A trading name of A Star Supply · ContactA trading name of A Star Supply · ContactA recall under the General Product Safety Regulation is not just an email. The regulation says who must act, how buyers must be contacted, what the notice has to contain, and what you must offer the people who bought the product. Here is each part, with the article it comes from.
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Article 9(8) is the trigger for manufacturers. Where a manufacturer considers, or has reason to believe on the basis of information in its possession, that a product it placed on the market is dangerous, it must immediately take the corrective measures necessary to bring the product into conformity, including a withdrawal or recall as appropriate, inform consumers under Article 35 or 36, and inform the market surveillance authorities of the countries where the product was made available through the Safety Business Gateway.
Importers have the matching duty in Article 11(8) and distributors in Article 12(4). A withdrawal stops a product still in the supply chain from being made available; a recall aims at the return of a product that has already reached the consumer (Article 3(25) and (26)).
The threshold is "considers or has reason to believe", not proof. A manufacturer must also give consumers a public way to report safety issues and keep an internal register of complaints, recalls and corrective measures (Articles 9(11) and 9(12)).
Article 35(1) says all affected consumers that can be identified must be notified directly and without undue delay, and that operators who collect their customers' personal data must use that information for recalls and safety warnings.
The Commission's guidelines say the actor in the supply chain with access to the customer data should be the one contacting them, so cooperation up and down the chain matters. They also state that this use of customer data is fully compatible with EU data protection law, and that you should reflect the obligation in your privacy statement.
Article 35(2) adds a rule for product registration schemes and customer loyalty programmes that identify what a customer bought: you must let customers give contact details for safety purposes only, and that data may be used only to contact them about a recall or safety warning.
This is why order records matter. If you cannot tell which buyers received which batch, you cannot do what Article 35(1) requires.
Article 35(4) says that where not all affected consumers can be contacted, you must spread a clear and visible recall notice or safety warning through other appropriate channels, reaching as widely as possible. It names your website, social media channels, newsletters and retail outlets, and, as appropriate, announcements in mass media.
The same paragraph requires the information to be accessible to persons with disabilities. The guidelines add practical points: follow web accessibility practice, spell out in text any important information carried in an image so it is machine-readable, and allow for magnification, brightness and contrast adjustment.
Article 36(1) says written recall information must take the form of a recall notice, and Article 36(2) says it must be easily understood and available in the languages of the countries where the product was made available.
The Commission's guidelines say a template has been set out in Commission Implementing Regulation (EU) 2024/1435 and is available on the Safety Gate Portal in a format that lets businesses create a notice easily.
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Article 36(2)(c) requires the hazard description to avoid any element that may decrease consumers' perception of risk. It names examples: "voluntary", "precautionary", "discretionary", "in rare situations", "in specific situations", and indicating that there have been no reported accidents.
The standard press-release phrasing of a recall is written to reassure. The regulation asks for the opposite.
The guidelines add that you may offer extra incentives such as discounts or vouchers to encourage participation, and that asking consumers to dispose of the product themselves is only acceptable where they can do so easily and safely.
The Commission's guidelines set out three differences from the contractual remedies in Directives (EU) 2019/770 and (EU) 2019/771: in a recall there is no time limit on activating the remedies; the consumer can claim from the economic operator responsible for the recall rather than only from the trader who sold it; and the consumer does not have to prove the product is dangerous.
A consumer cannot take both routes for the same safety issue. Once given a remedy under one, they cannot claim again under the other for that issue.
If you sell through a marketplace, Article 22(12)(a) requires it to notify affected consumers who bought through it and publish recall information on its interface. That does not replace your own duties.
The economic operator whose duty is triggered. Article 9(8) puts it on the manufacturer that considers or has reason to believe a product it placed on the market is dangerous, with matching duties for importers (Article 11(8)) and distributors (Article 12(4)).
The headline "Product safety recall"; a clear description of the product with picture, name, brand and identification numbers; the hazard; what consumers should do, including stopping use immediately; the remedies; a free phone number or interactive online service; and encouragement to share it (Article 36(2)).
Article 36(2)(c) names "voluntary", "precautionary", "discretionary", "in rare situations" and "in specific situations" as examples of wording that may decrease the perception of risk, and says the hazard description must avoid such elements. Saying there have been no reported accidents is named too.
You must offer a choice of at least two of repair, replacement and refund, unless the alternatives are impossible or disproportionate. A refund must be at least the price paid. If repair or replacement is not completed in a reasonable time, the consumer is entitled to a refund anyway (Article 37).
Not the consumer. Article 37(5) says the consumer shall not bear the costs of shipping or otherwise returning the product, and that you must arrange collection for products that are not portable by nature.
Article 36(2) says it must be available in the language or languages of the Member States where the product was made available on the market, and easily understood by consumers.
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