A manufacturer must regularly review its products taking into account any event that could materially affect the potential risk to the target market. At the very least, any review must ask:
- whether the product meets the identified needs, characteristics and objectives of the target market (including those with characteristics of vulnerability),
- whether the intended distribution strategy remains appropriate, including whether the product is being distributed to the target market or reaching retail customers outside the target market,[1] and
- whether products or services have been distributed to customers in the target market.[2]
Where a manufacturer identifies any circumstances related to the product that may adversely affect retail customers, it must:
- take appropriate action to mitigate the situation and prevent any further harm, and
- where appropriate, promptly inform other relevant persons in the distribution chain about the circumstances that led to action being taken and the remedial action taken.[3]
In terms of action it could take, a manufacturer could consider:
- making changes to a product or service,
- providing additional information to distributors or customers,
- amending the distribution strategy before making further sales,
- offering existing customers the option to leave the product or service without additional cost, or
- providing appropriate mitigation of any harm suffered.[4]
Next time
Next time, we’ll be turning our attention to look at product monitoring and governance, so stay tuned!
[1] PRIN 2A.3.7R
[2] FG 22/5, 6.65
[3] PRIN 2A.3.8R
[4] FG 22/5, 6.79
