Withdrawal
Definition
Withdrawal is any measure aimed at preventing a product that is in the supply chain from being made available on the market. It stops onward supply but does not seek the return of units already held by end users.
Expanded Explanation
The definition is set in Regulation (EU) 2019/1020, which carries it forward from earlier product safety law. Withdrawal acts on stock: units in warehouses, in transit, with distributors and on retail shelves or online listings. It is the appropriate measure when a product must stop being supplied but poses no risk that justifies retrieving units already sold.
For a passport-bearing product, withdrawal can be triggered by informational non-compliance as well as physical non-compliance. If a required passport is absent, inaccessible or materially wrong, the product may not be lawfully made available even though nothing about the article itself has changed.
Why It Matters
Withdrawal is commercially disruptive but recoverable. Distinguishing it from recall matters for proportionality, cost and communication: a withdrawal is a supply-chain instruction, a recall is a consumer-facing event.
Legal and Regulatory Context
Definitions and powers are in Regulation (EU) 2019/1020. Where a product-specific measure adopted under Regulation (EU) 2024/1781 sets passport requirements, failure to meet them can be the non-compliance that triggers withdrawal once the relevant application date is reached.
Relationship to Adjacent Concepts
Withdrawal and recall are both forms of corrective action, distinguished by whether end users are asked to return the product.
Common Misconceptions
They are separately defined legal measures. Withdrawal addresses the supply chain; recall addresses products already with end users.
Related Terms
Related Knowledge Base Articles
- How Digital Product Passports Will Be Enforced
- Who Is Legally Responsible for a Digital Product Passport?
Related Articles
- Corrective Action
- Market Surveillance
- Market Surveillance Authority
- Recall
- Authorised Representative
- Conformity Assessment
- EU Declaration of Conformity
- Harmonised Standard
See Also
References
- Regulation (EU) 2019/1020 on market surveillance and compliance of products: https://eur-lex.europa.eu/eli/reg/2019/1020/oj
About This Article
tieback Knowledge is a continuously maintained reference library covering Digital Product Passports, product traceability, product compliance and related regulations. Articles are reviewed regularly as legislation, standards and implementation guidance evolve.