To cover up the horsemeat fraud, criminal food business operators tempered with their bookkeeping. This adversely affected the traceability of horsemeat and beef alike. This article assesses to what extent national food safety authorities in seven EU Member States issued recall orders to deal with this situation. Since no measurable food safety problems have been found, several countries consider that the conditions of Article 19 of Regulation 178/2002 have not been met. In some of these countries recalls orders, nevertheless, were issued based on national food law that has a wider scope. Other countries consider disruption of traceability sufficient justification to invoke Article 19.