must I include a complaint received via social media in my complaint register

A complaint via Instagram is just as valid a complaint

Yes, a complaint that comes in via Instagram, Facebook, WhatsApp or another social media channel counts substantively as a complaint about product safety. The channel through which a complaint arrives is not relevant to the question of whether that complaint must be included; what matters is what the complaint concerns. A message from a consumer reporting that a product poses a hazard, breaks in a way that indicates unsafe conditions, or has caused injury is substantively a product safety complaint — regardless of whether it arrives by email, phone, review form or a direct message on social media.

This obligation applies to the manufacturer, and this is a role that encompasses more parties than is often assumed: whoever sells a product under their own name or brand is themselves considered a manufacturer, even if the product was sourced elsewhere and only has their own logo applied to it. For that party, there is an obligation to record complaints about product safety. A distributor — a party that resells products of another brand without making changes to them — does not have this specific registration obligation in the same way; for that role the emphasis lies elsewhere in the supply chain. Which role precisely applies determines what must be done with an incoming complaint, and that makes the question of which role in the supply chain is being fulfilled the first step before the complaint itself is addressed.

Where this obligation stems from: Article 9 of the regulation

Article 9 of Regulation (EU) 2023/988 requires manufacturers to maintain a register of complaints about the safety of their products, as part of the internal procedures for product safety that this provision prescribes. The regulation makes no distinction based on the channel through which a complaint arrives — it concerns the content of the report, not the medium. NVWA confirms on its page on product safety and GPSR that these internal systems are part of the obligations that follow from the regulation. How such a register looks in practice and what exactly it must contain is addressed in the structure of a complaints register and fits within the broader framework of an internal compliance system.