Page last updated April 2022
FSANZ data on Australian food recalls helps identify key issues, track trends and develop prevention strategies. Undeclared allergens is the most common reason for food recalls year-on-year. Below is an analysis of food recalls due to undeclared allergens since 2016. This information expands on analysis of
food recall statistics for the last 10 years. These statistics are updated annually.
Table 1: Undeclared allergen food recalls 2016-2021
| 2016 | 2017 | 2018 | 2019 | 2020 | 2021 | total |
number of undeclared allergen recalls | 33 | 35 | 46 | 32 | 51 | 38 |
235 (45%) of 517 total recalls
|
% of total recalls for that year | 46 | 51 | 46 | 37 | 47 | 48 |
Problem detection
Problem detection information is collected when FSANZ coordinates a recall. It is separated into five categories listed at Table 2. The 'other' category is used for detection that does not fit within the four categories (including unreported).
Table 2: Problem detection for undeclared allergen recalls 2016-2021
| 2016 | 2017 | 2018 | 2019 | 2020 | 2021 | total |
customer complaint | 13 | 16 | 21 | 16 | 18 | 20 | 104 |
distributor or retailer complaint | 3 | 3 | 1 | 1 | 2 | 0 | 10 |
routine government testing | 8 | 6 | 5 | 6 | 12 | 8 | 45 |
routine testing by the company | 6 | 8 | 14 | 4 | 8 | 0 | 40 |
other | 3 | 2 | 5 | 5 | 11 | 10 | 36 |
total | 33 | 35 | 46 | 32 | 51 | 38 | 235 |
Figure 1: Problem detection for undeclared allergen recalls 2016–2021![]()

Figure 2: Problem detection for undeclared allergen recalls by year 2016-2020![]()

As shown in Figure 2, customer complaint is the most common method of detecting the need to recall food due to undeclared allergens.
Root cause
FSANZ has reviewed allergen-related recalls and identified 5 root causes of undeclared allergens:
Packaging errors, for example:
- product packed in the wrong packaging
- front of pack dairy free claim instead of a gluten free claim
- incorrect ingredient list.
Accidental cross contamination either of a raw ingredient or during the final production process.
Lack of skills and knowledge to fulfil labelling requirements, for example:
- pasta was declared as an ingredient, but wheat was not
- ingredients were reformulated however labelling did not reflect the new ingredients
- ingredients were not fully-translated into English from the original language.
Supplier verification issues, for example a raw ingredient contained an allergen but this information was not passed on to the manufacturer.
Unknown, for example:
- the food business was not able to determine what caused the issue at the time of recall, or when submitting their post recall report
- the food business did not provide enough information to FSANZ to identify root cause at the time of recall, or in their post recall report.
The raw numbers for each year are presented in Table 3 and Figure 3, with percentages graphed in Figure 4. Using percentages allows the data to be compared against each year, noting only partial data is available for 2016 due to a mid-year start to collection.
Table 3: Root cause for undeclared allergens food recalls mid 2016-2021
| 2016 | 2017 | 2018 | 2019 | 2020 | 2021 | total post recall reports |
packaging errors | 5 (31%) | 21 (68%) | 22 (54%) | 16 (53%) | 22 (51%) | 13 (36%) | 99 |
accidental cross-contact | 4 (25%) | 2 (6%) | 5 (12%) | 6 (20%) | 6 (14%) | 8 (22%) | 31 |
lack of skills and knowledge | 0 | 0 | 1 (2%) | 0 | 6 (14%) | 3 (8%) | 10 |
supplier verification issues | 1 (6%) | 7 (23%) | 9 (22%) | 4 (13%) | 8 (19%) | 9 (25%) | 38 |
unknown | 6 (38%) | 1 (3%) | 4 (10%) | 4 (13%) | 1 (2%) | 3 (8%) | 19 |
total post recall reports | 16 | 31 | 41 | 30 | 43 | 36 | 197 |
Figure 3. Root cause for all undeclared allergen food recalls mid 2016-2020![]()

Figure 4: Root cause percentage for undeclared allergen food recalls by year mid 2016-2021![]()

As shown in Table 3, and Figure 3 and 4, packaging errors are the leading cause of undeclared allergen recalls based on data from post recall reports. The exception to this was in 2016 when the most common cause was unknown, noting that FSANZ only began analysing information to provide root cause statistics mid-year.
Corrective actions
We collect corrective action information for all food recalls. This information is collected when the recall commences to determine the steps that have or will be taken to prevent the problem from re-occurring. Final information on corrective action is collected in post recall reports. The corrective action data below is from mid-2016 to 2021 to allow comparison with root cause.
Table 3: Reported corrective actions for undeclared allergen recalls by root cause mid 2016-2021
Root cause (post recall reports) |
| accidental cross contact (31) | lack of skills and knowledge (10) | packaging errors (99) | supplier verification issues (38) | unknown (19) |
altered product ingredients | 7 (23%) | 1 (10%) | 12 (12%) | 11 (29%) | 4 (21%) |
altered product label | 14 (45%) | 4 (40%) | 54 (55%) | 20 (53%) | 11 (58%) |
amended processing/ handling procedures | 11 (35%) | 3 (30%) | 47 (47%) | 12 (32%) | 6 (32%) |
changed suppliers | 1 (3%) | 1 (10%) | 6 (6%) | 9 (24%) | 2 (11%) |
identified new critical control points | 3 (10%) | 2 (20%) | 9 (9%) | 2 (5%) | 0 (0%) |
improved communication procedures | 5 (16%) | 4 (40%) | 39 (39%) | 17 (45%) | 7 (37%) |
improved hygiene practices (GHP's) | 2 (6%) | 0 (0%) | 1 (1%) | 0 (0%) | 0(0%) |
improved manufacturing process (GMP's) | 5 (16%) | 0 (0%) | 12 (12%) | 5 (13%) | 2 (11%) |
new/changed equipment | 4 (13%) | 1 (10%) | 1 (1%) | 1 (3%) | 1 (5%) |
training of staff | 10 (32%) | 4 (40%) | 56 (57%) | 15 (39%) | 8 (42%) |
other | 8 (26%) | 0 (0%) | 24 (24%) | 9 (24%) | 2 (11%) |
none | 2 (6%) | 0 (0%) | 0 (0%) | 0 (0%) | 1 (5%)
|
Note: the percentages are the
percent of all post recall reports identifying each corrective action for each
root cause. For example: for undeclared allergen recalls where packaging errors
were determined to be the root cause, 55% of food business reported altering
product labels.
Figure 5: Reported corrective actions for undeclared allergen recalls mid 2016-2021

As shown in Figure 5, since 2016 the most common corrective action reported for undeclared allergen recalls was altered product label. This was followed by training of staff and amended processing/handling procedures.
Figure 6: Reported corrective actions for undeclared allergen recalls by root cause mid 2016-2021

As shown in Figure 6, altered product label was the most common reported corrective action where accidental cross contact or supplier verification issues were the root cause, or where the root cause was unknown. Training of staff was the most common corrective action for recalls where the root cause was packaging errors. Training of staff, improved communication procedures and altered product label, were equal most reported corrective actions where lack of skills and knowledge was the root cause.