This month, the Consumer Product Safety Commission (CPSC) is introducing a new template for companies reporting the monthly progress of recalls. Like the prior reporting template, new monthly reports require companies to identify the number of product corrections in the possession of manufacturers, distributors, retailers and consumers, as well as incident updates. However, the new reports now require information on the number of website hits to the recall materials posted on the firm’s website, as well as information on the number of Facebook posts and responses, the number of Twitter feeds and retweets, and identified availability of the recalled product on any online auction sites. Notable evidence of the shift to online presence is the absence in the new template of any reference to the number of printed retailer posters. The new reporting template is available at www.cpsc.gov.
These changes suggest that companies need to ensure they have the ability to monitor recall-related postings and website hits, as well as policies in place to address social media posting. The CPSC might be working toward formal rulemaking requiring social media postings and imposing a duty on companies to examine resale of recalled products online. This means now is the time to get your company recall-ready. McGuireWoods’ CPSC team has decades of experience counseling manufacturers, importers, distributors and retailers on their regulatory obligations and remedies, including all manner of CPSC compliance issues. We invite you to contact us to discuss your company’s recall readiness and response plan.