Recall notice template under the GPSR: how a recall runs

When a recall is due

A recall becomes relevant when a product that is already with the customer is not safe. The rules are in Articles 35 and 36 GPSR. Which event obliges you to act is something you assess with the risk analysis (Article 9 GPSR).

Two ways to reach consumers

First way: all affected consumers who can be identified are notified directly and without undue delay (Article 35(1)), for example by email or letter. Customer data you have collected has to be used for this.

Second way: where you cannot contact all of them, you publish a clear and visible recall notice through other channels, such as your website, social media, newsletters and retail outlets (Article 35(4)). You can build it on the template of Implementing Regulation (EU) 2024/1435. Neither that Regulation nor Article 36 GPSR says in so many words that the template must be used; the content of the notice is fixed by Article 36(2).

What the notice contains

Written recall information takes the form of a recall notice (Article 36(1)). It has to be easy for consumers to understand and available in the language or languages of the Member States where the product was made available. Article 36(2) lists its elements. Take them from the legal text and fill in every one:

• The headline “Product safety recall”
• A clear description of the product: picture, name and brand, identification numbers such as batch or serial number, and when, where and by whom it was sold, if available
• A clear description of the hazard, without anything that may lower the perception of risk, such as the terms “voluntary” or “precautionary” or a note that no accidents have been reported
• What consumers should do, including an instruction to stop using the product immediately
• A clear description of the remedies available to consumers under Article 37
• A free phone number or interactive online service for more information
• Encouragement to share the information with other persons, if appropriate

The steps in practice

Fix the procedure before you need it.

• Narrow down the affected products and batches.
• Identify the distributors and customers you can reach directly.
• Write the notice along the template.
• Notify consumers directly; where that is not possible, publish the recall notice.
• Check your notification duties. Accidents go through the Safety Business Gateway (Article 20 GPSR).
• Document responses and returns.

Frequently asked questions