Product Recall Best Practices for EU GPSR Compliance

Product Recall Best Practices for EU GPSR Compliance

No business welcomes a product recall, but under Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR), being prepared is essential. A poorly managed recall can damage your brand, while a well-handled recall shows a commitment to safety and builds consumer trust.

Why this matters

Consumers quickly learn about recalls through Safety Gate alerts, media, and social media. Article 35 of the GPSR requires direct communication with affected consumers before announcing a recall publicly.

A clear recall notice ensures:

What is a GPSR-compliant recall notice?

A simple apology or press release is not enough. The notice must help consumers identify affected products, understand the risks, and know how to act. See our overview of GPSR requirements for details.

The 3-step approach for businesses

1. Trace and investigate

Article 9 requires tracing affected products and identifying specific batches, lots, or serial numbers. Maintain records to enable rapid identification. See our guidance on traceability best practice if you need support.

2. Prepare a compliant recall notice

European Commission guidance requires a recall notice to include:

  • Headline and product description: name, brand, product IDs, batch/serial numbers, and a photo showing this information
  • Plain language hazard explanation (avoid minimising terms like "voluntary recall")
  • Clear stop-use instructions unless safe conditions of use can be specified
  • Remedy details: refund, replacement, or repair as required by Article 37
  • Contact information in relevant EU languages
  • Encouragement for consumers to share the information
  • Accessible format: ensure machine-readable information for online publication

Read more about how GPSR compliance documentation helps with recall readiness.

3. Notify consumers directly

Article 35 requires contacting consumers before any public notice. Use your records (e.g., orders, warranty registrations, marketing lists) for direct communication. See our guide on EU Safety Gate registration for additional context.

Labeling and traceability best practice

Good traceability helps consumers quickly identify affected products:

  • Can batch or serial numbers be located easily?
  • Are these details printed both on the product and packaging?
  • Do your records link batches to distribution channels?

Appointing an EU Responsible Person may help manage ongoing obligations.

Why this approach protects your business

A clear recall process:

Checklist

  • Trace affected products (Article 9)
  • Draft a recall notice with all required elements (Article 35 and Annex VI)
  • Offer remedies (Article 37)
  • Notify consumers directly before public announcement
  • Ensure proper labeling and traceability at all times

Managing a recall properly ensures compliance under EU law and can protect consumer relationships.

Further reading

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