The recall is over and we want to prevent the next one

A recall under the General Product Safety Regulation (EU) 2023/988 does not end when the company decides it has done enough. Market surveillance authorities may request regular progress reports from the economic operator and may decide whether or when the corrective measure can be considered completed (Article 15(6)). Regulation (EU) 2019/1020 requires them to have procedures for verifying that the corrective action that was to be taken has been taken (Article 11(7)(b)), and the GPSR applies that provision to consumer products through Article 23(1).^[1][2]

What follows is the manufacturer's ordinary duty, now with new information. Before placing a product on the market, the manufacturer carries out an internal risk analysis and draws up technical documentation, which, where appropriate, contains an analysis of the possible risks and the solutions adopted to eliminate or mitigate them, including the outcome of test reports (Article 9(2)). That documentation must be kept up to date and at the disposal of the authorities for 10 years (Article 9(3)). Manufacturers also ensure that procedures are in place for products produced in series to remain in conformity with the general safety requirement (Article 9(4)). A recall is a sign that one of those procedures may need to change.^[1]

The authority's interest goes beyond the recalled product. Where a dangerous product has been identified, it may request from the manufacturer information on other products produced using the same procedure, containing the same components or being part of the same production batch, which are affected by the same risk (Article 23(3)). The recall and the corrective measures belong in the internal register next to the complaints that led to them (Articles 9(12) and 11(10)), and the description of the risk, complaints, accidents and corrective measures must remain presentable for 10 years (Article 15(4)).^[1]

Prevention also pays off in the next inspection. Authorities choose checks on a risk-based approach that considers, among other factors, the economic operator's past record of non-compliance and consumer complaints (Regulation (EU) 2019/1020, Article 11(3)).^[2]