You can draw up a recall procedure for the most part yourself. Regulation (EU) 2023/988 does not prescribe a single fixed format, but it does expect you to know in advance who you must inform, how you reach customers, and what steps you take if a product must be withdrawn from the market. If you have that foundation in order, you can write most of the procedure yourself. Where it becomes more difficult is with the sections that align with your specific role in the supply chain and with the risk assessment of the product itself.
The boundary between doing it yourself and outsourcing therefore does not lie with the document as a whole, but with individual sections. Some sections are organisational and you can establish them yourself. Other sections require knowledge about obligations that differ by role, and there it is advisable not to improvise.
What a recall procedure regulates in practice
A recall procedure describes what happens as soon as it becomes clear that a product may not be safe: who within your organisation makes that decision, which customers and sales channels you must reach, what text you communicate, and how you retrieve or block stock. The procedure is separate from the question of whether a product actually poses a risk; it is a procedure that is ready before that question arises. That distinction is important: gpsria.eu structures this process and the associated steps, but itself gives no judgment on the safety of a product and does not state that a product complies with the law.
Sections you can usually complete yourself
The internal side of the procedure is usually easy to write yourself. Think of the contact person who receives a report internally, the list of sales channels and wholesale partners you must inform, the template text to customers, and the logistical arrangements for returns or destruction. These are matters that you as an organisation can oversee yourself, without necessarily needing legal expertise for that. Setting out who within your company is authorised to initiate a recall action is also something you can determine yourself and set out in a procedure.
Where the boundary often lies
It becomes more difficult with the sections that depend on your role in the supply chain. A manufacturer has different obligations than an importer or a pure reseller, and those obligations partly determine what must be included in the procedure regarding notifications to supervisory authorities and the scope of the action. If you are not sure which role applies to your situation, you can check that first with the free role and obligation check; that provides an indication, without you needing an account first.
The assessment of when a situation must actually be treated as a recall action, and not as a routine complaint or a single return, also often requires specific expertise. The same applies to the question of whether, and how, a report must be made through the designated channels. These are not steps you can leave to a generic template; they depend on the nature of the product and your position in the supply chain.
Do it yourself, structure it, or have it drawn up
In practice, a middle ground often works best: establish the organizational side yourself, and have the parts that relate to legal obligations reviewed by someone who knows the situation. gpsria.eu offers a compliance system for this purpose in which the recall procedure is structured alongside your complaint register and product dossiers, so that the steps align with each other. We never act ourselves as the responsible party in the EU; for that role, and for the definitive legal assessment of your situation, we refer you to specialized partners.
If you want to see what is exactly in the compliance system and what remains free, you will find a complete overview in the knowledge base with all topics per situation. It is also possible to read how the information on the site is created and what it is based on via the explanation of how gpsria.eu works.
A practical first step
Before you invest time in writing a complete recall procedure, it is useful first to clarify which role you hold and what obligations follow from it. This prevents you from setting up a procedure that does not align with what is actually expected of you. Do the free role check, or browse through the knowledge base to see which parts are relevant to your situation.