Use case
From the first complaint to the last batch brought back: a product recall that means "without undue delay" and can prove it.
A manufacturer of battery-powered garden tools, around 400 employees, selling through specialist dealers, DIY stores and its own online shop. Monday, 09:15: a dealer reports three complaints about hedge trimmers from the same batch, all for overheating at the battery compartment, one with scorch marks on the housing. The law sets no fixed number of hours here; it requires action "without undue delay". If it comes to a dispute, you have to show that not a single hour went unused from Monday morning onwards. We give your quality management the software for exactly these days: it sets its own deadlines where the law names none, and records every decision with the time. Legal advice and the notification to the authority stay with you.
Duty
What the law requires
Since 13 December 2024, consumer products have been covered by the EU's General Product Safety Regulation, and products for professional use by EU product law, such as the Machinery Regulation, together with the Market Surveillance Regulation. Both demand the same pace: without undue delay.
| Legal basis | Regulation (EU) 2023/988 on general product safety (General Product Safety Regulation, GPSR), Articles 9, 20 and 35 to 37; for professional products the relevant EU harmonisation legislation, for example Article 10(9) of the Machinery Regulation (EU) 2023/1230, and Article 4(3) of the Market Surveillance Regulation (EU) 2019/1020 |
|---|---|
| Who is affected | Manufacturers of consumer products in the EU, such as tools, garden equipment and household appliances. Machinery, installations and components for professional use are covered by EU harmonisation legislation, such as the Machinery Regulation. |
| Trigger | An accident involving a product that has led to death or to serious, including temporary, adverse effects on health (Article 20), or the realisation that a product is dangerous (Article 9). For professional products, becoming aware of a risk. |
| Deadlines | Without undue delay: accident report, corrective measures and informing the authorities. The law does not name a number of hours. |
| Recipient and channel | The authorities of the member state in which the accident occurred, via the Safety Business Gateway, the reporting channel for businesses. For professional products, the competent market surveillance authority. |
| Content of the accident report | Type and identification number of the product, circumstances of the accident |
| Consumer information | Buyers who can be identified are informed directly. The recall notice follows a fixed template with the heading "Product safety recall" and no wording that plays down the risk. Remedy by repair, replacement or refund (Article 37). |
| Public warning | Safety Gate, formerly RAPEX, is the EU's public warning system. |
| Legal position as of | October 2026. We build the workflow; the legal assessment of whether a case must be reported and which corrective measure is sufficient stays with your legal department or law firm. |
Clock
The workflow, hour by hour
Because the law names no hours, the workflow sets its own: risk assessment within 24 hours, decision on the corrective measure within 48 hours. These are internal deadlines, not those of the regulation; they make "without undue delay" something you can prove.
- Minute 0
The complaint arrives, whatever the channel
An email from a dealer, a service ticket, a shop review, an accident report from a consumer or a notice from an authority: every incoming report becomes a case. The workflow extracts the product, batch, serial number, date of purchase and damage, and files the photos.
- Hour 1
Spotting the cluster
One case is a complaint; three identical cases are a pattern. The workflow searches service, warranty and shop for cases with the same fault and groups them by batch, serial number range and production period. By 10:00 your quality management has an overview instead of three separate emails.
- by hour 24
Risk assessment with a proposal
The workflow proposes an assessment: severity of the possible harm, probability, quantity affected according to production and shipping. Your product safety officer confirms or changes the assessment. If there has been an accident, the draft accident report is produced in parallel, with the type and identification number of the product and the circumstances. The clock sends reminders and escalates to management if nothing has been decided.
- by hour 48
Decision on the corrective measure
Stop of sale, withdrawal or recall: the workflow presents the options with figures, such as stock at dealers and in the warehouse from your ERP system and the number of buyers who can be identified. Management makes the decision. After that, the information to the authorities is ready for approval for the Safety Business Gateway.
- Days 2 to 5
Cascade: retail, buyers, the public
First retailers stop selling, then known buyers are told, then the recall notice follows. A person approves each wave.
- Weeks 1 to 12
Returns and remedy
The return rate is a running figure: shipped, returned, repaired, replaced or refunded, per dealer and country. Every return is matched by its serial number. If the rate lags behind, the workflow proposes the next reminder wave.
- afterwards
Closure and lessons
Once the rate reaches your target, the closing status is produced from the log. New fault patterns and revised templates go into the rules.
Cascade
Who learns what has happened, and when
A recall only reaches those it can find. That is why the cascade goes to retail first, then to the buyers you know, then to the public. Each wave has a draft, a person who approves it and a timestamp.
| Wave | Recipient | Channel | Content | Approval |
|---|---|---|---|---|
| 1, with the decision | Specialist dealers, DIY chains, marketplaces and your own online shop | Email to the quality contacts, call to the chains' head offices, block in the shop | Stop of sale, affected batches and serial numbers, clear the shelves, return route | Management and head of sales |
| 2, on the same day | Buyers who can be identified: product registrations, warranty cards, orders in the online shop | Email from the template in the buyer's language, a letter where only a postal address is available | Risk, the device affected and how to recognise it, stop using it, remedy, contact | Product safety and legal department |
| 3, on the same day | All other buyers and the public | Recall notice in the prescribed template, recall page, hotline with a script, notice in shops | "Product safety recall" as the heading, product description with picture, the risk without playing it down, remedy | Product safety and management |
| 4, with the decision, updates ongoing | Authorities via the Safety Business Gateway, for professional products the market surveillance authority | Entry in the gateway from the draft, updates on returns | Product, identification number, risk, measures taken, return rate | Product safety |
| 5, from week 2 | Buyers who have not responded, dealers with stock still on hand | Reminder by email and letter, call list for the field sales team | Reminder with status, simple return route, remedy | Head of service |
You set the order, the templates and the dealer contacts in the analysis. The workflow matches confirmations and questions to the case and follows up when no answer comes. If a DIY store has not confirmed the stop of sale by the evening, the field sales team calls it the next morning.
Approval
What stays with your people
- The risk assessment. The workflow proposes and gives reasons. Whether a product is dangerous is decided by your product safety officer, in case of doubt with the test laboratory and the legal department.
- The corrective measure. Recall or not, repair, replacement or refund: management decides. The workflow supplies the figures.
- Every notification to the authority. No draft goes into the Safety Business Gateway without approval.
- Every wave of the cascade. Wording of the recall notice, group of recipients and timing are confirmed before sending.
- The conversation with the authority. A person answers questions from market surveillance. The workflow puts the case in front of them with every point in time and the return rate.
Integration
Which systems the workflow sits in
A recall needs serial numbers, stock levels and buyers. The workflow reads them where they are today and writes back there.
- IncomingService inbox, complaint form, dealer portal, shop reviews, hotline
- CaseFreshdesk, Zendesk, ServiceNow or the complaints module your quality management already uses
- ProductionSerial numbers, batches and production data from the manufacturing execution system, suppliers per batch
- StockERP such as SAP, Microsoft Dynamics or proALPHA with deliveries per dealer and warehouse stock
- BuyersCustomer database (CRM), product registrations, warranty cards, orders from the online shop
- CommunicationEmail and letter from templates per language, recall page, Teams or Slack for escalation
- AuthoritySafety Business Gateway. Authority portals rarely have an interface: the workflow pre-fills the notification, a person enters it, and the timestamp goes into the log.
Evidence
The log is the evidence
Whether you acted without undue delay is, if in doubt, for someone else to judge. The answer is an export: the first complaint, the cluster, the risk assessment with reasons and the name of the person who approved it, the corrective measure, the notification in the gateway, every wave with its recipients and confirmations, the course of the return rate.
The insurer, the dealers and the auditor receive the same export. And because the individual cases that did not lead to a recall are in the case too, there is proof that every complaint was checked.
Twice a year a trial run with a made-up cluster passes through the workflow without anything going out. It shows whether data and contacts are right and whether those who approve respond within the internal deadlines.
Experience
What we bring
The building blocks of this workflow have been running at our customers for years. We built a service portal with returns process and ticketing system for a fuel cell manufacturer and still look after it today. Processing messy product data by the million from a CRM is something we know from a spare parts dealer. Reading and assigning incoming items at scale is something we know from a technology distributor with twelve sites, where enquiries from twelve sites across Europe reach the right team according to rules.
We put the recall workflow into operation together with your quality management, and the acceptance test is a made-up cluster. It has to show that the workflow finds every dealer with stock from the batch still on hand and obtains the approvals within your internal deadlines. We show you a sample log of such a run in the first call.
Price
Price and scope
The order of magnitude first: the workflow analysis costs €4,900 at a fixed price and takes three days. Based on our projects, a custom tool typically costs between €25,000 and €60,000, as a fixed price that becomes binding after the analysis; the first version is ready in about six weeks, longer with several duties and languages. Ongoing operation after that starts at €2,900 a month and can be cancelled monthly. A more precise figure in advance would be guesswork: a recall for one product line sold in your own shop and one through DIY stores in nine countries do not need the same tool. What determines the price:
- number of incoming channels that complaints come from
- number of systems from which serial numbers, stock levels and buyers are assembled
- number of dealers, countries and languages in the cascade
- whether returns are connected to a logistics provider
- whether buyer data has to be cleaned up first
Data flow: complaints, buyer addresses and production data stay on your server or in a German data centre. The AI components run on open models on your own servers or via EU data centres; no buyer address goes to a model that trains on it. Data flow per service.
Related
Related use cases
- Cyber Resilience Act: the reporting duty as a workflow. When the problem lies not in the device but in the software, with fixed deadlines of 24 and 72 hours.
- Medical devices: reporting incidents. The same path from complaint to report, with deadlines of two, ten or fifteen days.
- NIS2: reporting a security incident in your own operations. When the attack hits the operations that make the product.
- All use cases: reporting duties with deadlines, with the table of deadlines across all duties.
Further reading: Cleaning up CRM data before AI uses it and Workflow analysis: which workflow pays off.
Questions
Questions about the recall workflow
What quality management and management ask before they entrust a recall to a workflow. More answers under Questions and answers.
The law sets no deadline. So why a clock?
Because "without undue delay" is shorter than it sounds, and because you may have to prove it. The workflow sets itself internal deadlines, such as a risk assessment within 24 hours and a decision on the corrective measure within 48 hours, and sends reminders and escalates after that. Which deadlines suit your products is something you set in the analysis with your legal department.
Does the AI decide whether we recall?
No. It spots clusters, proposes a risk assessment and gives its reasons with the cases from the case file. Whether a product is dangerous is decided by your product safety officer; whether and how to recall, by your management. No notification and no email goes out without approval.
We sell almost entirely through retailers and hardly know any buyers. Is it still worth it?
Yes, because retail is the first wave, and without a workflow it is hard to keep track of whether every dealer has confirmed the stop of sale, even with twenty dealers. For buyers, every address counts; that is why putting data in order is often the first step.
Who is there at night and at the weekend, and who is liable for what?
If an accident report arrives on a Friday evening, the workflow opens the case, starts the internal deadlines and calls the people on your on-call list until someone confirms. As part of ongoing operation we monitor that the workflow is running, with response times on working days; round-the-clock standby is agreed separately. If it fails, the dealer list, buyer list and templates are ready as an export so that your team can carry on by hand. Your company remains responsible as the manufacturer for acting without undue delay; we are liable for the tool under our terms and conditions.
Handover
The first step is a 30-minute call.
You tell us about the workflow that costs you the most time. We tell you honestly whether AI pays off there and what the next step would be. Whether a workflow analysis follows is up to you.