19 October 2026 · 3 min read

Your product is made on someone else's site. Who runs the recall?

Short answer - In most markets the brand owner named on the pack carries the legal responsibility for the product, so you make the recall or withdrawal decision and you own the communication to the regulator and the retailer. The co-manufacturer holds almost everything you need to make that decision, batch records, line clearance notes, raw material lots, despatch data, retained samples. That split is the whole problem, if your contract does not say how fast they must give you those records, who speaks to whom, and who pays for the retrieval, you will be negotiating it whilst the clock runs. Sort it in the technical agreement, not in the incident

This piece covers the specific places the brand and co-manufacturer relationship breaks under pressure, and what to fix before Christmas volumes start moving.

The decision is yours even when the evidence is not

Your co-manufacturer may be bigger than you, better resourced than you, and more experienced at this. It does not matter. The pack says your name, so the decision to recall sits with you.

What goes wrong is the gap between asking and receiving, you ask for the batch records, their technical manager is on another site. The data comes as a scan of a paper log at eight in the evening, by then you have already had to tell a retailer something.

Agree the data you will need before you need it

You cannot specify every incident in advance, but you can specify the pack of information that any incident requires

Full batch traceability - forward and backward, including raw material lot numbers and the supplier they came from.
Despatch records - showing which customer received which batch, and in what quantity.
Line and shift records - for the production window, including who was on the line.
Retained samples -where they are stored and who is allowed to release them.
A named person and a deputy -reachable out of hours, with the authority to send all of the above without checking upwards first.

Put a time limit against each, then test it.

Decide who talks to the retailer

Two companies contacting the same retailer buyer with slightly different versions of the same event is a credibility problem you will not recover from quickly. Usually it should be you.

Rehearse across the boundary

A mock recall that stops at your own four walls tests nothing about the relationship that actually holds your traceability. Run one that requires their records, out of hours, and record how long it took. The number will be uncomfortable the first time.

Christmas makes the gap wider

Peak season is when co-manufacturers are running extra shifts, extra agency staff and unfamiliar products. It is also when their shutdown dates may not match yours. Ask now which days their technical team is off, and who covers.

Frequently asked questions

Who is legally responsible for a recall, the brand or the co-manufacturer?

Generally the business whose name is on the label is treated as the food business operator responsible for that product. The manufacturer carries their own obligations for what they produced. The specifics depend on your jurisdiction and your contract, so confirm with your regulator and legal advisors.

What should a technical agreement say about incidents?

Notification triggers and timings, the information pack and how fast it must arrive, named contacts and deputies including out of hours, who contacts customers and regulators, mock recall participation, and how costs are handled.

What if the co-manufacturer disagrees that there is a problem?

Make the decision anyway. You can be wrong and recover. You cannot recover from having waited for agreement that never came.

We use several co-packers. Does this change?

It gets harder. Each one has different record formats and different response times, so keep one view of where each product is made, who to call, and what their last rehearsal showed.

Friday4:30 is the coordination layer for the food and drink business, from product incidents to business and industry issues, first alert to closed-out review.

This article is general guidance, not legal or regulatory advice. Always confirm your specific obligations with your regulatory authorities and legal advisors.