Foreword

Publishing information

This PAS was sponsored by OPSS. Its development was facilitated by BSI Standards Limited and it was published under licence from The British Standards Institution. It came into effect on 31 March 2022.

Acknowledgement is given to Geraldine Cosh, as the technical author, and the following organizations that were involved in the development of this PAS as members of the steering group:

•	Association of Manufacturers of Domestic Appliances (AMDEA)
•	Association of Chief Trading Standards Officers (ACTSO)
•	Baker & McKenzie LLP
•	British Retail Consortium (BRC)
•	British Toy and Hobby Association (BTHA)
•	BSI Consumer and Public Interest Network (CPIN)
•	Chartered Trading Standards Institute (CTSI)
•	Cooley (UK) LLP
•	eBay
•	Electrical Safety First (ESF)
•	London Fire Brigade
•	National Caravan Council (NCC)
•	National Fire Chiefs Council
•	Royal Society for the Prevention of Accidents (ROSPA)
•	Samsung Electronics (UK) Ltd
•	Tesco

Acknowledgement is also given to the members of a wider review panel who were consulted in the development of this PAS.

The British Standards Institution retains ownership and copyright of this PAS. BSI Standards Limited as the publisher of the PAS reserves the right to withdraw or amend this PAS on receipt of authoritative advice that it is appropriate to do so. This PAS will be reviewed at intervals not exceeding two years.

This PAS is not to be regarded as a British Standard. It will be withdrawn in the event it is superseded by a British Standard.

The PAS process enables a code of practice to be rapidly developed in order to fulfil an immediate need in industry. A PAS can be considered for further development as a British Standard, or constitute part of the UK input into the development of a European or International Standard.

Supersession

This PAS supersedes PAS 7100:2018, which is withdrawn.

Relationship with other publications

This PAS is to be read in conjunction with PAS 7050:2022, which supports businesses and regulators in complying with their relevant legal duties relating to placing safe products on the market.

Information about this document

This is a partial revision of the PAS, and introduces the following principal changes:

•	to incorporate changes regarding UK exit from the European Union;
•	alignment with PAS 7050; and
•	new sections for online marketplaces and repair and refurbishment.

This publication can be withdrawn, revised, partially superseded or superseded. Information regarding the status of this publication can be found in the Standards Catalogue on the BSI website at bsigroup.com/standards, or by contacting the Customer Services team.

Where websites and webpages have been cited, they are provided for ease of reference and are correct at the time of publication. The location of a webpage or website, or its contents, cannot be guaranteed.

As a code of practice, this PAS takes the form of recommendations and guidance. It is not to be quoted as if it were a specification. Users are expected to ensure that claims of compliance are not misleading.

Users may substitute any of the recommendations in this PAS with practices of equivalent or better outcome. Any user claiming compliance with this PAS is expected to be able to justify any course of action that deviates from its recommendations.

Presentational conventions

The provisions of this PAS are presented in roman (i.e. upright) type. Its recommendations are expressed in sentences in which the principal auxiliary verb is “should”.

Commentary, explanation and general informative material is presented in smaller italic type, and does not constitute a normative element.

Where words have alternative spellings, the preferred spelling of the Shorter Oxford English Dictionary is used (e.g. “organization” rather than “organisation”).

Copyright is claimed on Figure 1. The copyright holder is the Office for Product Safety and Standards (OPSS), 4th Floor Cannon House, 18 The Priory Queensway, Birmingham, B4 6BS, United Kingdom.

Contractual and legal considerations

This publication has been prepared in good faith, however no representation, warranty, assurance or undertaking (express or implied) is or will be made, and no responsibility or liability is or will be accepted by BSI in relation to the adequacy, accuracy, completeness or reasonableness of this publication. All and any such responsibility and liability is expressly disclaimed to the full extent permitted by the law.

This publication is provided as is, and is to be used at the recipient’s own risk.

The recipient is advised to consider seeking professional guidance with respect to its use of this publication.

This publication is not intended to constitute a contract. Users are responsible for its correct application.

Compliance with a PAS cannot confer immunity from legal obligations.

Ministerial statement

The government is committed to protecting consumers from unsafe products. The UK’s product safety system requires businesses, government, regulators and consumers to all play important roles in keeping everyone safe. We want to ensure that not only are consumers protected from unsafe products, but that they have confidence in the products they buy and in businesses’ processes and preparedness to deal with any product safety issue should it arise.

I am delighted to welcome these two PAS Standards, produced under the leadership of the British Standards Institution (BSI). Together, the new PAS 7050 and the revised PAS 7100 will help businesses and regulators to have the appropriate systems and processes in place to enable the production of safe goods and to deal quickly and effectively if something goes wrong.

Since the original PAS 7100, Code of practice on consumer product safety related recalls and other corrective actions was launched in 2018, we have made considerable progress in reforming the UK’s product safety system and all learned a tremendous amount from our experiences of product safety and recalls. I am pleased that these experiences have been shared and reflected in these new Codes of Practice. I am grateful to the steering group members and other experts that have worked with BSI to develop these Codes.

Paul Scully MP
Minister for Small Business, Consumers and Labour
Markets and Minister for London

0 Introduction

0.1 General

The General Product Safety Regulations 2005 (GPSR) [1] and other product specific safety regulations require that new and used consumer products placed on the market in the United Kingdom are safe. Businesses across the supply chain are responsible for the safety of products.

The responsibilities imposed by the legislation include duties to:

•	place only safe products on the market, supported by information on their correct use;
•	warn consumers about potential product-related risks;
•	monitor the safety of products;
•	inform the relevant regulator if a safety issue is identified (where appropriate); and
•	take effective corrective action where necessary.

0.2 Incident management plans

OPSS supports this Code of Practice in helping businesses plan for and deal with product safety issues.

Business preparedness, in line with this PAS, supports incident management plans held by local authorities and OPSS as illustrated in Figure 1. [2]

0.3 Alignment with PAS 7050

Summaries of the key regulatory requirements relating to product safety, including the GPSR [1] and some examples of product specific safety regulations, are in Annex A together with details of product liability under civil law. Annex A also sets out the specific responsibilities of businesses with respect to product safety. Where the term businesses is used, this refers to all businesses involved in the manufacture and supply of consumer products, unless otherwise specified.

Although the majority of products placed on the UK market are safe and do not become the subject of corrective action, proactive measures and preparation are essential in the mitigation of product safety challenges and corrective actions. This PAS is also to be read in conjunction with PAS 7050:2022. This PAS and PAS 7050 aim to support businesses and regulators in complying with their relevant legal duties related to placing safe products on the market (PAS 7050) and in the event of a recall, or other corrective action, support businesses on how to prepare and deal with such situations (PAS 7100).

This PAS focuses on the development of a product safety incident plan (PSIP), which forms part of a product safety management plan (PSMP) as outlined in PAS 7050.

0.4 Annex information

Annex A provides the regulatory context for corrective action required of businesses. Annexes A, B and C are informative annexes which provide the regulatory context for corrective action required of businesses, which include a RACI matrix and a summary of risk assessment methodologies.

Checklists (Annexes D, E, F and G) are provided as tools for all businesses who are seeking to assess compliance with Part 1, and their supporting regulators. These are to be used as a guide and do not constitute an exhaustive list, with their relevance and application to be determined by each individual organization. In addition, the terms used might vary across organizations, with different naming conventions employed for the equivalent of a PSMP or PSIP.

Annex H provides guidance on the content and layout of corrective action announcements.

Section 1: Businesses

1 Scope

Part 1 sets out a code of practice for businesses, providing practical guidance to help them:

•	prepare to manage a possible safety related product recall or other corrective action;
•	establish mechanisms to monitor the safety of consumer products;
•	investigate any potential product safety issue;
•	establish mechanisms to deal with any product safety issue identified; and
•	review corrective action programmes to ensure that product safety responsibilities continue to be met.

Part 1 applies to all new and second-hand non-food consumer products including products for hire and loan. Non-food consumer products include those intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers even if use by them is not intended.

Part 1 is for use by all businesses, including manufacturers, designers, importers, distributors, repairers, refurbishers and the operators of online marketplaces for non-food consumer products irrespective of type or size. It is accepted that organizations might need to adjust the scale of activity associated with any product recall or other corrective action undertaken, but the principles that underpin this code are equally applicable whatever the size of organization and should be adhered to in all such undertakings.

Part 1 assumes that businesses placing products on the market, including following repair or refurbishment, will have already addressed their responsibility to supply only safe products and guidance on this is not provided in this PAS.

The PAS is not intended to conflict with existing sector specific schemes (e.g. automotive, medicines, medical devices) which should be referred to in respect of the product categories covered.

Part 1 does not apply to:

•	products covered by sector specific schemes (e.g. automotive, medicines, medical devices); and
•	transactions made directly consumer to consumer without the intermediation of any business.

Although Part 1 is not intended to cover business to business supply for direct use, most of the principles presented would also be relevant.

2 Normative references

3 Terms, definitions and abbreviated terms

4 Product safety incident plan

5 Managing a corrective action

6 Online marketplace operators

7 Repair and refurbishment

8 Distributors and importers of second-hand products

Section 2: Code of practice for regulators

1 Scope

2 Regulatory context

3 Effective regulatory arrangements

4 Support to business to develop a PSIP

5 Support to business incident investigation and risk assessment

6 Support businesses to review/revise PSIP

Bibliography

PAS 7100:2022

Product recall and other corrective actions. Code of practice

Current

Published:

31 Mar 2022