Recall Management
Support in managing a cosmetic product recall or withdrawal, from assessing the safety issue through authority notification to a documented corrective action plan.
- Assessment of the safety issue and the scope of affected product
- Notification to the competent authority and, where required, to the Safety Gate rapid alert system
- A documented corrective and preventive action plan
- Reassessment and reformulation support to return a compliant product to market
A recall is a regulatory process as much as a logistical one, and the decisions taken in the first hours must be defensible afterwards. The duty itself flows from Articles 5(2) to (4) and 25 of Regulation (EC) No 1223/2009: a Responsible Person that considers a product non-compliant must take corrective measures, withdraw or recall it, and where the product presents a risk to human health must immediately inform the competent authorities of every territory where it was made available.
The first task is to establish the nature and scope of the problem: the defect, the affected batches, and the risk they present. The authorities are notified, and a product presenting a serious risk is reported to the Safety Gate, the EU rapid alert system for dangerous non-food products, with the equivalent UK database operating under the General Product Safety Regulations 2005. A corrective and preventive action plan records what is done and why, both to satisfy the authority and to protect the brand if the decision is later examined. The General Product Safety Regulation (EU) 2023/988, applicable since 13 December 2024, sits over this as the general consumer-product framework.
We lead the process with a qualified safety assessor and carry it through to the reassessment or reformulation needed to return a compliant product to market. Where a recall sits within a wider incident it is handled as part of crisis management.