THE PROCESS IN MOTION

What happens when a lot of coffee must be recalled?

Start the scene or choose a stage. The animation simplifies the mechanism; what follows gives the details and the available references.

▶ Play the process01The result02The lot record03The withdrawal04The recall05The next lot

The result

An analysis certificate arrives: ochratoxin A above 3.0 µg/kg, on a lot already delivered. The roastery “has reason to believe” that its coffee is not safe: Article 19 of the European food law regulation kicks in, and it must act “immediately.”

Read the stages without animation

1. The resultAn analysis certificate arrives: ochratoxin A above 3.0 µg/kg, on a lot already delivered. The roastery “has reason to believe” that its coffee is not safe: Article 19 of the European food law regulation kicks in, and it must act “immediately.”
2. The lot recordWe go back through the roasting record: one bag of green coffee, two roastings, a lot number, six customers. When a dangerous food is part of a lot, the whole lot is presumed dangerous: so it is the lot as defined by the roastery that sets what must leave the market.
3. The withdrawalThe six customers are warned and withdraw the packs from their shelves: this is the withdrawal, which takes the product out of the commercial chain. The authority is informed. The distributor, which touches neither the packaging nor the label, withdraws within the limits of its activity and passes on what allows the product to be traced.
4. The recallThe coffee may have reached the consumer: a recall is needed. A notice is entered on Rappel Conso, the public recall site, approved by the administration, published, displayed in stores. It states the barcode, the lot, the best-before date, the sales period, the area, the distributors, and what the buyer must do.
5. The next lotThe supplier receives the certificate. The next contract requires an ochratoxin A analysis before shipment. No text obliges the importer to analyze for the roaster, and green coffee has no limit: the risk born at drying travels back up by contract where the law does not go.

To remember: A product that may have reached the consumer is recalled, and this recall is declared on Rappel Conso; it is the record linking a bag of green coffee and the lot sold that sets the extent of the recall.

In history: In history: public declaration of recalls has been mandatory in France since April 1, 2021.

Read the full article and its sources ↓

State of the law as of October 21, 2026. This section notes no dated deadline.

An establishment that registers, without approval

Regulation (EC) No 852/2004 on hygiene requires every operator to notify the competent authority of “each of the establishments” where it produces, processes or distributes food, so that it is registered, and then to report any significant change of activity and any closure (source 1, Article 6, paragraph 2). Approval, which presupposes a prior on-site inspection, is required only where a text provides for it (Article 6, paragraph 3), in practice for the foods of animal origin covered by Regulation (EC) No 853/2004. A roastery that roasts only coffee therefore registers; it is not approved.

It remains to know with whom, and on which form. In France, food safety has fallen, since the “single police,” to the Directorate-General for Food of the Ministry of Agriculture (DGAL) and, in the départements, to the departmental directorates for the protection of populations (DDPP), the Directorate-General for Competition, Consumer Affairs and Fraud Control (DGCCRF) keeping the fairness of information and the fight against fraud (source 7, summary). The form that all the sources consulted cite, Cerfa 13984, concerns establishments that handle animal foods or foods containing them. The route that a purely plant-based establishment must follow was not found in a text (see the gray areas).

HACCP: what Article 5 really asks

Article 5 of the same regulation requires “a permanent procedure or procedures based on the HACCP principles,” an English acronym for hazard analysis and critical control points (source 1, Article 5, paragraph 1). The seven principles are written in the text: identify the hazards; locate the points where control is essential; set critical limits there; monitor them; provide for corrective actions; verify periodically that the whole works; and document, “depending on the nature and size of the food business” (Article 5, paragraph 2). The obligation begins after primary production (Article 5, paragraph 3): the coffee farm, outside the Union anyway, is not bound by it, the roastery is.

The text draws up no list of hazards; it is for the roastery to do so. For coffee, the preceding sections supply the material: ochratoxin A, which is controlled at purchase (lot analysis certificate); acrylamide, which is controlled at heating; foreign bodies, stones and metals, which the destoner catches; glass, the reason for an instant coffee recall in June 2025 (case 3). Since Regulation (EU) 2021/382, in force since March 24, 2021, Annex II to Regulation 852/2004 adds two requirements: a “food safety culture,” that is, the commitment of management and the training of everyone, proportionate to the size of the business (Chapter XI bis), and the separation of equipment that has touched an allergen (Chapter IX, point 9), which concerns the roastery that flavors coffee with a hazelnut or almond flavoring (source 2). The viewpoint Growing without burning explains, from inside a roastery, when and how this logic becomes unavoidable: read it rather than a summary.

Traceability: one step back, one step forward

Regulation (EC) No 178/2002 sets the rule in its Article 18: every operator must be able to identify any person who has supplied it with a food, and the businesses to which it has supplied its products, and make this information available to the authorities “on demand” (source 3, Article 18, paragraphs 2 and 3). This is the principle summed up as “one step back, one step forward.” The text covers only business customers, not the consumer, and it sets no response time: the 24-hour figure that circulates in the trade comes from private standards or guides, not from this regulation.

Nothing in Article 18 obliges a roastery to link, internally, the bag of green to the lot sold. Another article nonetheless makes it indispensable. When a dangerous food is part of a lot, “it is presumed that the whole” of the lot is too, unless a detailed assessment proves otherwise (source 3, Article 14, paragraph 6). The lot that the roastery defines therefore fixes the scale of its recall. One who roasts three greens in the same lot without noting it will recall everything; one who keeps a record per roast (origin bag, date, profile, sales lot, customers) will recall only what must be recalled. The lot marking on the packaging, required by Directive 2011/91/EU, is described in section 3.

Upstream, the bag often arrives already marked: the rules of the International Coffee Organization (ICO) require that each export carry on each bag a lot-specific mark, made of the country code, the exporter code and a serial number (source 8, rule 3). It is a traceability identifier that the roastery can copy into its record.

Withdraw, inform, recall

Article 19 of Regulation 178/2002 distinguishes two actions. A withdrawal takes the product out of the commercial chain: the operator who “considers or has reason to believe” that a food it has imported, produced, processed or distributed is not safe “immediately” initiates withdrawal procedures once it has left its direct control, and informs the authorities. A recall goes all the way to the consumer: if the product may have reached them, the operator informs them “effectively and accurately” of the reasons for the withdrawal and, if necessary, recalls the products already supplied (source 3, Article 19, paragraph 1). It also informs the authorities without delay as soon as it thinks a product may harm health, and cooperates with them (paragraphs 3 and 4). A distributor that touches neither the packaging nor the label withdraws within the limits of its activity and passes on what makes it possible to trace the product’s path (paragraph 2).

The operator does not itself notify the European rapid alert system, the RASFF: it informs its national authority, and it is the State that notifies the others through this network when the risk is serious (source 3, Article 50, paragraphs 2 and 3).

Rappel Conso: the public declaration

In France, every product recall is declared on a public website. The obligation comes from Article L. 423-3 of the Consumer Code and, for foods, from Article L. 205-7-1 of the Rural Code; its terms are set by the order of January 20, 2021 (standardized order number, or NOR, ECOC2030070A, Journal officiel of January 23, 2021), in force since April 1, 2021 (source 4, Article 11). The professional declares on a restricted site, ticks a box attesting that the competent authority has been informed, and the notice is published only after approval by the administration (Article 4); the annex to the order lists the information to be supplied, mandatory or not, public or not (Article 6). Since March 11, 2026, an order of February 20, 2026 adds the quantity of products sold and its unit (source 5, summary: the amending order was not read).

Failing to declare, or declaring inaccurate or incomplete information, is punishable by the fine for fifth-class petty offenses, “incurred as many times as there are products concerned by the recall”; and the distributor that fails its withdrawal or recall obligations for a non-animal food incurs the same class of fine (source 6, Decree No. 2019-307 of April 11, 2019, Articles R. 452-5 and R. 452-3-1 of the Consumer Code).

A published notice says what the roastery must be able to answer: the barcode, the lot number, the best-before date, the sales period, the geographic area, the distributors, what the buyer must do. Notice 2023-07-0204 gives a complete example for a coffee sold in two départements (case 1). And because the dataset is open, anyone can count: between July 20, 2023 and July 28, 2026, eight coffee recall notices for mycotoxins, seven of which name ochratoxin A (source 9, count made on October 21, 2026 by searching the word “café” in the category “cacao, café et thé”).

What the roastery must be able to show

• proof of the declaration of its establishment, and its update when the activity changes;
• a hazard analysis and its control points, documented in proportion to its size;
• the list of its suppliers and its professional customers, lot by lot;
• a record per roast that links the bag of green to the lot sold;
• the OTA analysis certificates of the lots purchased, and, if it delivers beyond local retail, its acrylamide measurements;
• a withdrawal and recall procedure, with access to the Rappel Conso professional site.

None of these documents has a format imposed by Union law; it is their existence, and the ability to produce them when the authority asks, that the texts require.

Does the authority ask for them often? No public statistic says how often a roastery is inspected. The only national survey devoted to coffee that can be read, published by the DGCCRF on April 24, 2018, visited 20 establishments in 32 visits, importers, roasters and resellers, checked online sales sites and analyzed 21 samples: water, ash, stones, residual caffeine of decaf, without a search for ochratoxin (source 10). It gave rise to no legal proceedings, but to an injunction over health claims on a website. Checking exists, it is rare, and it concerns fairness as much as safety: it is traceability kept up day to day that protects the roastery the day a lot goes wrong.

The sources for this section

1. Regulation (EC) No 852/2004, hygiene of foodstuffs, Articles 5 and 6 (original version; version consolidated as of March 24, 2021 downloaded) · online · primary
2. Regulation (EU) 2021/382 of March 3, 2021, annexes to Regulation 852/2004: allergens, redistribution, food safety culture (OJ L 74 of March 4, 2021) · online · primary
3. Regulation (EC) No 178/2002, consolidated version of January 1, 2026, Articles 14, 18, 19 and 50 · online · primary
4. Order of January 20, 2021 on the digital declaration of product recalls by professionals on a public website, NOR ECOC2030070A, Journal officiel of January 23, 2021 · online · primary · reading: summary
5. Entreprendre Service Public, news item of March 13, 2026 on the order of February 20, 2026 amending the order of January 20, 2021 · online · secondary
6. Decree No. 2019-307 of April 11, 2019 on penalties for the withdrawal and recall of foods other than of animal origin, Journal officiel of April 13, 2019 (Articles R. 452-3-1 and R. 452-5 of the Consumer Code) · online · primary
7. DRAAF Occitanie, “Sécurité sanitaire des aliments : une police unique pour protéger le consommateur” · online · secondary · reading: summary
8. ICO, Rules on Statistics, Certificates of Origin, ICC-102-9 Rev. 5, October 7, 2022, rules 3 and 4 · online · primary
9. Rappel Conso, open dataset rappelconso-v2-gtin-trie, notices 2023-07-0204, 2023-10-0153, 2025-06-0045, 2025-07-0128, 2025-07-0140, 2025-10-0299, 2026-04-0324, 2026-06-0255, 2026-07-0280, queried on October 21, 2026 · online · primary
10. DGCCRF, “Authenticité et qualité du café,” April 24, 2018, Wayback capture of July 28, 2021 · online · primary