Be Prepared – Guidance on Voluntary Market Withdrawals and Recalls

While craft brewers strive to manufacture and ship the highest quality beer, which is in compliance with Alcohol and Tobacco Tax and Trade Bureau (TTB) and state regulations, it is possible for a product to enter the market that is mislabeled or could cause adverse health effects.

The U.S. Food and Drug Administration (FDA), under the mandate of the Food Safety Modernization Act (FSMA), is responsible for the regulation and food safety standards for most of the U.S. food supply. Recalls are classified according to their potential seriousness. The FDA now has authority to force a recall and shut down operations at breweries or other food-production plants if it deems that there is a significant threat to public health.

Contamination, adulteration and misbranding comprise the major reasons for which a brewer’s products can be recalled. Some examples of these include:

Voluntary Market Withdrawals and Recalls

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  • Misbranded or mislabeled beer
  • Foreign object inclusion such as plastic, glass or metal fragments
  • Chemical contamination
  • Allergens or other toxins in the beer
  • Package over-pressurization

The Brewers Association Quality Subcommittee has produced guidance that will help brewers understand the various types of market withdrawals and recalls. The document explains brewers’ legal obligations when a product is in withdraw from the market and makes suggestions for how to prepare for and execute a voluntary market withdrawal or recall.

Brewers have the responsibility to consumers to protect their health and well-being. This is of upmost importance to Brewers Association (BA) membership. When there is potential for adverse health effects, brewers must take steps to ensure that consumers are kept safe.