Product Recall Monitor
March 2025
The Liberty Specialty Markets (Liberty) Product Recall Monitor explores different drivers of product recalls across a variety of industries. In this edition, we focus on allergens and their effects on the Australian food industry.
How to access pre-incident credit to prepare
for a product recall
All Liberty Insured’s have pre-incident funds available as part of their Liberty Product Recall policy. The allocation is 10% of the net base premium which can be used towards any Liberty pre-approved pre-incident training. These pre incident funds can help you prepare for product recall situations.
What is pre-incident training?
Can Liberty consultants provide assistance during a product recall event?
Who is on Liberty’s panel?
Are consultant’s costs covered by Liberty’s policy as a result of an Insured Event?
Does the self-insured retention apply to Liberty consultants?
Contact us
Liberty is not authorised to provide financial product advice. The information in this document does not take into account your objectives, financial situation or needs. Always consider the applicable policy wording and other relevant documents before deciding to acquire a financial product. This information is current as at February 2025. Liberty means Liberty Specialty Markets, a trading name of Liberty Mutual Insurance Company, Australia Branch (ABN 61 086 083 605; AFSL No. 530842 (for claims handling and settling services only)) incorporated in Massachusetts, USA (the liability of members is limited); Liberty Specialty Markets Hong Kong Limited (UBI 66395065); Liberty Specialty Markets Singapore Pte Limited (UEN 201538069C); and Liberty Specialty Markets Singapore Pte Limited, Labuan Branch (Company No. LF12903), a licensed insurer under the Labuan Financial Services and Securities Act 2010 (Licence No. IS2016162).
If you’re looking for more information regarding product recall insurance, please contact our specialist Crisis Management underwriters.
Visit the Liberty Specialty Markets website
Learn more about Liberty Specialty Markets in Australia
CRISIS MANAGEMENT // NEWSLETTER // AUSTRALIA
What is pre-incident training?
Some of the services that our consultants offer include:
Mock recall exercises
Recall plan and crisis management plan reviews
Media training
Root cause analysis exercises
Contingency and business continuity planning/project management
Assistance in the development of risk based supplier management systems and programs
Can Liberty consultants also provide assistance during a product recall event?
Yes. We know it is often how a client reacts in the critical first days, or even hours, of a crisis that can determine how severe a crisis will become. This is when the experience and expertise of Liberty’s crisis management consultants is most useful. They can provide advice and assistance to help deal with the crisis at hand. In the event of an incident which may give rise to an insured event, and as part of Liberty’s product recall policies, we have made available crisis management experts for the Insured.
Who is on Liberty’s panel?
Liberty’s panel of consultants includes Intelligent Risks and HACCP Australia. Representatives from Intelligent Risks and HACCP Australia are based in Sydney and are happy to meet with clients pre or post binding.
HACCP Australia
Based in North Sydney, with staff located in Brisbane, Melbourne, Hong Kong & London. HACCP have over 20 years of involvement in the insurance industry, responding to client’s pre-incident and crisis response requirements. They have been in the food technology business for many years of "on the factory floor" experience. This extensive experience and knowledge make HACCP Australia one of the most experienced Crisis Management consultants in Australia and a significant addition to the value and expertise our clients can access. Accidental contaminations are historically the most common type of claim under a contaminated Products policy. Being able to provide access to the expertise and experience of HACCP Australia in the event of an incident will help clients better handle these incidents.
Intelligent Risks
Intelligent Risks was established in early 2001 and has grown into a market leading security, risk, due diligence and crisis management advisory firm. Intelligent Risks support large multinational clients and government agencies worldwide and leading Australian firms by delivering outcomes that build on best practice, and which are adapted to each client’s requirements and capabilities. The team is led by Neil Fergus who has many years of experience managing crisis events, including product recalls, extortion and malicious products tampering, for both the corporate and government sectors.
Are consultant’s costs covered by Liberty’s policy as a result of an Insured Event?
These costs are included under the policy, and continue for 12 months from first discovery of the insured event if indemnity is accepted under the policy. In the event indemnity is not accepted, Liberty will still pay the costs of the consultants up to the time Liberty first advises indemnity is not available under the policy.
Does the self-insured retention apply to Liberty consultants?
No self-insured retention applies to consultant and advisor costs. A self-insured retention is a specified amount of money that an insured party agrees to pay out-of-pocket before their insurance policy coverage begins for a particular claim.
Allergens in the food industry
Most recalled products
Undeclared allergens
Imported foods
Regulatory changes
Biodegradable and biobased food packaging
Why Liberty?
How to access pre-incident credit to prepare for a product recall
Contact us
Food and beverage
Home and living
Babies and kids
Health and lifestyle
Contact us
Learn about Liberty's Contaminated Products Insurance
View Liberty's examples of costs involved in product withdrawals
Learn the difference between Liberty's Contaminated Products Insurance and a standard product liability policy with a Recall Expense Extension
AP0986
Last updated March 2025
About Liberty Specialty Markets
Connect and join the Liberty conversation
All benefits and covers described in this newsletter are subject to the terms of the relevant policy
Allergens in the food industry
Australia has one of the highest rates of food allergies recorded in the world, affecting more than 1.5 million Australians. It also has one of the highest rates of hospital admissions due to anaphylaxis worldwide. Over the past five years, there has been a significant 51% rise in anaphylaxis cases reported in emergency departments of Australian hospitals, with annual cases now exceeding 11,5001. Undeclared allergens such as nuts present a major hazard in the food industry and are responsible for nearly half of all recalls. Between January 2020 and December 2024, Australia recorded a total of 431 food and beverage recalls, with 210 of those linked to undeclared allergens, representing 49% of all recall notifications. Allergen-related recalls consistently lead the statistics, followed by microbiological contamination issues and foreign matter; notably, in 2024, 64% of food and beverage recalls in Australia were allergen-related2.
Food & beverage recalls Australia
2024
2023
2022
2021
2020
0
50
100
150
Allergen-related recalls
Total recalls
Recall cause
2020 to 2024
Undeclared allergens
Foreign matter
Others
Microbiological
Chemical
Most recalled products
Mixed and/or processed foods are the most recalled products during this timeframe*, primarily because they contain multiple ingredients and undergo significant processing, heightening the risk of cross-contamination. Additionally, confectionery, bread, bakery items, and dairy products are often recalled due to the presence of undeclared allergens.
Allergen-related recalls by product category
Mixed and/or processed foods
Dairy products
Fruits, vegetables and herbs
Breads and bakery
Confectionery
26%
11%
10%
10%
10%
49%
22%
10%
6%
13%
44%
Over the last five years, most recalls were linked to a single undeclared allergen. However, 22% of these recalls involved multiple undeclared allergens. The allergens that were most frequently undeclared included milk, tree nuts, wheat/gluten, and eggs.
Undeclared allergens
Milk
Wheat
Others
Tree nuts
Eggs
30%
12%
15%
13%
30%
195
Undeclared allergens
Although imports account for only around 11% of food consumption by value3, they are responsible for nearly 50% of allergen-related recalls. This inconsistency can be traced back to differing allergen regulations among various countries, which include variations in labelling requirements and the particular allergens that need to be disclosed. It's possible that some foreign manufacturers may not be fully informed about Australia's specific regulatory standards, and that importers may lack sufficient quality control measures. Additionally, countries with lower rates of food allergies may not enforce the same strict regulations on food manufacturers. This variation in regulatory standards can result in inconsistencies as to how allergens are managed and disclosed in imported food items.
Undeclared allergens 2023-2024 (imported vs local)
Imported
Local
47%
53%
Imported foods
Regulatory changes
New allergen labelling requirements for food came into effect in Australia on 25 February 2024. All food products packaged after this date must adhere to the updated regulations. However, items that were packaged and labelled prior to 25 February 2024 and met the previous allergen declaration standards may still be sold until 25 February 20264.
What’s changed?
The Food Standards Code now mandates that food and ingredients must be labelled with specific required names. This update also stipulates that individual tree nuts, molluscs, and specific cereals must be declared separately.
wheat
walnut
sulphites**
egg
mollusk
crustacean
fish
soy, soya, soybean
peanut
lupin
milk
sesame
almond
brazil nut
cashew
macadamia
pecan
pistachio
pine nut
barley*
oats*
rye*
* Barley, oats and rye must be declared if they contain wheat ** Sulphites must be declared when added in amounts equal or more than 10 milligrams per kilogram of food.
Declarations must be made in the statement of ingredients using bold font and a font size no smaller than that used for other listed ingredients (e.g. maltodextrin (wheat), milk powder), and a separate allergen summary statement in bold font beginning with the word ‘contains' (e.g. contains milk) located in the same field of view and directly next to the statement of ingredients. More details of these changes can be found in the Food Standards Australia New Zealand report Plain English Allergen Labelling.
Biodegradable and biobased food packaging
New allergen labelling requirements for food will take effect in Australia on 25 February 2024. All food products packaged after this date must adhere to the updated regulations. However, items that were packaged and labelled prior to 25 February 2024 and met the previous allergen declaration standards may still be sold until 25 February 20264.
DID YOU KNOW?
Allergens can migrate from packaging materials into allergen-free foods.
As numerous countries implement bans on specific single-use plastics, there has been a notable increase in the demand for biodegradable and biobased food packaging. These innovative packaging solutions are increasingly made from protein-based materials sourced from milk, eggs, soy, rye, and wheat.
Recent research indicates that food contact materials made from wheat or rye, which contain gluten, can transfer gluten into gluten-free foods. A study conducted in Germany analysed gluten migration from six types of food contact materials, such as cutlery, wafer cups, plates, and straws. The findings revealed that the level of gluten migration differed – based on material properties, the type of food, and the length of contact time5. Gluten migration was detected in all wheat-based food contact materials except for cutlery, probably because of the minimal contact areas and brief contact times during pricking and cutting. On the other hand, plates exhibited a troubling level of migration, with gluten concentrations soaring to 203 mg/L.
According to the Food Standards Code in Australia, businesses making ‘gluten-free’ claims must be confident that their products or menu items contain no detectable gluten (i.e. < 5 mg/L). The migration levels observed exceeded the detection threshold, raising concerns. While individuals with wheat allergy and coeliac disease should avoid using these materials, there are currently no regulatory requirements for allergen labelling in food contact materials.
https://allergyfacts.org.au/get-involved/food-allergy-week/
https://www.foodstandards.gov.au/food-recalls/alerts
https://www.aph.gov.au/Parliamentary_Business/Committees/House/Agriculture/FoodsecurityinAustrali/Report/Chapter_3_-_Food_production _consumption_and_export#:~:text=We%20do%20not%20produce%20everything,of%20food%20consumption%20by%20value.&text=A%20different%20view%20on%20the,security%20on%20a%20global%20scale.
https://www.foodstandards.gov.au/business/labelling/allergen-labelling
Gluten migration from biodegradable food contact materials poses a risk to celiac disease patients | European Food Research and Technology
Gluten
migration
Regulatory requirements
Why Liberty?
Every day Liberty helps protect around a third of all products sold in major Australian supermarkets should they face a product recall. Liberty’s Crisis Management insurance products help to provide financial protection and assistance in the event of a product recall, malicious product tampering event or a product withdrawal.
Experts in crisis management
Market leading cover and best in class crisis support
Exceptional service, risk engineering and local claims handling
24/7 support
Find out more
Experts in crisis management
Liberty has the largest recall team in Australia, comprised of experienced underwriters with more than 20 years experience.
Our bespoke policies are tailored to suit the individual needs of clients, covering:
Accidental contamination
Product defect
Intentionally impaired ingredient
Government recall
Alleged contamination
Product extortion
Malicious product tampering
Adverse publicity
Market leading cover and best in class crisis support
Our market leading Contaminated Products Insurance includes Retailers Withdrawal coverage*. This means our policy also covers product withdrawal due to a quality issue with no threat of bodily injury. This fills the significant gap in coverage for many clients who find themselves exposed when their product is subject to a withdrawal from supermarkets due to a quality issue, as opposed to a food safety issue.
* All benefits and covers described in this monitor are subject to the terms of the relevant policy.
Exceptional service, risk engineering and local claims handling
We understand the need for a quick turnaround. Liberty has Crisis Management underwriters in all eastern states and can meet with clients when needed the most.
Our local claims handling is managed out of Sydney by our senior claims specialist, James Paul.
We have a dedicated Risk Engineer, Luis Gonzales, who provides technical support to underwriters regarding risk. Luis is available to meet with your client to help ensure we fully understand your client’s business.
24/7 support
You can expect 24/7 support from our dedicated crisis management consultants. We provide access to leading crisis management consultants, market leading food technologists and PR experts to assist you with the prevention, management and recovery from a product recall event.
If you would like to know more about product recalls and withdrawals and the tailored solutions we provide, please get in contact with a member of the Liberty Crisis Management team.
Find out more
Hover over icons to see labels
10%
Hover over icons to see labels
References
References 1 https://allergyfacts.org.au/get-involved/food-allergy-week/ 2 https://www.foodstandards.gov.au/food-recalls/alerts 3 https://www.aph.gov.au/Parliamentary_Business/Committees/House/Agriculture/FoodsecurityinAustrali/Report/Chapter_3_-_Food_production_consumption_and_export#:~:text=We%20do%20not%20produce%20everything,of%20food%20consumption%20by%20value.&text=A%20different%20view%20on%20the,security%20on%20a%20global%20scale. 4 https://www.foodstandards.gov.au/business/labelling/allergen-labelling 5 Gluten migration from biodegradable food contact materials poses a risk to celiac disease patients | European Food Research and Technology
Why Liberty?
Every day Liberty protects around a third of all products sold in major Australian supermarkets should they face a product recall. Liberty’s Crisis Management insurance products help to provide financial protection and assistance in the event of a product recall, malicious product tampering event or a product withdrawal.
Experts in crisis management
Market leading cover and best in class crisis support
Exceptional service, risk
engineering and local claims handling
24/7 support
Find out more
Experts in crisis management
Liberty has the largest recall team in Australia, comprised of experienced underwriters with more than 20 years experience.
Our bespoke policies are tailored to suit the individual needs of clients, covering:
Accidental contamination
Product defect
Intentionally impaired ingredient
Government recall
Alleged contamination
Product extortion
Malicious product tampering
Adverse publicity
Market leading cover and best in class crisis support
Our market leading Contaminated Products Insurance includes Retailers Withdrawal coverage*. This means our policy also covers product withdrawal due to a quality issue with no threat of bodily injury. This fills the significant gap in coverage for many clients who find themselves exposed when their product is subject to a withdrawal from supermarkets due to a quality issue, as opposed to a food safety issue.
* All benefits and covers described in this monitor are subject to the terms of the relevant policy.
Exceptional service, risk engineering and local claims handling
We understand the need for a quick turnaround. Liberty has Crisis Management underwriters in all eastern states and can meet with clients when needed the most.
Our local claims handling is managed out of Sydney by our senior claims specialist, James Paul.
We have a dedicated Risk Engineer, Luis Gonzales, who provides technical support to underwriters regarding risk. Luis is available to meet with your client to help ensure we fully understand your client’s business.
24/7 support
You can expect 24/7 support from our dedicated crisis management consultants. We provide access to leading crisis management consultants, market leading food technologists and PR experts to assist you with the prevention, management and recovery from a product recall event.
If you would like to know more about product recalls and withdrawals and the tailored solutions we provide, please get in contact with a member of the Liberty Crisis Management team.
Find out more
You can access pre-incident credit to prepare for a product recall
All Liberty Insured’s have pre-incident funds available as part of their Liberty Product Recall policy. The allocation is 10% of the net base premium which can be used towards any Liberty pre-approved pre-incident training. These pre incident funds can help you prepare for product recall situations.
What is
pre-incident training?
Who is on Liberty’s panel?
Can Liberty consultants provide assistance during a product recall event?
Are consultant’s costs covered by Liberty’s policy as a result of an Insured Event?
Does the self-insured retention apply to Liberty consultants?
What is pre-incident training?
Some of the services that our consultants offer include:
Mock recall exercises
Recall plan and crisis management plan reviews
Media training
Root cause analysis exercises
Contingency and business continuity planning/project management
Assistance in the development of risk based supplier management systems and programs
Can Liberty consultants also provide assistance during a product recall event?
Yes. We know it is often how a client reacts in the critical first days, or even hours, of a crisis that can determine how severe a crisis will become. This is when the experience and expertise of Liberty’s crisis management consultants is most useful. They can provide advice and assistance to help deal with the crisis at hand. In the event of an incident which may give rise to an insured event, and as part of Liberty’s product recall policies, we have made available crisis management experts for the Insured.
Who is on Liberty’s panel?
Liberty’s panel of consultants includes Intelligent Risks and HACCP Australia. Representatives from Intelligent Risks and HACCP Australia are based in Sydney and are happy to meet with clients pre or post binding.
HACCP Australia
Based in North Sydney, with staff located in Brisbane, Melbourne, Hong Kong & London. HACCP have over 20 years of involvement in the insurance industry, responding to client’s pre-incident and crisis response requirements. They have been in the food technology business for many years of "on the factory floor" experience. This extensive experience and knowledge make HACCP Australia one of the most experienced Crisis Management consultants in Australia and a significant addition to the value and expertise our clients can access. Accidental contaminations are historically the most common type of claim under a contaminated Products policy. Being able to provide access to the expertise and experience of HACCP Australia in the event of an incident will help clients better handle these incidents.
Intelligent Risks
Intelligent Risks was established in early 2001 and has grown into a market leading security, risk, due diligence and crisis management advisory firm. Intelligent Risks support large multinational clients and government agencies worldwide and leading Australian firms by delivering outcomes that build on best practice, and which are adapted to each client’s requirements and capabilities. The team is led by Neil Fergus who has many years of experience managing crisis events, including product recalls, extortion and malicious products tampering, for both the corporate and government sectors.
Are consultant’s costs covered by Liberty’s policy as a result of an Insured Event?
These costs are included under the policy, and continue for 12 months from first discovery of the insured event if indemnity is accepted under the policy. In the event indemnity is not accepted, Liberty will still pay the costs of the consultants up to the time Liberty first advises indemnity is not available under the policy.
Does the self-insured retention apply to Liberty consultants?
No self-insured retention applies to consultant and advisor costs. A self-insured retention is a specified amount of money that an insured party agrees to pay out-of-pocket before their insurance policy coverage begins for a particular claim.
References
Most recalled products
Most recalled products
Other
Contact us
If you’re looking for more information regarding product recall insurance, please contact our specialist Crisis Management underwriters.
Learn about Liberty's Contaminated Products Insurance
View Liberty's examples of costs involved in product withdrawals
Learn the difference between Liberty's Contaminated Products Insurance and a standard product liability policy with a Recall Expense Extension
Visit the Liberty Specialty Markets website
Learn more about Liberty Specialty Markets in Australia
Connect and join the Liberty conversation
AP0947
Last updated 6 December 2024
About Liberty Specialty Markets
All benefits and covers described in this newsletter are subject to the terms of the relevant policy
Liberty is not authorised to provide financial product advice. The information in this document does not take into account your objectives, financial situation or needs. Always consider the applicable policy wording and other relevant documents before deciding to acquire a financial product. This information is current as at August 2024. Liberty means Liberty Specialty Markets, a trading name of Liberty Mutual Insurance Company, Australia Branch (ABN 61 086 083 605; AFSL No. 530842 (for claims handling and settling services only)) incorporated in Massachusetts, USA (the liability of members is limited); Liberty Specialty Markets Hong Kong Limited (UBI 66395065); Liberty Specialty Markets Singapore Pte Limited (UEN 201538069C); and Liberty Specialty Markets Singapore Pte Limited, Labuan Branch (Company No. LF12903), a licensed insurer under the Labuan Financial Services and Securities Act 2010 (Licence No. IS2016162).
* Between January 2020 and December 2024