Product recalls in the EU: Safety Gate and GPSR
What the Safety Gate 2025 figures show, what GPSR Articles 35 to 37 require in a consumer recall, and why batch-level stock data keeps a recall narrow.
Safety Gate, the EU’s rapid alert system for dangerous non-food products, recorded 4,671 alerts in 2025, the highest number since it began in 2003. When a consumer product is recalled, the General Product Safety Regulation (EU) 2023/988 sets the rules: affected consumers are told directly where possible, the recall notice follows a fixed content, and consumers are offered a choice of at least two remedies among repair, replacement and refund. Batch-level stock and order data decides how many consumers a recall has to reach.
The GPSR has applied since 13 December 2024. Its recall chapter turned what used to be a matter of practice into a set of written obligations.
How many Safety Gate alerts were there in 2025?
The European Commission published its Safety Gate report for 2025 on 5 March 2026. The main figures are these.
| Measure | 2025 figure |
|---|---|
| Alerts notified | 4,671, up 13 percent on 2024 and more than double 2022 |
| Follow-up actions by national authorities | 5,794, up 35 percent on 2024 |
| Most reported product categories | cosmetics 36 percent, toys 16 percent, electrical appliances and equipment 11 percent |
| Leading risk | dangerous chemicals, 53 percent of notifications |
| Next risks | injuries 14 percent, choking 9 percent |
Two measures are easy to confuse. Alerts are notifications of dangerous products. Follow-up actions are the measures other national authorities take in response. The 13 percent and 35 percent rises describe different things.
How must consumers be told about a recall?
Article 35 of the GPSR puts direct contact first. Where the economic operator responsible for the recall holds the contact details of affected consumers, it notifies them directly and without undue delay. Law firm commentary on the article, from Norton Rose Fulbright and Cooley, describes customer data as the most effective route.
Where not every affected consumer can be reached directly, the notice is spread through other channels. Commentators list the operator’s website, social media, newsletters, retail outlets and media announcements. Norton Rose Fulbright notes that notices go out in the language or languages of the member states where the product was made available.
What must a recall notice contain?
Article 36 fixes the content. As summarised by IBF Solutions from Article 36(2), a recall notice carries:
- the heading “Product Safety Recall”;
- a clear description of the product, including images, name, brand, product identification numbers, and where and when it was sold;
- a clear description of the risk;
- a clear description of what consumers should do, including an invitation to stop using the product;
- an explicit reference to the remedies available under Article 37.
The article also rules out wording that may decrease consumers’ perception of the risk. Commentators give examples such as “voluntary”, “precautionary”, “discretionary” and “in rare situations”, and statements that no accidents have been reported.
The Commission set out a standard template in Implementing Regulation (EU) 2024/1435, published in the Official Journal on 27 May 2024 and applicable from 13 December 2024. A corrigendum later corrected the template, and Czechia’s Ministry of Industry and Trade directs businesses to use the corrected version.
Which remedies must be offered?
Article 37 requires the operator responsible for the recall to offer consumers an effective, cost-free and timely remedy. As Norton Rose Fulbright and Cooley summarise it, consumers get a choice of at least two of three options: repair, replacement, or an adequate refund. The operator may offer only one where the other options would be impossible or disproportionate.
Each remedy has a logistics shape. A refund may need the product back, or proof of disposal. A replacement means outbound stock of a safe version. A repair means inbound units, a repair process and a return shipment. The choice made at notice stage decides what the warehouse handles for months afterwards.
How does batch data make a recall smaller?
The recall notice must identify the product, including its identification numbers. Under Article 9 of the GPSR, manufacturers make products identifiable by consumers, including a batch or serial number or other identifying element. When the fault is confined to one batch, the notice can name that batch, and consumers holding other batches can keep using their product.
That precision only helps if the operator knows which consumers received the affected batch. The record that answers the question is the dispatch record: which batch left the warehouse, on which order, to which address, on which date. Lot, batch and expiry control in an EU warehouse sets out how those records are kept.
Without batch-level dispatch data, the operator knows what it sold but not which unit went where. The only safe notice then covers every unit ever sold, and every consumer holding one.
A worked example
Suppose a maker of electric kettles from outside the EU sells to consumers in Portugal, Spain and France from stock held in Portugal. All figures are hypothetical, for the mechanics only. Over a year it has sold 12,000 kettles from four production batches. Testing then shows a faulty thermostat in batch C only, 2,500 units, of which 1,900 have been sold.
With batch data, the first hour of the recall looks like this. The warehouse blocks the remaining 600 units of batch C, so none ship. The dispatch records list the 1,900 orders that carried batch C, with the consumers’ contact details from the orders. The notice names batch C, reaches those 1,900 consumers directly, in Portuguese, Spanish and French, and offers replacement or refund.
Without batch data, the maker has to address all 12,000 buyers, and handle replacements or refunds for units that were never faulty.
What does the warehouse do during a recall?
- Stop. Block the affected stock at once, including units in picking and returns.
- Identify. Produce the batch-to-order list for the responsible operator.
- Segregate. Keep recalled units that come back apart from saleable stock, under a clear status.
- Handle remedies. Receive returns, ship replacements, and record each unit’s outcome.
- Report. Give the operator counts it can pass to authorities: blocked, returned, replaced, refunded, destroyed.
The legal duties sit with the economic operators, not with the warehouse. The warehouse supplies the facts they need to meet them. Returns and recalls share the same inbound process, with a different status on the goods.
What can be prepared before any recall happens?
A recall is run in days, but it is won or lost in the months before. Five things can be in place while nothing is wrong.
- Batch on every order line. The dispatch record carries the batch or serial number for each unit shipped, not only the product code.
- Consumer contact data. Order data is kept in a form that lets the responsible operator reach buyers directly, within the limits of data protection law.
- A notice in each language. A draft recall notice following the Article 36 content, prepared in the languages of every market where the product is sold, so that only the details change on the day.
- A remedy plan. A view, per product, of which two remedies are realistic: whether replacement stock exists, whether repair is possible, and how refunds would be processed.
- A quarantine status. A stock status in the warehouse system that blocks units at once, across picking, packing and returns, without deleting them from the count.
None of this is specific to one law. It is the difference between a recall notice that names a batch and one that has to name a whole product line.
This is general information, not legal advice. The obligations in a specific recall are confirmed with the operator’s advisers and the competent authorities.
How this runs at EFC
When a recall comes, the work lands on the stock and on the returns. For brands selling to consumers in Europe, EFC holds stock and handles returns at its base in Portugal, run with its logistics partner. For consumer products, it also acts as GPSR Responsible Person, a role set out on responsible person and in GPSR and the Responsible Person, explained. It is not the cosmetics Responsible Person under Regulation (EC) No 1223/2009, and it gives no legal advice.
Sources
| Label | Value | Source |
|---|---|---|
| Safety Gate 2025 | 4,671 alerts, up 13 percent; 5,794 follow-up actions, up 35 percent; categories and risks | European Commission, press release IP/26/537, 5 March 2026, opened 2026-09-23 |
| GPSR application | applies from 13 December 2024; batch or serial number under Article 9 | GOV.UK, EU Regulation 2023/988 on general product safety, detailed guidance, opened 2026-09-23 |
| Article 35 and 37 | direct notification without undue delay; notice languages; at least two of repair, replacement, refund, cost-free and timely | Norton Rose Fulbright, new EU product recall requirements under the GPSR, opened 2026-09-23 |
| Article 35 to 37, channels and wording | other channels; terms that decrease perception of risk; template 2024/1435 | Cooley, the GPSR: new rules for product recalls, 7 November 2025, opened 2026-09-23 |
| Article 36(2) content | heading, product description, risk, consumer actions, remedies | IBF Solutions, standardised template for a recall notice, opened 2026-09-23 |
| Template | Implementing Regulation (EU) 2024/1435, published 27 May 2024, applicable 13 December 2024; use the corrigendum version | Ministry of Industry and Trade of the Czech Republic, recall notice template, opened 2026-09-23 |