The Product Recall process

Aspect

European Union (EU)

United Kingdom (U.K.)

Recall notice websites

EU Safety Gate (formerly RAPEX)
https://ec.europa.eu/safety-gate-alerts/screen/search

Product Recalls and Alerts
https://www.gov.uk/product-safety-alerts-reports-recalls

Legal framework

General Product Safety Regulation (GPSR) (Regulation EU 2023/998) (replacing General Product Safety Directive (GPSD) as of December 2024)

Governed by U.K.-specific regulations and guidance from the Office for Product Safety and Standards (OPSS) and the Food Standards Agency (FSA)

Key authorities

European Commission (policy and oversight), National Market Surveillance Authorities (MSAs) (enforcement at member state level), and Safety Gate (EU Rapid Alert System for dangerous non-food products), Rapid Alert System for Food and Feed (RASFF)

OPSS (non-food products), FSA (food), DVSA (vehicles – Driver and Vehicle Standards Agency), and CTSI (Trading Standards – Chartered Trading Standards Institute)

Aspect

European Union (EU)

United Kingdom (U.K.)

Triggering a recall

Voluntary by economic operators or mandatory by national Market Surveillance Authorities (MSAs)

Voluntary by businesses or ordered by competent authorities (e.g., OPSS, FSA)

Initial notification

Notify all relevant national authorities via the Safety Gate Business Gateway when a product poses a serious risk

Notify the Office for Product Safety and Standards (OPSS) and relevant local authorities immediately upon identifying a safety risk

Process

Cooperate with MSAs during investigation and corrective actions; maintain traceability and provide documentation within 10 days

Follow the code of practice PAS 7100:2022 for non-food recalls, which includes:

• Planning for recalls
• Executing corrective actions
• Reviewing effectiveness
• Cooperating with enforcement authorities during investigations

Note: PAS 7100:2022 is a voluntary code of practice but is widely adopted and supported by OPSS.

Communication requirements

Direct consumer contact is preferred; the use of a standardized recall notice format under Regulation (EU) 2024/1435 is recommended but not mandatory

Businesses must inform consumers clearly via recall notices (website, media, packaging inserts)

Consumer remedies

Repair, replacement or adequate refund, as per GPSR Article 37; remedies must be free and provided without delay

• Repair, replacement or refund, as per the Consumer Rights Act 2015; Manufacturers must plan for the collection and/or return of the product from consumers
• Businesses must provide clear instructions for returns or disposal

Remedy details

No strict time limit: consumers may claim remedies long after purchase

No strict time limit: Consumers may claim remedies below after purchase:

• Within 30 days: full refund
• Within 6 months: repair, replacement or refund if repair/replacement fails
• After 6 months: claim possible, but consumer must prove defect existed at purchase

Checklist for manufacturers involved in a recall (Both U.K. and EU)

• Monitor product safety through post-market surveillance
• Maintain traceability of products (i.e., batch numbers, distribution records)
• Establish a recall plan (aligned with PAS 7100 in the U.K. or GPSR in the EU)
• Train staff on recall procedures and responsibilities
• Document all actions taken during the recall process
• Analyze the root cause of the defect or hazard
• Implement corrective actions in design, manufacturing or supply chain
• Review and update recall procedures based on key learnings
• Submit final report to authorities (if required)

Aspect

European Union (EU)

United Kingdom (UK)

Legal basis

Regulation (EU) 2023/988 (GPSR)

o  General Product Safety Regulations 2005

o  Voluntary PAS 7100:2018/2022 (Code of Practice) and other industry guidelines

Who is covered

Importers, distributors, fulfillment service providers and authorized representatives

Importers, distributors, retailers, fulfillment service providers, authorized representatives

General duty

Place only safe products on the market; conduct risk assessments and maintain documentation

Confirm product safety; monitor safety; take corrective action if risks are identified

Importers

Must verify product compliance, hold technical documentation and include contact details on packaging; cooperate with authorities

Treated as the primary responsible party for bringing products into GB; must demonstrate compliance and notify authorities of risks

Distributors

Must check CE marking, labeling and documentation; avoid selling unsafe products; report risks

Must not sell unsafe products; must report safety issues to manufacturers or National Trading Standards

Fulfillment service providers

Considered economic operators if they perform warehousing, packaging or dispatching. If no other responsible party is identified, they are required to meet compliance obligations

May be treated as responsible if no manufacturer or importer is identified; expected to cooperate with authorities

Authorized representatives

Act as a contact point for non-EU manufacturers; hold documentation and liaise with authorities

Act as a contact point for non-U.K. manufacturers; hold documentation and liaise with authorities

Recall participation

Must cooperate with manufacturers and authorities during recalls; may initiate corrective actions if needed

• Must cooperate with manufacturers and authorities during recalls; may initiate corrective actions if needed
• Expected to follow PAS 7100 guidance for corrective actions

Traceability

Maintain records of suppliers and product batches; support investigations and recalls

Keep records to trace product origins; provide documentation to regulators when requested

Notification duties

Notify authorities via Safety Gate if risks are identified; support recall communication

Notify National Trading Standards or OPSS immediately upon identifying safety risks

Aspect

Process for both the EU and the U.K.

• Stop using a product immediately if it’s recalled or poses a safety hazard
• Follow instructions provided in the recall notice (e.g., return, repair, disposal)
• Keep proof of purchase (receipt, order confirmation) if possible
• Contact the manufacturer or retailer for remedy options
• Respond quickly to recall notices to avoid injury or property loss
• Ask questions if the recall process is unclear or slow
• Use official channels to escalate concerns (National Trading Standards in the U.K. or national authorities in the EU)
• Share recall information with others who may own the same product