{
  "type": "problem",
  "slug": "complaints-register",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/complaints-register/",
  "markdown": "https://www.conphora.com/solutions/problem/complaints-register.md",
  "title": "We keep no register of complaints",
  "description": "The GPSR requires manufacturers and importers to keep a register of safety complaints, recalls and corrective measures. What it holds and for how long.",
  "answer": "Under the General Product Safety Regulation (EU) 2023/988, manufacturers must keep an internal register of safety complaints, product recalls and corrective measures, and importers must file the complaints they investigate there or in their own register. Set up a public complaint channel, decide what goes in the register, and store only the personal data the investigation needs, for as long as it needs it and never longer than five years.",
  "theme": {
    "id": "incidents-recalls",
    "label": "Incidents, recalls and authorities"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "GPSR"
  ],
  "path": [
    "recall-manager",
    "knowledge-articles"
  ],
  "trigger": "A retailer, an authority or your own quality team asks to see how you record safety complaints, and there is nothing to show",
  "keep": "Personal data in the register no longer than five years after entry (GPSR Articles 9(13) and 11(11)); complaints, known accidents, the risk description and corrective measures must be presentable for 10 years after you were supplied with or supplied the product (GPSR Article 15(4))",
  "why": [
    {
      "text": "The General Product Safety Regulation (EU) 2023/988, which applies from 13 December 2024, turned complaint handling from good practice into a written duty. Article 9(11) requires manufacturers to make publicly available communication channels, such as a telephone number, an electronic address or a dedicated section of their website, through which consumers can submit complaints and report accidents or safety issues. Article 9(12) then requires them to investigate the complaints and accident information that concern the safety of their products and that the complainant alleges to be dangerous, and to keep an internal register of those complaints as well as of product recalls and any corrective measures taken.",
      "sources": [
        1
      ]
    },
    {
      "text": "Importers carry a parallel duty. They verify whether the manufacturer's communication channels are available to consumers and provide their own if they are not (Article 11(9)). They investigate the safety complaints and accident information they receive and file them, together with recalls and corrective measures, either in the manufacturer's register or in their own (Article 11(10)). They also keep the manufacturer, distributors and, where relevant, fulfilment service providers and online marketplaces informed in a timely manner of the investigation and its results.",
      "sources": [
        1
      ]
    },
    {
      "text": "The register is limited by data protection. It may store only the personal data necessary to investigate the complaint, kept only for as long as the investigation needs and in any event no longer than five years after the data were entered (Articles 9(13) and 11(11)). The product facts and the outcome of the investigation are a different matter: on request, every economic operator must give the market surveillance authority a full description of the risk, related complaints and known accidents, and of any corrective measure taken, and must be able to present that information for 10 years after it was supplied with or supplied the product (Article 15(2) and 15(4)).",
      "sources": [
        1
      ]
    },
    {
      "text": "A register is what makes that request answerable. Market surveillance authorities follow a risk-based approach that takes into account, among other factors, the economic operator's past record of non-compliance and consumer complaints and other information received from other sources (Regulation (EU) 2019/1020, Article 11(3), applied to GPSR products by Article 23(1)). An operator that already records and investigates complaints can show what it knew and what it did.",
      "sources": [
        2
      ]
    }
  ],
  "steps": [
    {
      "name": "Open a channel consumers can actually use",
      "text": "Publish a telephone number, an electronic address or a dedicated section of your website where consumers can submit complaints and report accidents or safety issues, and take accessibility needs into account. If you import, check that the manufacturer's channel exists; if it does not, provide one yourself."
    },
    {
      "name": "Decide what the register must capture",
      "text": "The register covers complaints and accident information that concern the safety of your products and that the complainant alleges to be dangerous, plus product recalls and every corrective measure taken to bring a product into conformity (GPSR Articles 9(12) and 11(10)). The articles fix no fields; in practice, give each entry the product type, batch or serial number, the date, the description of the issue, the investigation and the outcome."
    },
    {
      "name": "Investigate each entry and record the result",
      "text": "The duty is to investigate, not only to log. Record what you checked, what you concluded about the risk and what you decided. An entry without an outcome will not help you when an authority asks for a description of complaints and known accidents."
    },
    {
      "name": "Link recalls and corrective measures to the same register",
      "text": "When an investigation leads to a withdrawal, a recall or another corrective measure, record the measure in the register with the complaints that triggered it, so the history of the product reads as one file.",
      "item": "recall-manager"
    },
    {
      "name": "Limit and delete personal data",
      "text": "Store only the personal data needed to investigate the complaint, keep it only as long as the investigation needs it, and in any event no longer than five years after it was entered. Keep the product facts and the outcome after the personal data is gone."
    },
    {
      "name": "Keep the chain informed of the results",
      "text": "Importers keep the manufacturer, distributors and, where relevant, fulfilment service providers and online marketplaces informed in a timely manner of the investigation and its results. Manufacturers keep other economic operators, responsible persons and online marketplaces in the supply chain informed of any safety issue they identify (GPSR Articles 9(10) and 11(10))."
    }
  ],
  "documents": [
    {
      "name": "The internal register of complaints, recalls and corrective measures",
      "from": "The manufacturer; the importer files its complaints there or in its own register",
      "ground": "GPSR Articles 9(12) and 11(10)"
    },
    {
      "name": "The published complaint channel",
      "from": "The manufacturer, or the importer where the manufacturer has none",
      "ground": "GPSR Articles 9(11) and 11(9)"
    },
    {
      "name": "A description of the risk, related complaints and known accidents",
      "from": "You, on request of a market surveillance authority",
      "ground": "GPSR Article 15(2)(a)"
    },
    {
      "name": "A description of the corrective measures taken",
      "from": "You, on request of a market surveillance authority",
      "ground": "GPSR Article 15(2)(b)"
    }
  ],
  "risks": [
    {
      "title": "You cannot answer the authority's request",
      "text": "On request, every economic operator must give the market surveillance authority a full description of the risk, related complaints and known accidents, and be able to present it for 10 years (GPSR Article 15(2) and 15(4)). Without a register, that description has to be rebuilt from mailboxes.",
      "source": 1
    },
    {
      "title": "The authority requires corrective action",
      "text": "Where a product is found not to comply, the authority requires appropriate and proportionate corrective action within a period it specifies, and takes measures itself if the operator does not act (Regulation (EU) 2019/1020, Article 16(2) and 16(5), applied by GPSR Article 23(1)).",
      "source": 2
    },
    {
      "title": "Penalties under national law",
      "text": "Each Member State lays down effective, proportionate and dissuasive penalties for infringements of the regulation by economic operators (GPSR Article 44).",
      "source": 1
    }
  ],
  "faq": [
    {
      "q": "Do distributors have to keep a complaint register?",
      "a": "The register duty in the GPSR is written for manufacturers (Article 9(12)) and importers (Article 11(10)). Distributors have their own duties to act on dangerous products and to inform the manufacturer or importer (Article 12(4)), and like every economic operator they must be able to give the authority a description of the risk, related complaints and known accidents for 10 years (Article 15(2) and 15(4))."
    },
    {
      "q": "Does every complaint go into the register?",
      "a": "The regulation names complaints and accident information that concern the safety of the product and that the complainant alleges to be dangerous (GPSR Article 9(12)). Complaints about colour or delivery time are not what the article is about."
    },
    {
      "q": "How long may we keep the complainant's name and address?",
      "a": "Only as long as the investigation needs it, and in any event no longer than five years after the data were entered (GPSR Articles 9(13) and 11(11))."
    },
    {
      "q": "Can we use the manufacturer's register instead of our own?",
      "a": "Yes, as an importer. Article 11(10) lets you file complaints, recalls and corrective measures in the manufacturer's register under Article 9(12) or in your own internal register."
    },
    {
      "q": "Does the register have a prescribed format?",
      "a": "Articles 9 and 11 of the GPSR do not prescribe a format. What they fix is the content (complaints, recalls, corrective measures), the duty to investigate and the limits on personal data."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2023/988 on general product safety",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/reg/2023/988/oj",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "safety-complaint",
    "customer-injured",
    "authority-letter",
    "withdrawal-or-recall",
    "after-the-recall"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-05",
  "notice": "General information, not legal advice."
}