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UK product safety management and recall planning: legal and compliance checklist (OPSS guidance; PAS 7100:2022/PAS 7050:2022; UKCA/CE/UKNI)

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This Checklist

This Checklist outlines the principal points a business should weigh up when confronting a product safety issue. It explains what to build into systems for managing product liability exposure in this field, with reference to the Code of Practice on Product recalls and other corrective actions (PAS 7100:2022).

  • Pinpoint all applicable laws (eg Sale of Goods Act 1979, Sale and Supply of Goods Act 1994, Consumer Protection Act 1987, General Product Safety Regulations 2005 (GPSR 2005), SI 2005/1803, Consumer Rights Act 2015, Digital Markets, Competition and Consumers Act 2024), standards, and codes of practice (eg Code of Practice on Product recalls and other corrective actions (PAS 7100:2022) and Code of Practice on Bringing Safe Products to the Market (PAS 7050:2022)) that govern the products. See Practice Notes: Consumer protection for defective or dangerous products—legal bases, Product liability and defective products and General Product Safety Regulations 2005—Offences.
  • Also, identify industry best practice (eg by trade associations) and consider putting it into effect.
  • Take into account specific regimes for the manufacture, import and sale of particular goods such as fireworks, cosmetics, toys, pharmaceuticals and medical devices, food and animal feed, and automotive.
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Simon Castley
Simon Castley chambers

Simon is a partner in the Litigation and Arbitration group at CMS. He has extensive expertise in product liability, regulation, and class action issues with a sector focus on consumer products and manufacturing industry, including major FMCG and automotive companies. Simon is increasingly involved in supporting manufacturers in connection with new legislation that has the potential to create an unfavourable regulatory environment and adversely impact the levels of claims against them.  Simon was previously the London office managing partner of a prominent US litigation (defendant) practice specialising in product liability law....

Emma Bolton
Emma Bolton

Emma is a senior analyst in the firm's London office. Emma has assisted the lawyers in support of product liability litigation in England as well as assisted on US matters for a wide range of client products. ...

Leo Fielding
Leo Fielding

Leo handles a variety of multinational claims and regulatory issues with an emphasis on protecting clients’ brands in the United Kingdom, United States and Europe.  He focuses on highly regulated consumer products and covers the full spectrum of both pre-market and post-market regulations, risk and liability. He has worked extensively on mass torts and group actions with an emphasis on technical product features and marketing claims.  His experience also includes advising on complex, cross-border commercial litigation, arbitration, internal investigations and regulatory issues. Before joining SHB, Leo spent six years in the commercial disputes team of Freshfields Bruckhaus Deringer in London and has spent time on client secondment at BP. Product Liability - Litigation on tort, strict liability and civil law remedies together with advice on liability regulation, marketing, advertising and defense of prosecutions. Product safety counselling regarding product safety reporting, recalls and...

Web page updated on 20/05/2026

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