A recall is a measure aimed at getting a product that is in the end user's hands back to the manufacturer or to the operator that placed it on the market. In Türkiye, Law No. 7223 on Product Safety and Technical Regulations, and in the EU the General Product Safety Regulation (GPSR, 2023/988), applicable since 13 December 2024, set the minimum steps: recognising the risk, informing the competent authority, the notice, offering the consumer a remedy and completing the return. Both texts require the notice to include the information that identifies the product; a notice for a product whose batch or serial number is unknown inevitably ends up broad.
What is the difference between a recall and a withdrawal?
Law No. 7223 defines the two concepts separately. A withdrawal is any measure aimed at preventing a product in the supply chain from being made available on the market; the product is still in a warehouse, with a distributor or on the shelf. A recall is a measure aimed at getting back a product that is already in the end user's hands. The GPSR definitions of "withdrawal" and "recall" draw the same line. In most cases the two run together: what is on the shelf is withdrawn and what has been sold is recalled.
What are the steps of a recall in Türkiye?
Under Law No. 7223, when a manufacturer learns, or ought to know, that a product it has placed on the market is non-compliant, it promptly takes the corrective measures needed to bring the product into compliance and, where necessary, to stop placing it on the market, withdraw it or recall it. If the product presents a risk, the manufacturer informs the competent authority in detail and without delay about the risk and the measures taken.
Article 18 of the Law requires the measures taken to be announced effectively. The notice contains at least:
- the brand, model or type name or other distinguishing features that identify the product,
- where possible, a photograph or illustration of the product,
- a clear description of the measure taken and of the problem that made it necessary,
- the name, address and contact details of the responsible operator,
- the methods recommended to avoid the risk or remedy the problem.
For a recall (Article 19), the notice also gives the addresses where the product will be collected or repaired and the options offered to consumers. The operator offers a user who returns the product at least one of the following: fixing the problem, paying the product's retail value at the date of return, or replacing it with a safe, equivalent product. Costs are borne by the operator carrying out the recall. Distributors must also pass on the information they receive to the next distributor in the chain and display the notice where customers can easily see it.
What does the GPSR require from those selling into the EU?
The GPSR sets out in more detail how consumers are to be reached and how the notice is to be written.
Direct notification (Article 35). All affected consumers who can be identified are reached directly and without undue delay. Operators that collect customer data use it for the recall. Where not everyone can be reached, the notice is spread through channels such as the website, social media, newsletters and points of sale to achieve the widest reach.
Notice text (Article 36). The written notice carries the heading "Product safety recall". It shows a picture of the product, its name and brand, identification numbers such as the batch or serial number and, where relevant, where that number is found on the product. The hazard is described without wording that plays down the risk, such as "voluntary" or "precautionary", and consumers are asked to stop using the product immediately.
Remedy (Article 37). The operator offers at least two of the following: repair, replacement with a safe product, or a refund of at least the price paid. Return shipping costs are not passed on to the consumer.
The Regulation also requires manufacturers to put a type, batch or serial number on their products that consumers can easily see and read. Dangerous products and accidents are reported to market surveillance authorities through the Commission's Safety Business Gateway portal.
Compared with the Turkish rules, two differences stand out in practice. Consumers are offered at least two remedies rather than at least one, and the notice has to show where the number is on the product. The second difference means label design has to take recalls into account: a consumer who cannot find the number cannot tell whether the product in hand is covered.
Where does the process slow down in practice?
The steps the law asks for are clear; the slowdown usually starts where data is missing. If it cannot be established which batches are affected, the scope is kept wide; without a shipment record, distributors cannot be told which batch to set aside; if returns are not counted, the point at which the process was completed cannot be defended in an audit. We cover the operational side of narrowing scope, showing codes as invalid in the field and reversing a false alarm in the article on shortening recall time.
How is the Tagvex record used in a recall?
In Tagvex each batch or unit carries a unique number, and end-of-line, warehouse, distributor and dealer handovers are recorded. When a recall decision is taken, the affected batches and units are identified from this record and their location is visible. When a consumer scans the product with the mobile app, they can see whether it is covered. The record does not replace the notification to the competent authority or the notice obligations that Law No. 7223 and the GPSR place on the operator; it supplies the batch and location information those steps need.
