Regulation (EU) 2019/1020, the General Product Safety Regulation and Decision No 768/2008/EC all define a withdrawal as any measure aimed at preventing a product in the supply chain from being made available on the market. It is the counterpart of a recall, which is aimed at products already made available to the end user or consumer. In practice a withdrawal means stopping sales, blocking stock at the warehouse, the importer and the retailers, and taking the product off online listings, while the products already sold are left with their owners.
Withdrawal is one of the corrective measures that economic operators must consider on their own initiative. Article R2(8) of Decision 768/2008, and the corresponding provisions in each product act, require a manufacturer that has reason to believe a product it placed on the market is not in conformity to take the necessary corrective measures to bring it into conformity, to withdraw it or to recall it, as appropriate, and importers and distributors have parallel duties. Under the General Product Safety Regulation the same applies to a dangerous product (Articles 9(8), 11(8) and 12(4)), and the authorities must be informed through the Safety Business Gateway.
For market surveillance authorities, withdrawal appears in Article 16(3) of the Market Surveillance Regulation as one of the corrective actions they can require, next to preventing the product from being made available, recall, destruction and warnings. For products presenting a serious risk, Article 19(1) obliges them to ensure withdrawal or recall where no other effective means exists, and to notify the measure through the rapid alert system. Whether a withdrawal or a recall is appropriate depends on the risk assessment: a formal non-conformity may justify a withdrawal only, while a serious risk to consumers usually requires both.