Common product safety issues

Every day, national authorities responsible for product safety send alerts about measures taken against dangerous products through the Safety Gate/RAPEX system. Around half of the measures notified in the Safety Gate/RAPEX concern recalling products from consumers or other end users.

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.

Product recall action plan

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

• Robust product safety monitoring procedures to identify potential safety issues
• Product traceability strategies allowing for accurate identification of products, including marking products with contact details of an economic operator based in the EU and product identifiers (eg – model name, serial or batch number)
• Strategies to facilitate direct consumer contact, such as using product registration systems and customer loyalty programmes for safety purposes.  It is important to be mindful of the EU General Data Protection Regulation (GDPR)
• Communication strategy setting out available communication channels and including templates (eg – press release or internal messages)
• Corrective action team consisting of people with relevant expertise
• Regular trial exercises for recall events to familiarise staff with the action plan

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
• Decide on which type of action to take. If a decision is taken to recall the product, consideration needs to be given to which products (eg. 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
• Coordinate and cooperate with other actors (eg. 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)
• Retrieve products from consumers in a way that is convenient and cost-free for them. This could be achieved for example by arranging for pre-paid postage to enable the produce to be returned by the consumer or arranging for the repair or replacement of products from the consumers’ home
• 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 (both within and outside the EU)
• Monitor the progress of the recall to assess the effectiveness of the actions undertaken.
• Adjust or expand recall actions if the monitoring results are not satisfactory. For example – if the consumer response rate is low, it may be necessary to increase or change communications
• 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. Review the company’s production standards and implement any necessary changes. This should also include an assessment of the effectiveness of the recall action plan

Content and format of a recall notice

Recall notices should encourage consumers to take action, so they need to be clear and inspire an appropriate level of urgency. An example of good recall notice is available in ’Further information and links’.

The recall notice should:

• Be available in the official language(s) of the country where the product is being recalled
• Have an eye-catching format and graphical elements to enhance visibility and alert consumers to the risk (eg. red outline and bolding/highlighting of key words)
• Use plain, concise and easy-to-understand language – avoiding jargon and technical term
• Contain all key information as set out in the example template for a recall notice