This panel, fully titled “Challenges to Recalls, How to Get Consumers to Respond to Recalls, and New Effective Ways to Reach Consumers,” featured Carolyn Carlin, Christoper Nguyen, and Tanya Topka from CPSC. Here are key points from the session.
- CPSC Compliance Officer Carolyn Carlin stated that she not only expects recalling companies to use social media to communicate recalls, but she also expects tweets and Facebook posts to be reposted periodically, especially if a high number of marketing messages will follow soon after the recall post.
- Fast Track Team Lead Tanya Topka sees a relationship between increased use of social media and recall effectiveness.
- Her perspective is that a company should “recall your product the way you market your product.”
My thoughts: social media is not going away. If you handle recalls for your company, you may want to prospectively meet with your marketing and social media teams about this issue, so that posting a recall on Twitter won’t be a surprise when a recall occurs.
- Ms. Carlin said that recall posters are generally ineffective, only working well if they are placed on the shelf/in the location where the recalled product was offered for sale.
- She suggested that CPSC compliance officers will start including agreement on sign location when establishing the Corrective Action Plan.
- Tanya Topka will permit companies to eliminate in-store posters if companies present comprehensive social media plans (more than just tweets and Facebook posts – she gave paid ads as an example). She would trade the cost of posters for enhanced social media, and she expects posters to go lower and lower on the priority list for Corrective Action Plans (but note that some state laws require posters in-store if a product is recalled).
My thoughts: given the state laws and the difficulty of issuing customized CAPs to store personnel in individual states, I don’t see recall posters going away anytime soon. But the reference to enhanced social media suggests an opportunity for recalling companies to really build brand loyalty in connection with a recall, as social media permits direct contact with customers.
- In Ms. Topka’s experience, price point is one of the biggest factors in return rates for recalled products – more expensive products have higher recall return rates.
- Specialty products also have high recall return rates
- In response to an audience question, Ms. Topka expressed concern that recalled products often have no permanent marking on the product itself, so consumers cannot determine whether their product is subject to recall. She said she is evaluating systems for tracking products once packaging is thrown away, including photo registries.
My thoughts: photo registration (where a consumer can register a product by taking a picture and sending it to the manufacturer) may be the future of tracking labels. One audience member noted that photo registration can be a beneficial tool because it gives the manufacturer direct access to customers in addition to allowing a recalling company to directly contact customers who have the recalled product.
- CPSC is contemplating electronic filing of progress reports to facilitate submission, but also to allow CPSC to better analyze the information
My thoughts: I suspect this would be a welcome change, since the current fillable PDF seems to be more difficult to fill out than executing a recall.