Injury and Accident Law
Communicating Recall Information
Communicating Recall Information
The Commission encourages companies to be creative in developing ways to reach owners of recalled products and to motivate them to respond. The following are examples of types of notice that may be appropriate. This list is meant as a guide only, and is by no means all-inclusive. As new or innovative methods of notice and means of communication become available, such as use of the Internet, the staff encourages their use.
- A joint news release from CPSC and the firm;
- Targeted distribution of the news release;
- A dedicated toll-free number and/or fax number for consumers to call to respond to the recall notice;
- Information on recalling firm’s world wide web sites and ability to register for recall remedy on-line;
- A video news release to complement the written news release;
- A national news conference and/or television or radio announcements;
- Direct notice to consumers known to have the product -- identified through registration cards, credit cards, sales records, catalog orders, or other means;
- Notices to distributors, dealers, sales representatives, retailers, service personnel, installers, and other persons who may have handled or been involved with the product;
- Purchase of mailing lists of populations likely to use the product;
- Paid notices via television and/or radio;
- Paid notices in national newspapers and/or magazines to reach targeted users of the product;
- Paid notices through local or regional media;
- Incentives such as money, gifts, premiums, or coupons to encourage consumers to return the product;
- Point-of-purchase posters;
- Notices in product catalogs, newsletters, and other marketing materials;
- Posters for display at locations where users are likely to visit, such as stores, medical clinics, pediatricians' offices, day care centers, repair shops, equipment rental locations, etc.;
- Notices to repair/parts shops;
- Service bulletins;
- Notices included with product replacement parts/accessories;
- Notices to day care centers;
- Notices to second hand stores.
The Compliance staff must review and agree upon each communication that a firm intends to use in a product recall before publication or dissemination. It is, therefore, imperative that companies give the Compliance staff advance drafts of all notices or other communications to media, customers, and consumers. Following are some specific suggestions for communicating recall information:
Unless a firm can identify all purchasers of a product being recalled and notify them directly, the Commission typically issues a news release jointly with the firm. The Compliance staff develops the wording of the release with the recalling firm and in conjunction with the Commission's Office of Information and Public Affairs. The agreed-upon language for the news release provides the foundation for preparing other notice documents. The Commission discourages unilateral releases issued by companies because they create confusion among the media and public, particularly if CPSC is also issuing a release on the same subject.
The CPSC’s Office of Information and Public Affairs sends the news releases to national wire services, major metropolitan daily newspapers, television and radio networks, and periodicals on the agency's news contact mailing list. News releases from the Commission receive wide media attention and generate a good response rate from consumers.
Each recall news release should use the word "recall" in the heading and should begin, "In cooperation with the U.S. Consumer Product Safety Commission (CPSC)...."
Recall news releases must include the following:
- The name and location of the recalling firm
- The name of the product
- The number of products involved
- A description of the hazard
- The number of deaths, injuries, and incidents involving the product
- Detailed description of the product, including model numbers, colors, sizes, and labeling
- A line drawing or photograph of the product
- Major retailers and where and when the product was sold and retail cost
- Complete instructions for consumers on how to participate in the recall
When a recalling firm has the ability to reach all owners of a recalled product through direct notification (for example, by registration cards, membership or loyalty cards, catalog sales, credit card purchases, extended warranty sales, etc.), the staff will prepare a recall alert in the form and style of a press release. It will be posted on the CPSC website (available via: www.cpsc.gov or www.recalls.gov) so consumers can confirm and verify the Commission is involved in the recall. Summaries of recall alerts are also provided to national wire services.
Video News Releases
A video news release (VNR) is a video version of the written news release that describes the recall in audio-visual terms. Distributed via satellite to television stations nationwide, it is an effective method to enhance a recall announcement. A VNR increases the chances that television news media will air information about a recall because it effectively provides news of the recall to television news producers in the form that they need.
Commission staff works with firms to produce VNRs announcing recalls. Like news releases, VNRs need to communicate basic information clearly and concisely. VNRs should incorporate the same information as the news release, as well as video images of the product. They often also include brief statements of firm officials and/or the Chairman of the Commission. When writing a VNR script, remember that, if this information is to reach consumers, television networks or local stations must pick it up -- which means that the script must be written for television producers.
A brief guide describing how to produce a VNR is available from the Office of Compliance upon request or at: http://www.cpsc.gov/BUSINFO/vnrprod.html.
Posters are an effective means of providing continuing notice of recalls to consumers at points of purchase or other locations that they visit. Guidelines for posters and counter cards are as follows:
- Keep them BRIEF and eye-catching; in general, a poster requires far fewer words than a news release.
- Describe the hazard and tell consumers what to do.
- Use color to make the poster stand out.
- Use a print font, size, and color that provides a strong contrast to the background color of the poster.
- Include the terms "safety" and "recall" in the heading.
- Use a good quality line drawing or photograph of the product with call outs identifying product information, such as model numbers and date codes.
- The firm’s toll-free telephone number should be in large size type at the bottom of the poster.
- The poster should include "Post until [date at least 120 days from recall announcement]."
- Consider tear-off sheets with each poster with information on the recall for consumers to take home.
When a firm produces a point of purchase poster announcing a recall, it must contact its retailers or other entities that the firm wants to display the posters before the recall is announced. The firm must explain the reason for the recall and the contribution to public safety that the posters provide. The firm must also:
- Advise retailers or other firms to place the posters in several conspicuous locations in their stores or offices where customers will see them, e.g., the area where the product was originally displayed for sale, store entrances, waiting rooms in pediatric clinics, service counters at repair shops.
- Provide sufficient numbers of posters for retailers or others to display them in more than one place in each store or location, and provide a contact for ordering additional posters.
CPSC recommends that posters be 11 x 17 inches, but in no case smaller than 8.5 x 11 inches. These two sizes are easiest to mail in bulk quantities. Larger sizes may be appropriate for repair and service shops. Also, many retailers, particularly large chains, have specific requirements for posters, including size and some product identification information. To avoid delays and having to reprint, a firm producing a recall poster must contact retailers in advance to see if they have any such requirements.
Other Forms of Notice
Like news releases and posters, letters, advertisements, bulletins, newsletters, and other communications about a recall need to provide sufficient information and motivation for the reader or listener to identify the product and to take the action you are requesting. They should be written in language targeted to the intended audience.
- Letters or other communications should be specific and concise.
- The words "Important Safety Notice" or "Safety Recall" must appear at the top of each notice and cover letter or in the subject line of
- Notices to retailers and distributors must explain the reason for the recall, including the hazard, and include all the instructions needed to tell them how to handle their product inventory, as well as instructions for displaying posters or notices, providing information to consumers, and disposing of returned products.
- All letters and other notices to consumers must explain clearly the reason for the recall, including injury or potential injury information, and provide complete instructions.
an email notification and must also be on the lower left corner of any mailing envelope.
A firm conducting a recall must provide a toll-free (800/888/877/866) telephone number for consumers to respond to the recall announcement. Generally, this number should be dedicated only to the recall. Historically, the Commission staff has found that most firm’s systems for handling consumer relations or for ordering products, repairs, or accessories are unable to respond effectively to callers about recall announcements, particularly during the first few weeks after the initial announcement.
When establishing a telephone system to handle a recall, be over-generous in estimating consumer response, especially during the first several days/weeks. It is easier to cut back than it is to add more capacity once a recall is announced, and consumers who are unable to get through may get upset.
Whether you use an automated system or live operators to answer the calls, prepare scripts and instructions for responding to questions. Operators or taped messages should begin by identifying the firm and product and explaining the reason for the recall. Most consumers who hear about a recall by radio, television, or word of mouth will not remember all the information they initially heard. Again, at its beginning, the message should reinforce the need for listeners to act, particularly if the message is lengthy.
CPSC Compliance staff must review all scripts before the recall is announced. All automated systems should provide a number for consumers to contact the firm for special problems, e.g., problems completing repairs or installing parts.
Companies should post and make available a notice of the recall in a conspicuous location on their own website. The recall information should be segregated from other company information with a distinct icon or heading designating this safety information. Firms should provide historical recall information since not all products are returned during the designated recall period. Companies should provide an opportunity for owners of recalled products to register for the recall remedy on-line.