When a product defect is discovered, foreign companies must navigate China's recall requirements. Here's how to manage product recalls effectively.
When Recall Is Required
- Product has safety defects
- Does not meet mandatory standards
- Poses unreasonable risk of harm
- Regulatory authority orders recall
Types of Recalls
Voluntary Recall
- Company initiates
- Shows responsibility
- May reduce penalties
Mandatory Recall
- Ordered by authorities
- When company fails to act
- Stricter oversight
Best Practice: Voluntary recalls are viewed more favorably by regulators and can help protect your brand reputation.
Recall Process
- Investigation: Confirm defect and scope
- Notification: Report to relevant authority
- Plan submission: Submit recall plan
- Public notice: Announce recall
- Implementation: Execute recall
- Reporting: Submit completion report
Regulatory Authorities
- SAMR: General consumer products
- NMPA: Drugs and medical devices
- MIIT: Automobiles
- Customs: Imported products
Recall Plan Contents
- Product identification
- Defect description
- Affected quantity and distribution
- Remedy measures
- Timeline
- Consumer notification method
Consumer Remedies
- Repair
- Replacement
- Refund
- Other appropriate measures
Penalties for Non-Compliance
- Fines
- Confiscation of products
- Business license revocation
- Criminal liability for serious cases
Managing Recall Costs
- Product liability insurance
- Supplier indemnification
- Recall cost insurance
- Efficient logistics planning
Prevention
- Quality control systems
- Compliance testing
- Supply chain monitoring
- Early warning systems
Product Recall Assistance
I help foreign companies manage product recalls and regulatory compliance in China.
Contact MeDisclaimer: This article is for informational purposes only and does not constitute legal advice. For advice on your specific situation, please contact me directly.
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