Is a recall plan mandatory for food importers in Canada? 

COMPLIANCE ALERT: Every food importer in Canada must have a written recall plan. Once every 12 months you are required to simulate a recall using your written procedure and keep records of the simulation for two years. 

Yes. A recall plan is mandatory for all food importers operating under the SFCR. This is not a recommendation or a best practice. It is a legal requirement with no exemptions for small importers or low-volume operations. 

Your recall plan must be a written document included within your Preventive Control Plan. It must describe the specific steps your business will take to remove food from the marketplace in the event of a recall, including how you will identify affected product, how you will notify the CFIA if the food presents a risk to human health, and how you will track and document the recall from initiation to completion. 

Beyond having the written plan, you must conduct an annual recall simulation once every 12 months. The simulation must be run using your actual written procedure. You must document the details of the simulation and the results and keep those records for two years from the date the simulation was conducted. 

The annual simulation requirement is not a formality. It exists because a recall plan that has never been tested is unlikely to execute effectively under real conditions. CFIA inspectors ask to see your simulation records as part of standard PCP verification. A missing or outdated simulation record is a documented non-compliance. 

INSIDER INTELLIGENCE: Most food businesses understand that a recall plan must exist. Fewer understand that an untested recall plan with no simulation records is a compliance gap that CFIA specifically looks for during inspections. The simulation is the proof that the plan works.