Complete Guide to Processed Food Recall – BPOM Regulation No. 22 of 2025

In the world of the food industry, nothing is more crucial than consumer safety. When a product is proven to contain a hazard or violate standards, swift and decisive action is non-negotiable. This is why BPOM Regulation Number 22 of 2025 concerning the Withdrawal and Destruction of Processed Food has been introduced.

This regulation is not just a legal document; it is a mandatory guideline for every Food Business Actor (Producers, Importers, and Distributors) to protect the public and maintain business reputation. By understanding this regulation, you not only comply with the law but are also ready to handle a Processed Food Withdrawal (Food Recall) situation professionally.

This guide will thoroughly dissect everything from food risk classification (Class I, II, III), the withdrawal and destruction procedures, to the administrative sanctions that await.

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1. Definitions and Types of Food Recall

Before diving into compliance, it’s important to understand the two core concepts behind this regulation.

a. What Is a Food Recall and Destruction?

• Food Recall: The process of stopping the distribution and withdrawing processed food (packaged food and beverages) that fail to meet safety, quality, or nutritional requirements, or that violate applicable laws.
• Destruction: A follow-up action to eliminate recalled products so that they cannot be consumed or re-entered into circulation.

b. Types of Recall: Mandatory vs. Voluntary

Type	Key Definition	Implementation Basis
Mandatory Recall	An official order from BPOM requiring a business to withdraw its product from circulation.	Issued if the product poses high health risks or severe regulatory violations.
Voluntary Recall	A recall initiated directly by the business (manufacturer/importer).	Conducted once the company identifies or suspects its product does not meet the requirements.

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2. Risk Classification (Class I, II, and III)

Food recalls are not all equal — BPOM classifies them into three risk levels, each determining how severe the health impact is and how long the recall must be completed.

Recall Class	Health Risk Level	Max Recall Duration	Main Triggers
Class I	Critical / Life-threatening	14 Calendar Days	May cause death or permanent health damage (e.g., undeclared allergens, deadly microbial contamination).
Class II	Moderate Risk	30 Calendar Days	May cause temporary illness (e.g., high pesticide residue or microbial contamination with short-term impact).
Class III	Technical / Non-Health	180 Calendar Days	No serious health risk, but violates labeling or quality standards (e.g., incorrect nutrition info, misleading claims).

Why does this matter?

• Class I (14 Days): Shows the urgency of traceability — companies must act fast to prevent harm.
• Class III (180 Days): Allows more time to fix technical violations without health risks.

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3. Step-by-Step Recall Procedure

Here are the five mandatory steps every food business must follow under BPOM Regulation No. 22 of 2025:

1. Stop Distribution and Notify Authorities
   • Immediately halt sales, distribution, or imports of the affected product.
   • Notify BPOM within 24 hours through the official recall system.
   • Inform all distributors and retailers to stop selling the product.
2. Prepare a Recall Plan
   • Outline methods, target quantities, and traceability data.
   • Include follow-up actions such as reprocessing, relabeling, or destruction.
3. Execute the Recall and Public Announcement
   • Conduct the recall within the required timeline (14, 30, or 180 days).
   • Publish a recall notice via websites, media, or retail outlets explaining reasons and potential risks.
4. Secure and Quarantine Recalled Products
   • Store recalled products separately to prevent re-entry into the market.
   • Choose an appropriate follow-up action:
     • Destruction – for Class I products.
     • Reprocessing or Relabeling – for Class II or III products, with BPOM approval.
     • Return to Supplier/Exporter – for imported products.
5. Submit Final Report & Proof of Destruction
   • Destruction must be witnessed by BPOM officers.
   • Submit a final recall report and Destruction Minutes (BAP) within 30 working days, including photos or videos.

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4. What Happens If You Don’t Comply

Compliance with the recall and destruction process isn’t optional — it’s a legal obligation.
If a business fails to act, misses deadlines, or neglects reporting, BPOM can impose administrative sanctions, including:

1. Written Warning – Official notice from BPOM to correct violations.
2. Fines or Financial Penalties – For food safety-related breaches.
3. Temporary Suspension – Stopping production or sales until compliance is achieved.
4. Revocation of Licenses and Certificates – Such as CPPOB, HACCP, SNI, or PB-UMKU, potentially shutting down operations entirely.

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Compliance is Not an Option, But a Business Investment

BPOM Regulation No. 22 of 2025 highlights that food recall is part of responsible business practice.
With a solid traceability system and fast response, you can avoid penalties, protect your brand, and build consumer trust.

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