In the world of food product recalls, last year was an anomaly. As COVID-19 appeared and began to spread across the globe, the food industry was affected significantly. While some companies struggled to keep the lights on, others were overwhelmed by the massive increase in consumer demand for their food products. Overall, industry struggled to feed the world while keeping its employees safe, and the regulators struggled to effectively and consistently execute their own responsibilities.

The consequence of these changes is that we witnessed a dramatic decrease in the numbers of recalls last year. In 2018, two years before the pandemic hit, there were a total of 714 recalls. In 2019, the year before COVID-19 emerged, there were 643. Last year, amidst the virus swirling throughout the U.S., the numbers dropped to only 420. The last time there were fewer food product recalls in the U.S. was 2011 — an entire decade ago.

In turn, as the months passed and industry (and the U.S. as a whole) became more skilled at controlling for the spread of COVID-19, and as FDA began to consider whether to reawaken its inspection apparatus, we fully expected to see more recalls being announced by industry.

Rather, the opposite has occurred.

So far in 2021, there have been a total of only 93 recalls of FDA-regulated products. This means that, on the FDA side, the food industry is on pace to have only 223 voluntary recalls this year. Those numbers are stunning when compared to the 699 voluntary recalls of FDA-regulated products in 2016.

On the USDA side, the numbers are still very low. As noted, in 2020, there were only 31 recalls of USDA-regulated products. That was the lowest number of recalls in any single year in the last two decades. This year, the USDA-regulated industry is once again on track to witness only 31 recalls. Here too, this number is stark when compared to the 150 recalls of USDA-regulated products in 2015.

So, what is driving this change? Most likely COVID-19, and the significant impact it has had on industry and the regulators alike. While my heart would like to ascribe the banner years — in terms of the total numbers of recalls — to our ability to more consistently produce a safer product, the timing is likely too coincidental.

In my humble view, the lesson to be learned here is that, while industry may be enjoying a slight reprieve from the regulators' focus and attention on recall-causing issues, the agencies will be back. Just as the numbers of recalls are trending low, as with anything in life, there will come a moment when they begin to swing back. Thus, all companies should take the time now to identify and address any weaknesses, to ensure that, when the pendulum does swing the other way, they are not part of the correction.

A new year brings even fewer recalls

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