Rethinking the Recall Process

The Consumer Product Safety Commission (“CPSC”) announced a revised version of its Recall Handbook and new Guidelines for Retailers and Reverse Logistics Providers. The Recall Handbook contains a number of changes including the following:

• Companies should file Section 15(b) Reports through the CPSC’s website (, rather than by mail or phone. The staff repeated that preference at last week’s annual meeting of the International Consumer Product Health and Safety Organization.

• When announcing a recall, companies should consider use of their social media presence, including Facebook, Google+, YouTube, Twitter, and company blogs.

• Companies should consider the use of mobile scanners to obtain information on recalls from mobile devices. The recall poster should include a QR code or other mobile scanning code to let consumers act on the recall immediately.

• Companies conducting a recall should develop a plan regarding disposition of the returned product.

The Recall Handbook also clarifies the following:

• In addition to the factors identified for determining whether a risk of injury could make a product defective, the CPSC will also consider whether the risk was obvious to the consumer; whether there were adequate warnings and instructions to mitigate the risk; and whether the risk of injury was the result of consumer misuse and, if so, whether the misuse was foreseeable.

• For the Fast Track Product Recall Program, if a corrective action plan is not approved within 20 working days, the staff typically will not make a preliminary hazard determination if the company has provided the required information, but the staff has not been able to review it within the time period.

Manufacturers and 3PLs that process recalls should review this document closely, industry sources say. Now that the CPSC has the ability to level fines and penalties, the importance of complying with these guidelines is greater than ever.

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