargo owner, authorities, insurance company	Authority for return shipment, disposal, re-export, inspection	Obtain written approval
When Completing	Work records, disposal certificates, return documents	Quantity, disposal method, person who issued instructions, completion date	Keep a complete set of evidence

Situations Requiring Consultation with Experts

• When the priority of response cannot be determined by the distinction between Alert and Information alone
• When the relationships among the notified country, country of origin, shipping country, and distribution country are unclear
• When the return destination or final disposal of Border rejection cargo cannot be confirmed
• When there is a possibility that rejected cargo has been reshipped to Japan
• When it is not possible to determine whether cargo destined for Japan is from the same lot
• When it is unclear whether voluntary recall notification is required under the Food Sanitation Act or Food Labeling Act
• When the handling of subject cargo before customs clearance or during bonded storage is unclear
• When transport accidents such as temperature deviations co-exist with food safety issues
• When the applicability of marine cargo insurance or liability insurance is uncertain
• When responsibility for costs associated with recall, return shipment, or disposal is disputed
• When damages occur due to mistaken cargo release by warehouses or delays in information sharing
• When consumer health damage or product liability issues arise

Points to Note

• RASFF is a network for rapid sharing of food and feed safety information within the EU.
• A RASFF notification itself does not constitute a uniform recall order applicable throughout the entire EU.
• Notifications are shared through competent authorities and designated contact points in each country.
• Alerts and Information are classified not only based on hazard level but also on the promptness of response by other countries and distribution status.
• Information is divided into Information for follow-up and Information for attention.
• News notifications include unofficial information, unconfirmed reports, or information about unidentified products.
• Border rejection differs from recalls of products already circulating in the EU market.
• Rejected border cargo is not necessarily subject to destruction.
• Please confirm subsequent measures such as return, reshipment, or special handling.
• Do not confuse the notifying country, country of origin, and dispatching country.
• The same product name may correspond to different factories, lots, expiration dates, or packaging.
• A RASFF notification does not automatically determine suspension of sales or recall obligations within Japan.
• In Japan, please verify information with the Ministry of Health, Labour and Welfare, Consumer Affairs Agency, local authorities, and importers.
• Do not judge marine cargo insurance coverage based solely on RASFF notifications.
• Freight forwarders and warehouse operators should not discard or return cargo without formal instructions.
• As notification information is updated, save the confirmation date and update history.

Summary

• RASFF is a system for the rapid sharing of risk information related to food, feed, and food contact materials within the EU.
• RASFF is not just a list of food recalls; it manages distributed cases, border rejections, and unconfirmed information separately.
• RASFF is operated through contact points of competent authorities in EU member states and others, with the European Commission managing the network.
• Voluntary inspections or recalls by food businesses may trigger RASFF notifications through the competent authorities.
• It is important to distinguish RASFF notifications from companies’ voluntary recalls, administrative orders, and border rejections or other legal actions.
• An Alert notification indicates a significant direct or indirect risk that requires, or may require, rapid response by other members.
• Information for follow-up notifications concern items distributed or potentially distributed in other countries’ markets but do not need immediate rapid action.
• Information for attention notifications are limited to the notifying country, concerning products before market entry or already removed from the market.
• News notifications involve unofficial, unconfirmed information or risk information of unidentified products.
• Border rejection notifications indicate that food or related cargo was refused entry at the EU border due to risk concerns.
• Border rejection differs from the recall of products that have already entered the EU market.
• Border rejected cargo may be subject to disposal, re-export outside the EU, or special treatment.
• If cargo refused in the EU is returned to the exporting country, it should be confirmed whether it is being reshipped to a third country.
• When matching cargo for Japan, confirm not only product names but also brand, manufacturer, factory, lot, best-before date, packaging, and country of origin.
• The notifying country, country of origin, dispatch country, and distribution country may be different from each other.
• Because publicly available RASFF Window information has limitations, additional information should be obtained from manufacturers or exporters if necessary.
• In Japan, RASFF notifications alone do not automatically trigger sales suspension, recall, or disposal.
• Separate confirmation is needed under Japan’s Food Sanitation Act, Food Labeling Act, import food monitoring, and voluntary recall notification system.
• For cargo in transit, check location, customs clearance status, bonded circumstances, and delivery status.
• For warehouse stock, isolate the relevant lots, suspend shipments, verify quantities, and preserve records.
• Freight forwarders support cargo tracking and information sharing but are not necessarily the final decision-makers for food safety.
• Warehouse operators should not dispose of or return cargo without formal instructions from the cargo owner or relevant party.
• Being subject to an RASFF notification does not by itself constitute a marine cargo insurance claim event.
• Marine cargo insurance separates accidental physical damage during transport from manufacturing, labeling, food hygiene, and regulatory issues.
• Temperature deviations, water damage, handling damage, and similar issues may be subject to insurance review depending on cause and policy terms.
• Residue pesticides, undeclared allergens, bacterial contamination at manufacturing stages, and similar issues are handled as non-transport accident matters.
• When RASFF causes and transport accidents coexist, losses and costs should be separated and managed by cause.
• Contracting Carrier and Actual Carrier refer to legal and contractual statuses and do not replace the freight forwarder Standard Five Classifications.
• Individual tasks like information transfer, lot matching, or shipment hold notification do not constitute a sixth classification.
• Since RASFF information is updated, it is important to record notification numbers, confirmation dates, follow-up information, and final actions.

Upon confirming a RASFF notification, first verify the notification category, notifying country, country of origin, dispatch country, product, risk content, lot number, and distribution status.

For Border rejection notifications, do not treat the refusal at the EU border as final; confirm subsequent actions such as disposal, re-export, or special handling, and the final destination after return shipment.

For cargo that may be subject to RASFF, do not independently decide on disposal or return; share information with importers, manufacturers, authorities, insurance companies, etc., and obtain formal instructions.

This article provides general information on RASFF, EU food and feed safety information, Japanese import food practices, marine cargo insurance, and liability. It does not determine the safety of specific products, legal effects of RASFF notifications, obligations for suspension, recall, disposal within Japan, disposal of border-rejected shipments, insurance coverage, or the legal responsibilities of freight forwarders, warehouse operators, or other parties. Actual responses should be confirmed based on the latest RASFF information, measures by the EU and competent authorities, manufacturer responses, Japan’s Food Sanitation Act, Food Labeling Act, instructions from relevant administrative agencies, sales contracts, transport contracts, warehouse agreements, insurance clauses, and expert advice.