In that particular case the FDA notified the firm that it was considered it a [class I/II] recall but, according to the FDA, a press release/recall alert was not necessary, but would be published in a weekly report that is accessible to the public -if they look for it.
I read the guidance but missed your underlined above, that according to the SQF definition, the action was a withdrawal.
As I read the code, and this is just my impression, an intent of 5.3 (responsibilities) and 2.6.3 is that SQFI and the CB wants to be notified of anything public. While this recall was not "public," and had not entered commerce it could be argued it became public when it was published in the FDA report. The firm, to stay on the safe side, elected to notify the CB and SQFI once it was published.
Any other thoughts on this appreciated, this one is a little gray to me.