Responding to a CPSC recall notice

Section 15(b) of the Consumer Product Safety Act (CPSA) obligates every manufacturer, importer, distributor, and retailer to report to CPSC any product that fails to comply with a rule, contains a defect that could create a substantial product hazard, or creates an unreasonable risk of serious injury or death. The report is due within 24 hours of learning the triggering information. This guide walks the response playbook and how EntryProof's audit trail supports each step.

Step 1: Preserve every scrap of information about the incident

The moment you learn of an injury report, a media allegation, a lawsuit claim, or a lab test that shows a compliance failure, freeze the state of your records. In EntryProof, the SKU's audit trail already timestamps every certificate version, every test report, every field change, and every share event; nothing you do inside the app rewrites past history. Outside of EntryProof, screenshot the incident report, save the email or ticket, and note the exact time you learned of it.

Step 2: Assess whether the 15(b) trigger is met

CPSC does not require every complaint to be reported. It requires reports of information that reasonably supports the conclusion that the product creates a substantial product hazard. The CPSC Section 15(b) reporting guide on cpsc.gov walks the analysis. When in genuine doubt, err toward reporting; CPSC has a Fast-Track program (see step 4) that materially reduces regulatory friction if you self-report early.

Step 3: File the Section 15(b) report on SaferProducts.gov

Section 15(b) reports are filed through CPSC's Business Portal at saferproducts.gov/CPSRMSPublic/Section15/Section15.aspx. The report walks the incident description, product identification, sales volume, distribution channels, and known injury data. EntryProof pre-computes several of these fields (SKU ID, ASIN, certificate history, sold-through count if you've wired a Shopify or Amazon integration) so you can copy them into the CPSC form without a records hunt.

Step 4: Consider Fast-Track voluntary recall

CPSC's Fast-Track program lets a company voluntarily initiate a corrective action (recall, repair, refund, replacement) within 20 working days of the 15(b) report, in exchange for CPSC skipping the formal Preliminary Determination process. This is dramatically faster and cheaper than a contested recall. Fast-Track details are on the CPSC recall handbook, Section IV on cpsc.gov. The trade-off: you commit to a public recall announcement, so weigh reputational impact.

Step 5: Draft the recall press release

Every CPSC recall gets a joint press release: CPSC drafts, the company reviews, both parties agree on final language. The release lists the product, the hazard, the number of units, the incidents to date, and the remedy. EntryProof's audit trail is useful in this drafting because it shows exactly which certificate versions covered which shipment windows, which tightens the "when were units affected" narrative.

Step 6: Post the recall to your channels

Once the joint release is public, CPSC requires immediate posting to all e-commerce product pages, social channels, and marketing lists. Amazon, Walmart, and Shopify all have recall-notification hooks; the marketplaces themselves are legally obligated to display the recall notice under 15 U.S.C. 2064(b) on congress.gov.

Step 7: Track remedy uptake

CPSC monitors remedy uptake for 12–18 months post-recall. Your job is to keep records of every consumer who claimed a repair/refund/replacement, so you can respond to CPSC's periodic status requests. EntryProof stores these records in a Recalls tab on the SKU. The recall handbook on cpsc.gov above walks the reporting cadence.

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FAQ

How strict is the 24-hour clock? Strict in practice. CPSC has assessed civil penalties in the millions for late 15(b) reports; the CPSC civil penalty factors on ecfr.gov, 16 CFR Part 1119 list reporting delay as a heavily-weighted factor.

Do I need a lawyer to file 15(b)? Not required, but strongly recommended for anything beyond an unambiguous rule-violation. Section 15 analysis is factually and legally nuanced, and Fast-Track vs contested-recall tradeoffs benefit from counsel.

Does EntryProof file the 15(b) report for me? No. EntryProof surfaces the trigger, exports the audit trail, and can pre-fill fields, but the filing itself is a business decision that must be made and signed by the responsible officer.

Still stuck? Email support@digitalempireholdings.com or support@digitalempireholdings.com.

FAQ

How strict is the 24-hour clock?

Strict in practice. CPSC has assessed civil penalties in the millions for late 15(b) reports; the [CPSC civil penalty factors on ecfr.gov, 16 CFR Part 1119](https://www.ecfr.gov/current/title-16/chapter-II/subchapter-B/part-1119) list reporting delay as a heavily-weighted factor.

Do I need a lawyer to file 15(b)?

Not required, but strongly recommended for anything beyond an unambiguous rule-violation. Section 15 analysis is factually and legally nuanced, and Fast-Track vs contested-recall tradeoffs benefit from counsel.

Does EntryProof file the 15(b) report for me?

No. EntryProof surfaces the trigger, exports the audit trail, and can pre-fill fields, but the filing itself is a business decision that must be made and signed by the responsible officer.