A comparative analysis of National food recall systems.

Food recall and withdrawal is a fundamental tool for risk management and different Counties stated the compulsory application of a “system” for food; the present work is an analysis of different systems applied in different Coutries. The main objective of analyzed systems is the consumer health protection through an audit system and the application, by producers, of system to rapidly recall/withdrawal of food. The comparative analysis of different national systems (ie: European Union, Australia, Canada, United States and China) showe differences both of the terminological and legal aspects; the words recall and withdrawal have different significance in E.U. legislation than in other Counties legislations; from a legal point of view two main recall/withdrawal system could be identified: a compulsory one (E.U. and China) and a voluntary one (U.S.A, Canada e Australia); all the investigated systems have a cooperative approach between Authority and Food Busines Operator but different hint on their respective roles could be identified