Food Recall Regulations In Indonesia, Thailand, And Vietnam

Introduction

Food safety incidents can emerge without warning, requiring businesses to act swiftly to protect consumers and comply with regulatory obligations. Across Southeast Asia, Thailand, Vietnam, and Indonesia have each developed comprehensive food recall frameworks designed to ensure rapid removal of unsafe products from the market while holding businesses accountable for compliance failures.

While these three jurisdictions share common objectives—protecting public health and ensuring food safety—each has crafted distinct regulatory approaches reflecting their unique administrative structures, enforcement priorities, and legal traditions. Understanding these differences is essential for food businesses operating in the region, as recall procedures, timelines, reporting requirements, and penalties vary significantly across borders.

This article examines the food recall regulations in Thailand, Vietnam, and Indonesia, providing practical guidance on legal requirements, procedural steps, and compliance obligations in each market.

INDONESIA

Food recall rules in Indonesia are overseen by the National Agency of Drug and Food Control (Badan Pengawas Obat dan Makanan or "BPOM"). A new BPOM regulation in July 2025 updated these rules, replacing the country's first food recall rules, from 2017.

The latest rules address the recall and destruction of processed food, including food additives, raw materials, auxiliary materials, food packaging, labels, and/or other materials used in the processed food production process. In order to avoid a recall, producers, importers, and distributors of processed food must comply with the following:

• Food Safety and Quality Standards;
• Labelling rules; and
• Food advertising rules (new in the 2025 BPOM regulation).

In addition, these business actors must have a Business License to Support Business Activities (PB-UMKU). There are two types of food recall: mandatory and voluntary.

Mandatory and Voluntary Recall

Mandatory recalls can be implemented based on:

• Sampling and testing results;
• Label monitoring;
• Advertising monitoring;
• BPOM's Rapid Alert System for connecting with domestic authorities and authorities in other countries regarding food that does not meet safety, quality, and label requirements;
• Food-poisoning outbreaks;
• Verified public complaints;
• Results of studies on food safety or quality;
• Inspection findings;
• Expiration and nonextension of the PB-UMKU;
• Revocation of the PB-UMKU; and
• Lack of a required PB-UMKU for food business activities.

If a mandatory recall is ordered, business actors must conduct the recall and issue a recall notice to their distribution facilities based on the relevant instructions from BPOM.

Voluntary recalls are carried out by business actors based on their own risk assessments. In such cases, business actors should issue a recall notice. The notice must at least identify the food, provide the reason for recall, and define the recall period and scope. The notice must be delivered to any distribution facilities and to the head of BPOM or the provincial government, with a copy sent to the other authority

To support the recall procedure, business actors must have a food traceability system (or refer to an internationally applicable system) as a basis for effective recalls, as well as a written recall procedure to monitor and evaluate the effectiveness of the recall implementation.

Recall Classification

Indonesian law defines three different classes of food recalls:

• Class I – When consumption or exposure to the food may cause serious health problems or even death.
• Class II – When consumption or exposure to the food may cause temporary health problems, there is only a low possibility of causing serious health problems, or the food is of inadequate quality.
• Class III – When consumption or exposure to the food will not cause health problems, but there is a violation of laws and regulations other than those covered by class I and class II recalls.

Class I recalls must be completed no later than 14 calendar days from the date that BPOM issues the recall instruction. The deadlines for class II and class III recalls are 30 and 180 calendar days, respectively, from the date the recall instruction is issued.

Recalls are conducted in distribution facilities and can be extended to the consumer level if the recall is due to the risk of serious health problems or death. Retailers must ensure that all recalled food is not sold or displayed at the point of sale and is kept separate from other food. Business actors must provide a means for returning food products recalled from consumers.

Report and Publication

Business actors must submit a report regarding the food recall to the head of BPOM, and under the 2025 regulation now have the option of also sending it to the head of the relevant provincial government.

For class I food recalls, business actors must also publish an announcement regarding the recall within 24 hours of the recall instruction—a requirement that the 2025 notification has carried over from the 2017 regulation.

Destruction of Food

The destruction of food that has been recalled can be ordered by the head of BPOM or the provincial government, or business actors can destroy it voluntarily. The destruction is conducted onsite after evaluation by an inspector from BPOM or the provincial government. Both types of destruction must be witnessed by an officer from BPOM or the provincial government, and the business actor must prepare and submit a report to either BPOM or the provincial government regarding the destruction, with a copy of the report sent to the other authority..

Administrative Sanctions

Business actors that do not comply with the provisions and obligations related to food recalls are subject to administrative sanctions, including written warnings, fines, temporary suspension of activity, suspension of public-facing business activities up to six months, and revocation of the business' PB-UMKU.

THAILAND

Thailand regulates food product recalls through the Food Act B.E. 2522 (1979) and its bylaws, along with administrative mechanisms led by the Thailand Food and Drug Administration (TFDA). While the Food Act prohibits the sale of unsafe food and grants authorities broad powers to act against unsafe and noncompliant products, Notification of the Ministry of Public Health No. 420 embeds recall readiness into food Good Manufacturing Practices, requiring food businesses to maintain recall procedures and traceability systems.

In addition, the Thailand Rapid Alert System for Food and Feed (RASFF) is an alert system for reporting imports of human food and animal feed into Thailand. The RASFF is used by various competent authorities, including the TFDA, Department of Agriculture, and Department of Livestock Development, among others.

The RASFF provides an operational platform for incident notification, risk assessment, public alerts, interagency coordination, and postincident close-out. In practice, recalls may be initiated voluntarily by operators or ordered by the TFDA when risk to consumer health or noncompliance is identified.

Legal Basis and Competent Authorities

When necessary, the TFDA can direct operators to halt distribution, withdraw products from the market, and take remedial actions to address hazards. In particular, the Import/Export Inspection Division of the TFDA is empowered to order product recalls of the imported product that are found to violate regulatory requirements.

Alongside the TFDA, the Office of Consumer Protection Board (OCPB), established under the Consumer Protection Act, plays a significant role in consumer safety. The OCPB is authorized to investigate consumer complaints, order the recall or withdrawal of unsafe or noncompliant products, and coordinate with the TFDA and other agencies to ensure effective consumer protection in food safety matters. Ministry of Public Health Notification 420 on Good Manufacturing Practice (GMP) requires food manufacturers to implement and maintain a documented recall procedure, establish a product traceability system—including batch and lot identification and distribution records—and put in place mechanisms to verify the effectiveness of recalls as part of their GMP controls. These obligations are designed to ensure the rapid removal of unsafe or noncompliant food from the market and to facilitate timely communication with authorities and supply chain partners. The Rapid Alert System for Food and Feed (RASFF), operated by the National Bureau of Agricultural Commodity and Food Standards, serves as the operational backbone for incident reporting, risk assessment, rapid response, alerts, and multiagency coordination. Key participants in this system include TFDA, the Department of Medical Sciences, and the Department of Livestock Development, among others.

Scope and Triggers

Food product recalls in Thailand can be issued for a broad range of processed and unprocessed foods, beverages, food additives, and other regulated domestic and imported food products available in the Thai market. Recalls may be triggered by a variety of situations, such as chemical or microbiological contamination; excessive levels of approved substances; unhygienic production, packing, or storage conditions; adulteration or substitution of ingredients; or quality that fails to meet TFDA standards. Other triggers include labeling or advertising violations that mislead consumers or affect the safe use of the product, the presence of expired products, and hazards related to containers or packaging materials.

In practice, recalls are often initiated following findings from sampling, testing, or inspections conducted by the TFDA or provincial public health offices. Surveillance signals and outbreak investigations, such as those related to food poisoning, can also prompt recalls. Public complaints that are verified by the TFDA or the OCPB, rapid alerts issued through RASFF (including those received via INFOSAN, the International Food Safety Authorities Network), and monitoring of labels or advertising for deceptive or unsafe information are additional common precursors.

Types of Recalls: Voluntary and Mandated

Recalls in Thailand can be initiated voluntarily by food business operators or mandated by the authorities (e.g., TFDA). Voluntary recalls typically arise when operators, through internal risk assessments, self-inspections, complaints, or notifications from their supply chain, identify a potential risk and act to remove the affected products from the market. Ministry of Public Health Notification No. 420 requires that operators be prepared to execute such recalls effectively and promptly. On the other hand, when the TFDA identifies a significant risk or a legal violation, it has the authority to mandate a recall—or in the worst-case scenario, market withdrawal. In these cases, the TFDA may order the cessation of distribution and direct the necessary recall or withdrawal steps. For the most serious hazards, the TFDA can escalate its response by issuing public alerts, seizing products, and ordering their disposal or destruction to ensure consumer safety

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