Product recalls: what online sellers must do

Recall or withdrawal?

The GPSR distinguishes two measures (Article 3(25) and (26)):

• Withdrawal: preventing a product that is still in the supply chain – in your warehouse or your store – from being made available.
• Recall: achieving the return of a product that consumers have already bought.

For sellers, a recall nearly always means both: taking stock off sale and reaching buyers.

How you find out about a recall

Manufacturers must keep other economic operators in the supply chain informed of safety issues in a timely manner (Article 9(10)). In practice the message does not always arrive – for example if you buy through intermediaries or the manufacturer is based outside the EU.

Authorities publish recalls and warnings in public databases, in the EU mainly in Safety Gate. Checking these sources against your catalogue regularly tells you about recalls regardless of your supplier. The sources are listed in the guide Where official recalls are published.

Step by step: what to do

1. Stop selling

   Take the product off sale in your store and on all other channels, and block the stock (Article 12(3)). In Shopify, set the product status to “Draft”.

2. Check what is affected

   Compare model, batch or serial number, EAN and sales period with the notice. Often only a specific batch or period is affected, not every product of the brand.

3. Inform the manufacturer or importer

   Contact your supplier without delay and agree how the recall will run and who does what (Article 12(4)(a)).

4. Involve the authorities

   Distributors ensure that the market surveillance authorities of the countries they supplied are informed through the EU Safety Business Gateway (Article 12(4)(c)). If the manufacturer has already notified them, get confirmation; otherwise notify them yourself – with information on the risk, the number of products affected and any action already taken.

5. Inform customers directly

   Find the orders containing the product and contact the buyers. The GPSR requires that all affected consumers who can be identified are notified directly and without undue delay, using the customer data held (Article 35(1)).

6. Inform the public

   If not all buyers can be reached, publish a clear and visible recall notice through other channels: your website, newsletters, social media, points of sale (Article 35(4)). It must be accessible to persons with disabilities.

7. Agree the remedy

   Agree with the manufacturer which remedy customers receive and how returns work (Article 37, see below).

8. Keep records

   Note when you learned what, which stock was affected, whom you informed and when, and which remedy was provided.

The recall notice: required content under Article 36

When customers are informed of a product safety recall in writing – by email, letter or on a website – this takes the form of a recall notice. It must be easy to understand, available in the language(s) of the countries where the product was sold, and contain:

1. a
   Headline

   the words “Product safety recall”;

2. b
   Product description

   picture, name and brand; product identification numbers such as batch or serial number, with a graphic showing where to find them if applicable; when, where and by whom the product was sold, if available;

3. c
   Description of the hazard

   clear, and without anything that may decrease the perception of risk (see below);

4. d
   What customers should do

   including an instruction to stop using the product immediately;

5. e
   Remedies

   which remedies are available under Article 37;

6. f
   Contact

   a free phone number or interactive online service for more information;

7. g
   Sharing

   where appropriate, encouragement to share the information with others.

Wording to avoid

Article 36(2)(c) explicitly names terms such as “voluntary”, “precautionary”, “discretionary”, “in rare situations” or “in specific situations”, as well as stating that no accidents have been reported. The familiar phrase “voluntary, precautionary recall” therefore has no place in a recall notice.

Example structure

Article 36(3) provides for the European Commission to set out a template for recall notices. Check whether a current version is available before publishing.

Remedies: what customers are entitled to

The economic operator responsible for the recall – usually the manufacturer – offers an effective, cost-free and timely remedy (Article 37(1)). Customers can choose between at least two of the following (Article 37(2)):

• repair of the product,
• replacement with a safe product of the same type and at least the same value and quality,
• a refund of at least the price paid.

Only one remedy may be offered if the others are impossible or disproportionately costly. If repair or replacement is not completed within a reasonable time, customers are always entitled to a refund. They do not bear shipping or return costs; products that cannot be transported are collected (Article 37(5)). Statutory warranty rights are not affected.

In your Shopify store

• Stop selling: set the product status to “Draft”; it is then no longer available on any sales channel.
• Find buyers: search the order list for the product and export the results.
• Contact customers: email the recall notice to the affected buyers.
• Recall page: create a page with the recall notice under “Online Store > Pages” and link it prominently, for example on the home page and in your newsletter.