Track, review, report and adjust

  • To make your recall successful, track, review and adjust what you are doing throughout the recall.
  • Whenever there are changes to the risk assessment, you need to let us know.
  • If you find your recall is not effective, or consumers are not responding to your recall, revisit your communication plan.
  • Keep your messages consistent with the approved words from your recall notice.

Checklist

  • Keep track of how many products you and others in the supply chain have provided a remedy for – submit a recall progress report one month after your recall is published and then at agreed times.
  • Monitor and track incidents and complaints.
  • Reassess the risk.
  • Regularly review and update your strategy to know if your communication is effective.
  • Keep recall communication current and consistent. Update messages when there is a change to the defect or hazard or how to receive a remedy. Tell the ACCC so we can update the Product Safety Australia website.
  • Tell the ACCC of any issues or changes with the recall.
See the complete supplier checklist

Track the number of remedies you provide

During the recall, you need to record products remedied and returned and submit reports to us on how the recall is progressing.

Track product remedies you provide and returns

Keep records during the recall. Track how many products have been:

  • remedied
  • returned from the supply chain.

Find out if there are consumers who still have the product and how many. Follow up on all reports of injuries, incidents and complaints about the recall.

Track how many remedies you have provided and compare this to earlier progress reports. Repeat your consumer communications if the number of remedies you have provided is slowing down.

Submit a mandatory report within 2 days of becoming aware of death, serious injury or illness.

You can also report a near miss, or injury or illness that doesn’t meet the threshold for a mandatory report in your regular progress reports or using the voluntary supplier report on our website.

Track how many consumers you have reached

Keep records of how many consumers you have told about the recall. If you have told consumers but are not getting a response, then you may need to review your communications. has sample messages you can use.

If you are providing updated instructions or warning labels, keep track of how many people you have given this information to.

Submit progress reports to us

Once we publish your recall we will write to you to tell you how often you should submit a progress report to us and what information we need. The frequency of reporting may vary depending on our risk assessment.

You will get a reminder email a week before a progress report is due, with a link to the form for you to fill in.

If you need help completing the progress report, email recallsmonitoring@accc.gov.au

Reassess the risk

You are responsible for ongoing risk assessment. There are times when you will need to reassess the risk during the recall. Whenever there are changes to the risk assessment, you need to let us know.

Reassess the risk when:

  • you learn new information about the defect or product – this includes when an overseas regulator issues a safety warning or a compulsory recall
  • you learn that more products you have supplied are also affected by the recall
  • a consumer is injured in Australia or overseas
  • consumers are not responding to the recall messages, or
  • you have only supplied a low number of remedies.

There may be other situations where you need to reassess the risk.

Tell us as soon as possible if you reassess the risk, and the risk level is higher or lower than initially assessed.

If the risk is higher, you’ll need to:

  • update the wording in your communications to consumers and advertisements and make sure the messaging is consistent
  • advise if your recall notice on the Product Safety Australia website needs updating
  • review your communication plan, contact methods, and frequency of contact
  • contact your consumers again with the updated information
  • review other aspects of your strategy for conducting the recall, such as instructions for your downstream suppliers and managing availability of spare parts.

Find out more about assessing the risk and conducting a root cause analysis.

Review the progress of your recall regularly

If you find your recall is not effective, or consumers are not responding to your recall, revisit your communication plan.

Look for ways to make it easier for consumers to access the remedy or contact you.

If we think that a recall is not performing adequately to address the risk, we may ask that you do more to improve the effectiveness of the recall.

A recall is effective when:

  • your recall advertising is clear, accessible and uses the same words as the recall notice
  • affected consumers are aware of the recall and are following your instructions on the recall notice
  • unsold stock has been removed from the supply chain
  • other businesses in the supply chain are aware of the recall and have informed their customers
  • you don’t receive any complaints about your recall, such as consumers not being aware of the recall or experiencing issues or delays in receiving a remedy
  • no incidents or injuries are occurring.

More information can be found in the monitoring and escalating a recall section of this guide.

Repeat your recall communication

Repeat your recall communication across different channels. Keep your messages consistent with the approved words from your recall notice.

If you have not received a response after multiple attempts then you may need to change your contact method or communication style.

Review your communication plan. For the duration of your recall, you can:

  • keep posting recall information on your social media platforms
  • add recall information in your email newsletters (in addition to your initial email about the recall) – mark emails as ‘important’
  • display your recall advertisements in high traffic areas in all retail stores that sold your recalled products. Make it highly visible.

In your follow up communications, add more information to encourage consumers to engage with the recall, including how many consumers have already received a remedy. You can find examples in the recall communications package.

Keep copies of your recall advertisements and communications. We may ask for copies when we assess how effective the recall has been.

We assess and can escalate the recalls we monitor

We assess the recall

Our focus is firstly on publishing your recall notice on the Product Safety Australia website so consumers are notified as quickly as possible of the defect, hazard and action they should take.

We will then write to you to let you know how often you should submit a progress report to us and what information we need.

For most recalls, we will ask you to send your first progress report one month after the recall is published on the Product Safety Australia website. 

The frequency of reporting varies and depends on our assessment of your recall and its risk, and how it compares to other recalls notified to us. We assess:

  • the risk to a person from your product – the severity of injury, or likely injury, likelihood of the hazard occurring, and likelihood of a person recognising the hazard and being able to act to avoid or reduce the injury
  • the risk to the public from your product – the number of affected products with consumers
  • the risk in executing the recall – this involves an assessment of your engagement with us and any challenges you are experiencing with the recall. Examples are:
    • the product has characteristics that make it harder to carry out an effective recall
    • you do not have consumer contact details
    • your consumers mainly come from groups that tend to be less responsive to recalls.

Some of the things we consider when assessing your recall are:

  • the number of affected products still with consumers
  • the defect rate and failure rate
  • the performance of your recall compared to other similar recalls and your earlier recalls
  • complaints or injury reports received or other stakeholder concerns
  • the level of risk to consumers and if this has changed
  • the effectiveness of your communication strategy, and the wording used in communications to consumers
  • issues with publishing your recall notice, including if your remedies are suitable.

We may also begin a review of your recall at other times to assess its effectiveness, including when:

  • you are not responding to us when we contact you
  • you are not providing progress reports
  • we have received a mandatory report, a complaint or other information relevant to the risk of your product and effectiveness of your recall.

Possible outcomes of our assessment

We use our Product Safety Priorities to prioritise what we will escalate.

If we decide that we need to intervene in a recall, we can ask you to:

  • revise your recall advertisements and consumer communications so they are consistent with your recall notice
  • change your remedy, including adding extra incentives for consumers to return the recalled product
  • improve the process for how your consumers receive the remedy
  • repeat your recall communications, including your in-store advertising, social media posts, and emails to consumers
  • meet with us to discuss your strategy.

As a result of our assessment, we may change the frequency of progress reports we need from you. This can include increasing or decreasing the frequency of reports or we may no longer need progress reports.

If you do not agree with our assessment of your recall’s performance, you can ask that we review your case. Email the Director, Monitoring and Recalls at recallsmonitoring@accc.gov.au and include the reasons for your request.

Other actions we can take to reduce the risk to public safety from your product

We may also consider:

  • adding a message to your recall notice on our website to include our view of the recall
  • issuing a safety alert
  • issuing a media statement about our assessment of the risk and concerns about the product
  • requiring that you give information to us under a compulsory information notice
  • enforcement action for engaging in misleading or deceptive conduct, or for making a false or misleading representation that the products are of a particular standard. See our Compliance and Enforcement Policy for how we approach enforcement action
  • recommending that the Commonwealth Minister issues a safety warning notice. This is a formal warning that tells consumers and suppliers about consumer goods or product-related services that may cause injury or are under investigation
  • recommending that the Commonwealth Minister issues a compulsory recall.

The reasons used to decide when to escalate and intervene in a recall are set out in the Product Safety Priorities. As a supplier, you are responsible for the performance of your recall. Managing your recall poorly can impact your business’ reputation and increase your legal risk.