As we have discussed in a previous post, recalls are part of life for many manufacturers, and the trend is for more frequent, and more geographically broad, product recalls.
This week, we would like to highlight the work done by several of our partners: Pat Lowry (West Palm Beach), Rob Elvin (Manchester, UK), Marie-Aimee Peyron (Paris), Horst Daniel (Frankfurt), and Fernando Gonzales (Madrid), and their attached SPB publication, “A Guide to Product Recalls United States And European Union.” As the publication points out, as trade becomes more global, and product distribution channels more complex, manufacturers and distributors need to be more proactive in managing and coordinating their product recall actions. They then describe at a high level how to set up an effective, and global, recall process.
Among the SPB team’s recommendations is an emphasis on organization and discipline in adopting and adhering to a recall protocol. Manufacturers and distributors should develop detailed recall plans that are reviewed by experienced regulatory counsel, identify a recall “chain of command” to ensure adherence to recall best practices, develop a robust “corrective action” plan to address any product deficiencies, and communicate with any and all governmental agencies implicated by the recall. The SPB publication then discusses the different recall procedures in the US and EU, along with country-by-country guidance for individual EU states.