We must recall a product sold in several EU countries

A recall under the General Product Safety Regulation (EU) 2023/988 follows the product, not the company's home country. Where a manufacturer considers, or has reason to believe, that a product it placed on the market is dangerous, it must immediately take the corrective measures needed, inform consumers, and inform, through the Safety Business Gateway, the market surveillance authorities of the Member States in which the product has been made available (Article 9(8)). The notification gives details of the risk to health and safety, of any corrective measure already taken and, if available, of the quantity, by Member State, of products still circulating on the market. Importers carry a corresponding duty under Article 11(8), including the notification through the Safety Business Gateway (Article 11(8)(d)).^[1]

Language follows the market as well. A recall notice must be one consumers can easily understand, available in the language or languages of the Member State or States where the product has been made available, and it must contain the elements listed in Article 36(2), including a free phone number or interactive online service where consumers can get more information in the relevant official languages. Consumers who can be identified are notified directly; where not all can be reached, the notice is spread through other appropriate channels for the widest possible reach (Article 35(1) and 35(4)).^[1]

Authorities share what they see. Member States notify corrective measures for products presenting a serious risk through the Safety Gate Rapid Alert System, within four working days after the measure is taken, and where one Member State notifies such a measure, the others notify the measures or other actions they take subsequently for the same products no later than four working days after taking them (Article 26(1), 26(4) and 26(7)). Evidence used by one Member State's authority may be used in another's investigations without further formal requirements (Regulation (EU) 2019/1020, Article 11(6), applied by GPSR Article 23(1)).^[1][2]

The rest of the chain is drawn in. Distributors who have reason to believe a product is dangerous make sure corrective measures are taken and give the details available to them, including the number of products involved (Article 12(4)). Providers of online marketplaces cooperate with authorities and operators, notify the buyers who bought through their interfaces when they have actual knowledge of a recall, and publish recall information on their interfaces (Article 22(12)). Each authority may request regular progress reports and decide whether or when the measure can be considered completed (Article 15(6)).^[1]