Managing Food Safety Incidents Across Multiple Jurisdictions

Food safety incidents rarely remain confined to a single market. A product issue identified in one jurisdiction can quickly attract attention from regulators elsewhere, triggering information requests, testing, recalls, or other precautionary actions. For food companies operating across multiple markets, managing the regulatory response often becomes as important as investigating the underlying issue.

Regulators Are Increasingly Coordinating Across Borders

Food safety authorities are placing greater emphasis on cross-border coordination. In July 2026, all 11 ASEAN Member States participated in a WHO-supported food safety emergency exercise involving a contaminated product distributed across multiple countries [1]. The exercise focused on information-sharing, product tracing, recall coordination, and public communications.

These initiatives reflect a broader reality: regulators increasingly exchange information and coordinate responses when food safety incidents affect more than one market. As a result, a regulatory inquiry in one jurisdiction may quickly lead to attention from authorities in others.

What This Means for Companies

Once authorities in more than one market become involved, the product identified in the initial notice may be just the starting point. Other products which share the same ingredient, manufacturing facility, or production line may be impacted as well. Thus, determining the exact products and markets that are affected require a detailed traceability review and extensive analysis of the local laws.

At the same time, regulatory requirements are not harmonized. Recall thresholds, notification obligations, response deadlines, and communication expectations vary across jurisdictions. While companies need a consistent factual understanding of the incident, the regulatory strategy often requires separate assessment in each market.

This creates practical challenges. Regulators in different jurisdictions may request information at different times and impose different expectations, even while the company is still determining the root cause and distribution scope of the issue.

Is Your Crisis Management Plan Built for Multiple Jurisdictions?

An effective crisis management plan should do more than establish internal reporting and recall procedures. It should also help companies identify affected markets quickly, coordinate responses across jurisdictions, and manage differing local regulatory requirements.

Key elements may include:

• clear escalation and decision-making procedures;
• robust traceability systems;
• tested recall and communication protocols;
• regular crisis simulation exercises; and
• periodic review of local legal requirements.

Companies also should ensure that crisis management procedures are updated as regulations evolve. For example, China will implement its revised Administrative Measures for Food Recalls beginning on December 1, 2026 [2]. Under the revised Measures, the steps required to initiate Level I, Level II, and Level III recalls must be completed within 24, 36, and 48 hours, respectively. Separate rules are also specified for cross-border e-commerce food operators, which require the appointment of a domestic food producer or operator to carry out recalls in China [3]. These developments highlight the importance of keeping recall protocols aligned with changing local regulatory requirements.

As regulators continue to strengthen cross-border cooperation, companies should consider whether their crisis management procedures are designed for today’s multi-jurisdiction regulatory environment rather than a single-market recall scenario.

Keller and Heckman regularly assists companies with food safety incidents, product recalls, and related crisis management matters in China and across multiple jurisdictions in the Asia-Pacific region. If you would like to know more about this topic, please contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), Sharon Tian (tian@khlaw.com), or your existing contact at Keller and Heckman LLP.

[1] https://www.who.int/indonesia/news/detail/27-08-2026-who-works-with-asean-to-put-food-safety-emergency-systems-to-the-test
[2] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2026/art_d285e36b03ce4ce68832a098be50782f.html
[3] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/spcjs/art/2026/art_b0bcafe73bf747279b27cef39d04e6b1.html