Folks, The General Product Safety Directive (in the UK, the General Product Safety Regulations 2005) have requirements for product recall. For more info on the UK Regulations, see: http://www.dti.gov.uk/consumers/Safety/products/general-regulations/index.html The above link takes you to the Guidance as well as the Regulations themselves. This Directive only applies to consumer equipment and equipment that is capable of being migrated to consumers. For such equipment it applies in addition to the LVD where the LVD applies (e.g. mains powered equipment) and where the LVD does not apply (e.g. SELV powered equipment) it applies alone, since such equipment is outside the voltage range of the LVD. Within the Guidance document, clause 6.5 states "The information provided in the notification [the formal notification that you, the manufacturer/producer, are about to recall the product] must include that required to precisely identify the product, all information relating to tracing the product". Clearly, if you do not have serial numbers marked on your product then the 'product to be traced' relates to everything you ever made of that type - which may well cost a whole lot more than the price of serialisation! Another point that may be of interest to this group is that, while compliance with European standards (e.g. Harmonised Standards as referenced for the LVD) will be taken into account when making an assessment of what is safe (para 4.6), there may be cases where the standards are considered inadequate and so the product is nevertheless found by the Court to be dangerous (see para 4.7). In reality this is nothing new, it is no more than is required under the Product Liability Directive, but it may be a new concept for some who think that compliance with the applicable standards is an end it itself - it isn't. Regards, Richard Hughes
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