How to manage a product recall

If you discover that a product you have placed on the market poses a safety risk to consumers, you must act immediately. Delaying action can result in consumer injuries, criminal prosecution, and significant financial penalties.

This guide explains what you must do when you identify an unsafe product, whether you are the manufacturer, an importer bringing goods into the UK, or a distributor in the supply chain.

When you must act

You have a legal duty to take action when you know or ought to know that a product you have supplied presents risks incompatible with the general safety requirement. This applies if:

• You receive consumer complaints about injuries or near-misses
• Quality control testing reveals a safety defect
• A component supplier notifies you of a problem
• You see similar products recalled in other markets
• Trading Standards or OPSS contacts you about safety concerns

The threshold is not certainty of harm - if there is a reasonable possibility that the product could cause injury, you must investigate and potentially act. Waiting for proof of actual injuries before acting is not acceptable and will be treated seriously by enforcement authorities.

Who has responsibilities

Producers have the primary responsibility for product safety. This includes:

• Manufacturers based in the UK
• Any business that puts its name or trademark on a product (own-branders)
• UK importers who bring products into the country
• Anyone who reconditions or refurbishes products

Distributors (wholesalers, retailers) must not supply products they know or should know are dangerous. They must also pass on safety information through the supply chain and cooperate with recall efforts.

Your notification obligations

Notification to the authorities is not optional - it is a legal requirement under Regulation 9 of the General Product Safety Regulations 2005. Failure to notify is a criminal offence.

You must notify your local Trading Standards authority immediately when you become aware that a product you have placed on the market poses risks to consumers. Trading Standards will then pass the notification to the Office for Product Safety and Standards (OPSS), the national regulator.

What "immediately" means

The regulations use the term "forthwith" which means without delay. In practice, you should notify within 24-48 hours of becoming aware of a risk. Taking a week to "investigate further" before notifying is unlikely to be acceptable unless genuinely necessary to establish basic facts.

You can notify while still gathering information. Initial notification can be followed up with fuller details as they become available. The key obligation is to alert authorities so they can assess the situation and advise on appropriate action.

Voluntary vs enforced action

It is always better to take voluntary action than to wait for enforcement authorities to compel you. Businesses that act promptly and cooperatively are treated more favourably than those who resist or delay. Voluntary recalls also tend to be less damaging to brand reputation than enforced ones.

The recall process step by step

A product recall is a structured process that must be managed carefully to protect consumers and demonstrate compliance. The following steps reflect OPSS guidance and industry best practice from PAS 7100:2022.

Risk assessment is critical

The level of action you need to take depends on the severity of the risk. OPSS provides the Product Safety Risk Assessment Methodology (PRISM) to help you evaluate risks consistently.

Factors that increase risk severity include:

• Potential for serious injury or death
• Vulnerable users (children, elderly, disabled)
• Likelihood of the hazard occurring in normal use
• Number of products in circulation
• Difficulty for consumers to identify affected products

A full recall from consumers is required for serious risk products. For lower risks, withdrawal from the supply chain (stopping further sales) may be sufficient.

Communicating with consumers

Effective consumer communication is essential for a successful recall. Your goal is to reach as many affected consumers as possible and make it easy for them to respond.

What your recall notice must include

Every recall notice should contain:

• Clear product identification - Name, model numbers, batch codes, date codes, photos showing how to identify affected products
• The hazard - What the safety problem is, in plain language
• The risk to consumers - What could happen if they continue to use the product
• What to do - Stop using immediately, keep out of reach of children, return to store
• The remedy - Repair, replacement, or refund and how to claim it
• Contact details - Phone number, email, website for questions and returns

Communication channels

Use multiple channels to maximise reach:

• Direct contact - Email or write to customers if you have purchase records (most effective)
• Company website - Prominent recall notice on homepage
• Social media - Posts on company accounts, consider paid promotion
• Press release - For products with wide distribution
• Point of sale - Notices in stores that sold the product
• Product registration databases - If consumers registered their purchase

For serious risk products, OPSS will publish the recall on the GOV.UK Product Safety Alerts page, which helps extend reach.

The remedy you must offer

Consumers must be offered an effective remedy at no cost to them. This typically means:

• Repair - Fix the safety defect (only if this genuinely eliminates the risk)
• Replacement - Provide a safe replacement product
• Refund - Return the purchase price

You should also cover reasonable return costs - asking consumers to pay postage to return a dangerous product will reduce compliance and damage your reputation.

Working with Trading Standards and OPSS

Enforcement authorities are not the enemy - they can be valuable partners in managing a recall effectively. Cooperating fully is not just a legal requirement, it is also in your commercial interest.

Your local Trading Standards

Trading Standards is your primary point of contact for product safety matters. They:

• Receive your initial notification
• Advise on appropriate corrective action
• Monitor your recall progress
• Can issue enforcement notices if voluntary action is inadequate

Find your local Trading Standards office through GOV.UK. For businesses operating nationally, you may also be assigned a Primary Authority which provides consistent regulatory advice.

OPSS (Office for Product Safety and Standards)

OPSS is the national regulator, part of the Department for Business and Trade. They:

• Maintain the UK Product Safety Database
• Publish recall notices on GOV.UK for serious risks
• Coordinate action across multiple Trading Standards areas
• Handle cross-border issues with international regulators
• Provide guidance on product safety compliance

If you receive an enforcement notice

Receiving an enforcement notice is serious but not the end of the world. You must:

• Comply with the requirements within the specified timeframe
• Keep records of all actions taken
• Report progress to the issuing authority

If you believe a notice is unreasonable, you can appeal to a Magistrates' Court within 21 days. However, the notice remains in force during the appeal unless the court orders otherwise. Seeking legal advice before appealing is strongly recommended.

Record keeping and follow-up

Thorough documentation protects you legally and helps you improve future product safety. Keep records of:

During the recall

• All communications with authorities (dated, with names)
• Risk assessment methodology and conclusions
• Recall notices issued and channels used
• Consumer responses and products returned
• Remedies provided (repairs, replacements, refunds)
• Costs incurred

Monitoring effectiveness

Track your recall recovery rate - the percentage of products returned compared to estimated number in circulation. Industry average recovery rates are often below 30%, but for serious risks you should aim higher. Low recovery rates may require additional communication efforts.

If recovery is poor after initial efforts, consider:

• Additional advertising
• Extending the recall period
• Improving the remedy offered
• Working with consumer groups to spread awareness

Post-recall review

After the recall is complete, conduct an internal review:

• What caused the safety defect?
• Could it have been detected earlier?
• How effective were your communication channels?
• What would you do differently next time?

Use these lessons to improve your quality control processes and recall preparedness. Having a recall plan in place before you need it will make any future incident much easier to manage.

Retention periods

Keep recall documentation for at least 10 years. Product liability claims can be brought for up to 10 years after a product was supplied, and you may need to demonstrate the actions you took. Some product-specific regulations require longer retention periods.