Conducting a product recall—general consumer goods
Produced in partnership with Tom Fox of Arnold & Porter Kaye Scholer
Conducting a product recall—general consumer goods

The following Risk & Compliance practice note produced in partnership with Tom Fox of Arnold & Porter Kaye Scholer provides comprehensive and up to date legal information covering:

  • Conducting a product recall—general consumer goods
  • Legislation
  • Guidance
  • Monitoring products
  • Determination of risk
  • When to recall
  • When to notify relevant authorities
  • Notifying Trading Standards
  • Which office to notify
  • Timing of notification
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Risk & Compliance?

This Practice Note addresses the practicalities of product recall for general consumer products from the perspective of producers and distributors.

'Producer' and 'distributor' are defined terms under the General Product Safety Regulations 2005 (GPSR 2005), SI 2005/1803. In newer legislation, eg the Toy Safety Directive 2009/48/EC, the terms 'manufacturer', 'importer' and 'distributor' are used instead and are defined slightly differently.

This Practice Note focuses on products that are not covered by sector or product specific legislation. The same principles will cover some products covered by sector legislation, eg toys, but not others such as food and drink and cosmetics which are addressed by separate Practice Notes, eg Conducting a product recall—food and drink.


The main relevant piece of legislation is the EU’s General Product Safety Directive 2001/95/EC (GPSD), which is implemented in the UK by the GPSR 2005.

This applies to all

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