§611 Mandatory Recall Authority

MoCRA empowers FDA to mandate recalls if voluntary action is not fast enough. Companies must show they can trace lots, notify stakeholders, and confirm removal from the market.

Key obligations

  • Maintain a written recall plan with roles, decision criteria, and notification scripts.
  • Assemble an incident response team with clear escalation paths.
  • Track distribution to lot level for every sales channel.
  • Run mock recalls and document lessons learned.

Evidence regulators expect to see

  • Recall playbook, contact rosters, and communication templates.
  • Distribution exports that connect lots to customers or retail locations.
  • Incident logs showing prior withdrawals or drills and the corrective actions taken.
  • Supplier and 3PL agreements that describe recall responsibilities.

Intake sections that populate this section

Relevant SOP templates

Risk of non-compliance

  • FDA can order a compulsory recall and publish consumer alerts.
  • Retailers may impose chargebacks or remove the brand from planograms.
  • Civil liability increases if the recall is slow or incomplete.

Further reading

Use these notes to brief leadership and justify remediation work. As you complete the intake, the Generate Package step merges your answers into each SOP so you can demonstrate compliance with §611 Mandatory Recall Authority.