In the food and beverage sector, product recalls are an unavoidable part of business, but their financial and operational impact is often underestimated. While most companies focus on retrieving stock and managing public relations, a less visible cost can quietly compound in the background: customs duties. 

Whether caused by labelling errors, undeclared allergens or contamination, product recalls involving imported goods can often leave companies paying duty twice—once on import and again if the goods are returned or destroyed without the correct procedures. 

The Overlooked Role of Customs in Product Recalls 

Product recalls tend to trigger urgent action: removing stock from shelves, notifying distributors, and arranging disposal. But amid the rush, few businesses ask: What about customs? 

The recalled products often incurred multiple customs duty hits, but with proper management, these duties can be recovered. Let’s unwind the supply chains in a common, typical scenario. 

Case Study: BritBites and the Cost of a Labelling Error 

The Company: BritBites Ltd is a UK-based manufacturer of premium snack bars that exports to Europe and North America. 

The Scenario: In early 2025, BritBites voluntarily recalled a batch of peanut butter protein bars following a distributor report that allergen information was missing. Thousands of units needed to be returned to the UK for disposal. 

The Challenge: BritBites had already paid customs duties on imports of their snack bars to overseas markets. Without intervention, they risked additional duty and VAT on re-importing the bars on their return to the UK. 

The Solution: BritBites worked with their customs consultant to: 

  • Recover the duty paid in the overseas markets. Most countries operate similar “special procedures” or reliefs that enable duty recovery in these circumstances. For example, the US operates a scheme called Drawback that can be claimed up to five years after the goods are imported. A claim must be built and submitted, providing an audit trail linking the imports to the exports and referencing the appropriate customs declarations. 
  • Apply for customs relief on the return of the protein bars to the UK through Returned Goods Relief (RGR). The claim is simple: The importer must include the correct customs procedure code on the re-import declaration. However, to survive any challenge, the importer must hold evidence that the goods were originally exported from the UK, and certain other conditions apply. 

The Outcome: The company avoided double taxation, remained compliant, and reduced the financial impact of the recall. 

The Lesson: Customs planning isn’t just for regular trade; it’s essential during disruption. 

What You Need to Get Right 

Businesses must act deliberately to benefit from duty relief during a product recall. Here are four areas to focus on: 

1. Documentation

  • Pull together all documentation used to support customs declarations along the supply chain. In the case of the above example, this would include export documents to the US, import documents into the US, export documents back to the UK and import documents relating to the recalled products. Documents include customs declarations and commercial invoices. 
  • Maintain traceability of batch codes, SKUs, and quantities.
  • Log all correspondence with distributors regarding the recall.

2. Build the Claims

Application forms and conditions apply to all of these reliefs. You need to identify and complete the correct forms, understand and evidence any conditions and submit the necessary supporting particulars. 

3. Submit the Claims 

4. Prepare for Audit Checks

Prepare files ready for audit for the required period, typically six years.

One Final Thought

At Barbourne Brook, we work with clients to build resilience into their supply chains through compliance and proactive customs planning. The real cost of a recall isn’t just the lost product; it’s the opportunities missed to protect your business. 

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