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New Consumer Product Recall Code of Practice: What You Need to Know

The newly formed Office for Product Safety & Standards (OPSS) has embarked upon its commitment to improve product safety by introducing the first government-backed Code of Practice for product safety recalls – PAS7100.

The Code of Practice (the Code) aims to provide producers and distributors with clearer guidance on how to prepare for and deal with product safety issues, and we would advise producers and manufacturers to review their product recall arrangements in line with PAS7100. The Code is split into two parts: the first is intended for manufacturers, importers and distributors; the second is intended for regulators. The Code includes guidance on how to plan for a recall; how to undertake a risk assessment; how to manage a possible recall or other corrective action; how to set up processes to monitor product safety; what businesses should do when investigating a potential product safety issue; and how to review/ develop corrective action plans. It also guides regulators in relation to monitoring incidents, analysing data, supporting businesses and responding to a failure to take proper action.

The Code deals with non-food consumer products and focuses on corrective actions that should be taken on the discovery of an unsafe product. The principle instruction is clear: every business should create and implement a product safety incident plan (PSIP). A successful PSIP will consider product safety issues before they arise and be ready for use at the outset of a safety concern.

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About this Author

Rob Elvin Civil Claims Lawyer Squire Patton Boggs

Rob Elvin is the managing partner of our Manchester office. His particular expertise covers health, safety and environmental (including nuisance, noise abatement, pollution, permit appeals and environmental warranty and civil claims), judicial review, corporate defence (including bribery and corruption, investigations and corporate manslaughter), inquest law, food hygiene and safety, transport law, including public inquiries in front of traffic commissioners, product safety, liability and recall, and he is a solicitor-advocate. Rob also lectures on issues such as...

44 161 830 5257
Nicole Smith, SquirePattonBoggs, Consumer Regulation, Food Law, Licensing
Senior Associate

Nicola Smith specialises in hospitality and leisure. Her expertise covers both licensing and food law. Nicola acts for a wide range of clients from listed companies to entrepreneurs. She prides herself on providing commercially-minded advice as part of a one-stop shop for clients dealing with the management of all of their licensing and food law issues.

In addition to direct advice on licensing and food issues, Nicola provides support on corporate, property and insolvency transactions and advises on the licences required for the playing of copyright music by PRS or PPL. Nicola is experienced in reviewing and advising upon due diligence systems and has drafted operations manuals and compliance documents for numerous clients following such reviews. She has also provided training at both a legal and operational level including general updates and training on specific changes in law, such as the EU Food Information for Consumers Regulation.

44 121 222 3230
Gary Lewis, Health, Safety, Manchester, Squire Patton Boggs Law Firm

Gary is a director in our Environmental, Safety & Health practice based in our Manchester office.  His particular expertise covers health, safety and environmental prosecutions, corporate manslaughter, food safety and trading standards, including attendance at PACE interviews and advocacy in the Magistrates’ and Coroners’ Courts.

+44 161 830 5373
Laura Clare, Squire PB, Environmental law attorney

Laura is an associate in our Environmental, Safety & Health Practice based in our Manchester office. Her expertise covers ESH prosecutions, product safety, bribery and corruption, security and modern slavery.

She regularly advises organisations on the adequacy of their policies, procedures and organisational arrangements in relation to ESH matters and the extent of the duties owed by organisations with regards to risk, in both civil and criminal law. Laura has experience of dealing with various UK regulators, including the Health and Safety Executive, Trading...

+44 161 830 5143