Recall procedures

CATEGORY: Key processes and cross-cutting issues

Definition

A recall is any measure aimed at achieving the return of a dangerous product that is already in the hands of consumers or other end users. Recalls may be undertaken directly by economic operators on a voluntary basis (often as a result of guidance and suggestions provided by a market surveillance authority) or as a “mandatory recall” ordered by the authority. Other corrective actions can also be taken by economic operators or ordered by authorities, including:

Marking a product that poses risks in certain conditions with suitable warnings;
Making the marketing of a product subject to prior conditions in order to make it safe;
Completely banning the marketing of a product;
Withdrawing a product already on the market from the supply chain.

Being ready for a recall

Being prepared is key to be able to act swiftly and effectively when a recall becomes necessary so businesses should have in place a written recall strategy. An important element of the strategy is to establish an action plan.

Key elements of an effective actionplan:

Appoint a corrective action team consisting of people with relevant expertise;
Establish robust product safety monitoring procedures to identify potential safety issues;
Establish product traceability strategies allowing for accurate identification of products and actors in the supply chain. This includes marking the products with contact details of an economic operator based in the EU and product identifiers (e.g. model name) and serial or batch number);
Establish strategies to facilitate direct consumer contact, taking account of the EU General Data Protection Regulation (GDPR). This could include using product registration systems and customer loyalty programmes for safety purposes;
Establish a communication strategy that maps available communication channels and includes templates (e.g. for a recall notice, press release or internal messages);
Stimulate a possible recall event to familiarise staff with the action plan and the role that they have in securing a timely and effective outcome.

Key elements of an effective actionplan

Performing a recall

Implementing a recall will require the economic operator to go through the following steps:

Determine the level of risk by performing a risk assessment. (See factsheet on risk management)
Decide on which kind of action to take. If it is decided to recall the product, consideration needs to be given to which products (e.g. batches) need to be recalled and whether any additional measures are needed.
Inform relevant authorities in all the Member States where the product has been placed on the market. This can be done via the Product Safety Business Alert Gateway. Operators should adopt a standardised approach to cross-border recalls, ensuring that corrective actions are implemented in a speedy and consistent manner across all affected areas (under the control of national competent authorities).
Coordinate and cooperate with other actors, e.g. economic operators in the supply chain, and online marketplaces so they can stop unsafe products from being offered for sale.
Communicate the recall to consumers in a clear way and using a variety of communication methods (including direct consumer contact, whenever possible). See guidance below on recall communication.
Retrieve products from consumers in a way that is convenient and cost-free for them. This could be achieved for instance by:
- Arranging for pre-paid, addressed postage if the product is to be shipped back by the consumer;
- Arranging for the retrieval/repair/replacement of bulky, non-portable products at consumers’ home;
- Allowing customers to return the product to any shop that supplies the product, rather than restricting it to the outlet where the product was purchased;
- Accepting recalled products without proof of purchase.
Provide speedy and attractive remedies (for instance repair, replacement and/or refund) and possible extra incentives (such as discounts or vouchers) to motivate consumers to act.
Deal with the retrieved products in a transparent and auditable way, ensuring that recalled products or any of their dangerous parts cannot be resold (be it within or outside the EU).
Monitor the progress of the recall to assess the effectiveness of the actions undertaken. This should consider a variety of factors, including measuring parameters such as number of units still remaining on the market / recovered from the supply chain / recovered from consumers or repaired in the field.
Adjust or expand recall actions, if the monitoring results are not satisfactory. If, for instance, the response rate is low, it may be necessary to increase or divert the communication efforts. If the demand for repairs is higher than expected, it may be necessary to increase the repair workforce temporarily or outsource the work.
Terminate the recall, if justified by the monitoring results and approved by the competent market surveillance authority. The business should however maintain the recall capability in case the recall has to be resumed.
Learn from experience to avoid that the problem re-occurs. This includes reviewing the company’s production standards and implementing any necessary changes. It also includes an assessment of the effectiveness of the recall action plan.

Communicating recalls to consumers

A recall can only prevent harm if consumers return, or at least stop using, the dangerous product. Therefore, effective recall communication is of vital importance.

Channels for recall communication

Many consumers are simply not aware that they own a dangerous product, so the very prerequisite for taking action is not met. To help reach as many consumers affected by a recall as possible:

Whenever feasible, use direct consumer contact (e.g. personalised letter; direct email; telephone call or text message; alert through recall app or connected device). Consumer data is often available (e.g. because the product was registered, bought online or through a loyalty programme, or delivered to a consumer’s home). See the guidance Recall process from A to Z on how to use consumer data for recalls in the light of the GDPR.
Use a wide range of communication methods, if not all consumers can be reached directly. This may include, in particular, the company’s website, social media channels, newsletters, retail outlets and, as appropriate, announcements in the mass media and other communication channels. Online marketplaces can also play an important facilitating role in passing recall information to consumers, given that, depending on their business model, they may be able to identify consumers who have purchased a recalled product.
Adapt communication tools to consumer characteristics. For instance, social media channels are particularly effective for targeting younger audiences while older and less digitally-confident audiences may be better reached through local newspapers or other traditional media.

Content and format of a recall notice

Recall notices should encourage consumers to take action, and therefore need to be clear and inspire an appropriate level of urgency. A good recall notice (available here):

Is available in the official language(s) of the country where the product is being recalled.
Has an eye-catching format and graphical elements to enhance visibility and alert consumers to the risk (e.g. red outline and bolding/highlighting of key words).
Uses plain, concise and easy-to-understand language, avoiding jargon and technical terms. Short paragraphs with subheadings/bullet points are preferable to lengthy continuous text.
Contains all key information as set out in the below recommended template for a recall notice:

Further guidance

Comprehensive guidance is provided in the document “Recall process from A to Z: Guidance for economic operators and market surveillance authorities”
Further guidance, including downloadable templates for a recall notice in all EU languages, is provided on the Safety Gate webpage
OECD Policy guidance on recalls 2018

Disclaimer

The provided information was updated in 2022. Please note that some of the provided information could change during possible subsequent revisions of legislation, standards, and guidance documents. For any updates of official information on the EU product safety rules, please follow the Link to the webpage of the European Commission.

This document was produced with the financial support of the European Union. Its contents are the sole responsibility of SPEAC project and do not necessarily reflect the views of the European Union.