How to Handle a Product Recall under the EU General Product Safety Regulation (GPSR)

How to Handle a Product Recall under the EU General Product Safety Regulation (GPSR)

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

Why this matters

Consumers will quickly learn of recalls through Safety Gate alerts, media reports, or social media. Article 35 of the GPSR requires businesses to communicate directly with affected consumers before announcing a recall publicly.

A clear and actionable recall notice ensures:

What is a GPSR-compliant Recall Notice?

A simple apology or press release is not enough. The recall notice must be specific, clear, and actionable, allowing consumers to recognize affected products and understand the risks and remedies.

See our detailed overview of GPSR requirements for context.

The 3-step approach for businesses

1. Trace and investigate

Article 9 requires tracing affected products and identifying precisely which batches, lots, or serial numbers are involved. Maintain records sufficient to enable rapid tracing and identification. If you are unsure about traceability planning, visit our page on what we offer to help businesses implement best practice systems.

2. Prepare a legally compliant recall notice

According to official European Commission guidance, a valid recall notice must contain:

  • Clear headline and product description: Include product name, brand, product IDs, batch/serial numbers, and a photo showing where to find these details.
  • Hazard explanation in plain language. Avoid minimizing language such as “voluntary recall.”
  • Consumer instructions: Stop-use instructions must be clear unless safe use is possible under specified conditions.
  • Remedy information: Refund, replacement, or repair as required by Article 37.
  • Contact information: Freephone, email, or online form in relevant EU languages.
  • Encouragement to share information widely.
  • Online accessibility: Ensure machine-readable information for online notices.

See how GPSR compliance documentation supports your recall readiness.

3. Notify consumers directly

Article 35 requires contacting affected consumers before publication through general channels. Use your own records (e.g. online orders, warranty registrations, email marketing lists) to communicate directly.

To learn more about how the EU Safety Gate works, visit our guide on EU Safety Gate registration.

Labeling and traceability best practice

Strong traceability means consumers can easily identify affected products. Check your product labels and packaging now:

  • Can a consumer locate a batch or serial number within seconds?
  • Are these details printed both on the product and on packaging?
  • Do you maintain records that link batches to distribution channels?

For additional support, consider appointing an EU Responsible Person to manage your EU compliance obligations.

Why this approach protects your business

A proactive and transparent recall process:

Summary checklist

  • Investigate and trace affected products (Article 9)
  • Prepare a recall notice with all seven required elements (Article 35 and Annex VI)
  • Offer appropriate remedies (Article 37)
  • Contact affected consumers directly before publicizing the recall
  • Maintain clear labeling and batch traceability at all times

Managing a recall properly ensures you meet your obligations under EU law and can even strengthen consumer relationships.

Further reading and official sources


Show more insights

Get in Touch with EaseCert