RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions

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RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
Stericycle Expert Solutions

 RECALL SPOTLIGHT
 EUROPE: Q3 2019
RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
EXECUTIVE SUMMARY
Stericycle Expert Solution’s Q3 Spotlight report arrives in the midst of one of the biggest constitutional
headaches in Europe, with the question of how the UK will leave the EU one that may – or indeed may not –
be answered by the end of this month.

And while uncertainty remains over the future of that relationship, this quarter’s Spotlight can help us chart
a path ahead with recalls over the last period providing perhaps one of the clearest indications of what the
future holds.

While it may come as little surprise for those of us constantly having to update or renew our phones, the
key trend to have emerged across all categories in Q3 is that of software failures. From motoring to medical
devices, we are seeing more and more products being withdrawn from the market due to problems with
quality and reliability. With the launch of the 5G mobile network also taking place this quarter, bringing with
it a plethora of always-connected in-home devices and smart-nav applications, it is likely that this will be a
growing problem in Q4 and throughout 2020.

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RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
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RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
AUTOMOTIVE SPOTLIGHT - PAGE 6                                                                   FOOD AND BEVERAGE SPOTLIGHT - PAGE 16
                                                                                               For the first time this year, Italy has topped the list for the highest volume of recall
Germany remains at the top the list of notifying countries for the third quarter of the
                                                                                               notifications, accounting for 117 of 968 total notifications.
year, however after a spike in Q2, notices have returned to a lower level. Looking across
the European automotive industry, recall notices have risen by 21% from Q2 and – as
                                                                                               A spike in recalls of fish and fish products reflects the growing seafood market, however
to be expected – passenger cars are the most recalled vehicle in the category although
                                                                                               nuts (144) and fruits and vegetables (109) are still the most recalled products. Poultry
we have seen an increase in the recalls of vans.
                                                                                               issues, which we flagged as one to watch last quarter, have dropped down in Q3 to 70
                                                                                               compared to 104 in Q2 however it will be interesting to see how the poultry market
Broadly speaking, advancing technology has seen some interesting trends come into
                                                                                               changes post Brexit. Withdrawal from the market (130) remained the most common
play over the past few months, with new software and ‘smart’ devices improving user
                                                                                               action taken against recalled products. In contrast, there were fewer instances of product
experience but leaving vehicles vulnerable to defects and hacking.
                                                                                               destruction (82).

TOYS SPOTLIGHT - PAGE 26                                                                        ELECTRONICS SPOTLIGHT - PAGE 36
Our Q3 analysis revealed a rise in recalls over the past three months – although still         The third quarter of the year saw recalls rise by 51% in the electronics industry.
lower than Q1’s post-Christmas spike. Unexpectedly, Hungary placed a large number              New entrants to the recalled product list included: hot plates, insect killers and LED
of recall notifications – reaching the top of the table alongside Poland. Plastic dolls        hydroponics lights, however, USB chargers continue to top the list of electric products
remained the most recalled item with the majority due to chemical risks – hazards of this      recalled. Electric shock remains the predominant reason for recall in the electronics
nature rose by 95% between Q2 and Q3.                                                          market (34 notifications placed in Q3 alone).

Toy slime continues to appear on recall alert lists – with 52 recalls placed so far in 2019,   As was the case across most categories, rising risks from software defects and
compared to just 15 in 2018. Although there’s greater awareness of the potential risks of      vulnerabilities dominated wider trends with the potential to impact manufacturers. In this
harmful chemicals, increasing numbers of counterfeiters and scammers creating genuine          case risks were presented by ‘fake’ chargers that threatened to compromise user safety.
looking products on e-commerce platforms is making it tricky to navigate.
RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
CLOTHING SPOTLIGHT - PAGE 46                                                                MEDICAL DEVICES SPOTLIGHT - PAGE 56
                                                                                            Q3 saw a lot of movement in countries placing alerts of medical device recalls,
The clothing category placed 42 recalls in Q3, with Cyprus notifying the most often (24),
                                                                                            particularly Denmark and Germany. Italy, which topped the list in the previous review
followed by Germany (8), Romania (6) and Bulgaria (4). While recalls are up on the same
                                                                                            period, saw alerts fall 43% in Q3. Quality issues are again the most common reason for
period of 2018, recalls from Q2 are significantly lower.
                                                                                            recalls, with 257 alerts of this nature placed. However, on the whole, recalls of medical
                                                                                            devices have gradually decreased.
The vast majority of recalls were for children’s clothing, particularly dresses, and much
the same as in Q2, risk of injury (25) was the most common recall reason, followed by
                                                                                            Software is driving fantastic advancements in terms of patient monitoring and care, but
chemical risk. It was indeed chemical risk that dominated headlines over the past three
                                                                                            also exposes devices to risks of hacking and software errors. New regulations due to
months, with one major retailer recalling items due to dangerous levels of lead being
                                                                                            come into effect in Europe in 2020 that will help protect against security risks posed by
detected, however swift recall action is encouraging, with retailers taking ownership of
                                                                                            advancing technology.
the recall process.

PHARMACEUTICALS SPOTLIGHT - PAGE 66                                                         CONCLUSIONS - PAGE 76
 Looking at recall data for Q3 2019, there were 99 pharmaceutical recalls from              This Spotlight reinforces the fact that one thing continues to dominate all recall
 July until the end of September, down from 122 notifications in Q2. One of the             categories. From medical devices to automotive and household appliances, we are
 largest recalls in Q3 was for products containing Ranitidine, a drug used to treat         completely reliant on technology. And with this reliance comes great risk. As software
 indigestion, heartburn and acid reflux. In the last three months, 20 products              and technology advances at pace, big industries are finding that they are weathering
 originating from France were recalled. Second to France in terms of volume was             storms that were previously unknown to them.
 Portugal with 17 recalls – down from 22 in Q2 and 39 in Q1.
                                                                                            Hacking, cybercrime and faulty smart devices are making businesses vulnerable.
 As we approach the Brexit deadline date, we can expect companies to scale back             Never has there been a better time to put measures in place to protect customers and
 their R&D activity as uncertainty dominates the market and backlogs present the            brands. Like it or not, we are all operating in a world where technology is fundamental
 likely threat of product expiration.                                                       to progression.
RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
AUTOMOTIVE
SPOTLIGHT
RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
Q3 2019 OVERVIEW
The third quarter of the year continued in a similar vein to the previous two, with Germany again
topping the list of notifying countries with 93 notifications placed in Q3 – accounting to almost
70% of total notices across Europe. However, figures are down after a spike in Q2 (112) and
Germany has returned to similar levels as the beginning of 2019.

Interestingly, the number of cars produced in the USA which were subject to recall has risen to
double the figure in Q1, from six to 12 instances, placing the US third behind Germany (56) and
France (21).

More broadly, recall notices in the automotive industry have risen. Across the whole of Europe
there were 136 vehicle recalls submitted – up by 21% from Q2 (112).

There are a number of wider factors at play here, but technology is the prevailing one for
manufacturers to be aware of. Car recalls are rising as the industry becomes more high-tech,
with more components increasing the risk of defective products. Technology is making vehicles
vulnerable to security breaches and hacking, as well as tougher regulation processes putting
pressure on manufacturers. To help combat this, some manufacturers are investing in what is
known as smart factories, using AI to detect potential defaults before cars leave the premises.

This technology is also being implemented within cars, as smart devices increasingly expand
a vehicle’s capabilities, assisting everything from interior ambience to steering. However,
increasingly tech heavy vehicles might mean more chance of defective elements.

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RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
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RECALL SPOTLIGHT EUROPE: Q3 2019 - Stericycle Expert Solutions
DEEP DIVE
     As highlighted in previous automotive Spotlights, the increasing amount of technology built into new car models is
     leaving them vulnerable to defects.

     To help protect consumers, regulators are cracking down on manufacturers      BMW and Audi. However, high upfront investment is keeping small and
     and as such we can expect the amount of recalls to rise.                      medium sized enterprises at bay, which may restrict their potential to
                                                                                   compete and put them at higher risk of recall instance.
     To help negate any potential recall instances, a growing number of
     automotive producers are investing in ‘smart factories’ – so-called           Another trend having an impact on the automotive industry is the
     Industry 4.0. According to a recent report by Capgemini, the automotive       rise of smart devices. We’ve seen these across the board, from allergy
     sector is the most enthusiastic industry in setting these up, making large    detectors in the food & drink industry to trackable health monitoring in
     investments and setting higher targets for its digital manufacturing          medical devices. For automotive, recent examples include Mercedes-Benz
     operations than any other sector.                                             partnering with Garmin to launch a smartwatch that communicates with
                                                                                   a car’s artificial-intelligence driven dashboard, using the information to
     Figures show 49% of manufacturers have already invested more than             adapt the car’s interior ambiance.
     $250m in smart factories (MASCHINENMARKT INTERNATIONAL 2018) and
     by the end of 2022, automotive manufacturers expect that 24% of their         Another example came from Jaguar Land Rover, which developed a new
     plants will be smart factories.                                               sensory steering wheel that uses heat to tell drivers when to turn left or
                                                                                   right. The thermal changes could also be used to warn of approaching
     Although using manual modelling to predict outcomes based on past             junctions and roads with poor visibility.
     events is not new, manufacturers are increasingly able to harness machine
     learning platforms which not only learn from past failure patterns, but       Tesla has also updated its cars with a Smart Summon feature that allows
     detect issues that would otherwise go unnoticed.                              drivers to call their Tesla to come to them. When tested in an empty
                                                                                   parking lot or a private driveway, it works well, but not so much in busier
     This technology revolution has incredible potential to transform the recall   areas. It’s not hard to think where this might go wrong.
     market, removing any risk before the car has left the production line. This
     type of technology also has potential to be deployed into the field, using    The above example highlights that this type of technology is still in its
     predictive maintenance on vehicle assessments to ensure timely and need-      infancy and the continuous advancement in vehicle technology is blurring
     based upkeep.                                                                 the lines between the traditional automotive industry and the electronics/
                                                                                   tech sector – making it important for established manufacturers to work
     So what can be expected over the next few months? We’ve already seen          closely with tech companies to ensure vehicles and devices are rigorously
     well-known car marques pledge investments in smart factories, including       tested ahead of going to market.

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SAFETY GATE INSIGHT
 For the third quarter in a row, Germany was top of the list of notifying
 countries, with 93 notifications placed. In what has been an unsurprising
 three months, and similar to what we have seen in previous quarters, after
 Germany the largest numbers of notifications came from France (12),
 Portugal (11) and the UK (6).

 The third quarter of the year saw a rise in the number of cars recalled that
 were produced in the USA – doubling from 6 in Q1 to 12 in Q3. The same
 period also saw double the amount of pickup trucks recalled (8), although
 figures have remain relatively low in comparison to passenger cars (88).

 Overall, the main reason for recall in the automotive market in Q3 was
 passenger safety, and the biggest risk was from airbags. Airbags have been
 around since the 1970s and are mandatory in every vehicle. When they were
 first launched, car manufacturers recommended an inspection of them every
 10 years. However, advances in airbag module technology mean long-term,
 functional reliability of the airbags should be ensured. While this is of some
 comfort, the consistent recall of cars with airbag issues can cause concern,
 and is something the wider industry needs to pay close attention to.

 Auto recalls have been on the rise in recent years and the recent figures have
 highlighted that this is unlikely to change anytime soon. Manufacturers must
 shift priority from firefighting to prevention across all functional processes
 with proper quality management solutions – like the solutions made available
 through smart factories. Quality should be at the core of all functions, with
 clearly defined targets and key quality indicators.

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NO. OF RECALLS BY COUNTRY OF PRODUCTION                NO. OF RECALLS BY COUNTRY OF NOTIFICATION                                               NUMBER OF AUTOMOTIVE RECALLS

                                                      100

        Thailand                                       90
                                                                                                                                            150
           Spain                                       80

Republic of Korea                                      70

 United Kingdom                                        60                                                                                   100

           China                                       50

            Italy                                      40
                                                                                                                                                50
           Japan                                       30

    United States                                      20

                                                                                                                                                 0
          France                                       10

                                                                                                                                               18

                                                                                                                                                         18

                                                                                                                                                                 18

                                                                                                                                                                         19

                                                                                                                                                                                 19

                                                                                                                                                                                         19
                                                                                                                                            20

                                                                                                                                                      20

                                                                                                                                                              20

                                                                                                                                                                      20

                                                                                                                                                                              20

                                                                                                                                                                                       20
                                                                                                                                            2

                                                                                                                                                      3

                                                                                                                                                              4

                                                                                                                                                                      1

                                                                                                                                                                              2
        Germany

                                                                                                                                                                                       3
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ANALYSIS
The lag between consumer technology innovation and implementation in
the latest marques is a terrific indicator as to where the sector is heading; and
just as the arrival of highly efficient powerful LED projectors brought about
the inclusion of heads-up displays in more vehicles, the increasing investment
in IOT integration and virtualisation is a perfect indicator as to where the
industry might be headed.

Some integration has already been seen, with Tesla, Nissan and BMW among
early adopters of the app-driven car interface, albeit mostly for gimmicky
reasons. However, the increasing electrification of the motor vehicle fleet
means even greater opportunity for cross device interaction as manufacturers
try to compensate for lack of range and charging time for a greater in-car
experience.

As such, the idea that people will be able to use their mobile phone as the
key for their car is one that doesn’t appear to be that far away, while faster
5G networks and cloud computing opens the door for heads-up satellite
navigation systems, with front-facing cameras to track your position on the
road and highlight both directions and possible threats not too far off in the
distance.

As this report has already highlighted, the risk of hacks has already increased
over recent times. However, the proliferation of IOT within a vehicle makes
this a greater risk than ever before. In fact, there were six recalls for vehicles
linked to software failings in 2019, five of which were in the last quarter.
Software wasn’t listed as a reason for recall in the last two quarters of 2018.

As such, Stericycle Expert Solutions predicts that over the coming months
there will be a sharp rise in the number of software recalls in comparison to
mechanical recalls. With electric cars featuring fewer moving parts than their
petrol and diesel equivalents, this situation will be exacerbated in the years
ahead.

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FOOD & BEVERAGE
SPOTLIGHT
Q3 2019 OVERVIEW
Food, glorious food. We love it, need it and talk about it a lot. And apparently we Europeans love Italian
cuisine most of all. In 2018 YouGov conducted a survey of seven European countries which included the
UK, Germany, Denmark, France, Sweden, Finland and Norway, finding that Italian dishes were the most
popular.

For the first time this year, Italy has topped the list for the highest volume of recall notifications,
accounting for 117 of 968 total notifications.

Thirty-seven of these came under the fish and fish products category – a third of the 107 recalls for
the quarter. This correlates with the growing demand for fish and seafood across Europe, as countries
within the EU continue to rely on seafood imports in response to increasing concern about the carbon
footprint of other meats such as beef, pork and lamb.

According to the WWF, on 9 July Europe had used up all of its domestic fish resources for 2019 and
had to begin importing it from across the world. Countries with the highest dependence on seafood
products from foreign waters include Portugal, Spain, Lithuania, France and Sweden.

Nuts (144) and fruits and vegetables (109) are still the most recalled products, ahead of fish and fish
products (107). It’s the spike in fish recalls that we want to explore further to discover the root cause
and how this fares in relation to poultry recalls, which have dropped down in Q3 to 70 compared to 104
in Q2 – which in itself was a significant spike from just 57 Q1. Is there a wider protein issue at play or is
it down to contamination?

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DEEP DIVE
     Looking more closely at the reasons why notifications were issued by Italy for fish and fish products, a total of 20 were
     cited as containing mercury – all ranked as a serious risk to consumers.

     Putting this into context, mercury exposure at high levels can harm all            In contrast, in Q2 this year we documented the ongoing issue of
     of the major human internal organs. It is believed that increased levels           European sanctions of Brazilian poultry due to salmonella contamination.
     in the bloodstream of unborn babies and young children may harm the                Interestingly, the volume of poultry recalls and notifications dropped to
     development of the nervous system.                                                 only 70 this quarter, down from 104 in Q2.

     Fish and shellfish are a Mediterranean diet staple food. They contain high-        The EU has been running a salmonella reduction scheme for more than
     quality protein and other essential nutrients such as omega-3 fatty acids.         10 years and the UK in particular has a low tolerance for salmonella rates
     The risk posed by mercury in fish depends on both the volumes of mercury           which range from 1.2% to 1.5%, as stipulated by the Foods Standards
     within the fish and of course the amount of fish eaten.                            Agency (FSA). As many as 370 consignments of Brazilian chicken tested
                                                                                        positive for salmonella since April 2017. So why are we seeing a drop in
     In the last 500 years, human activities have caused the release of 1.5million      European notifications?
     tonnes of mercury into the environment and it can easily navigate its way
     into our waterways and travel for up to six months. In a recent article            Of the 43 notifications which cited salmonella contamination as the
     published by Physics World, one of the most dangerous pathways to                  reason for the recall, only three listed Brazil as “countries concerned”. The
     mercury poisoning is for people, is eating large fish like tuna because            notifying countries were the United Kingdom (2) and the Netherlands (1).
     they concentrate the methylmercury they consume from smaller fish and              The sanctions are still in place. It will be interesting to see how the poultry
     shellfish.                                                                         market changes post Brexit. Will the United States become the UK’s largest
                                                                                        poultry supplier? We will find out soon.
     And while we do not believe there is a need for anyone to panic over this,
     it is our thinking that countries like Italy will continue to monitor and reject
     consignments of fish in the coming months as they become more reliant
     on imports from across the world to meet the unrelenting demand for fresh
     fish.

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RASFF INSIGHT
 In addition to the rise in seafood recalls, feed materials went up from 52 in
 Q2 to 73 in Q3, placing the category in the top four most recalled produce
 items. There was also a sharp rise in the volume of recalls that cited “not
 authorised” under action taken. This featured 97 times during Q3, up from 85
 in Q2.

 Withdrawal from the market (130) remained the most common action taken
 against recalled products. In contrast, there were fewer instances of product
 destruction (82).

                    ACTION TAKEN                      Q3 2019
               Withdrawal from the market                130

                  Recall from consumers                  104

                  Import not authorized                  97

                        Re-dispatch                      91

                        Destruction                      82

                     Official detention                  57

                   Informing recipient(s)                46

                   Informing authorities                 38

               Public warning - press release            37

               Physical/chemical treatment               35

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NUMBER OF FOOD RECALLS                                                                                                 NUMBER OF RECALLS BY FOOD CATEGORY

1060
                                                                                                  Cereals and bakery products

1040                                                                                                          Herbs and spices

                                                                                                        Food contact materials
1020

                                                                              Dietetic foods, food supplements, fortified foods
1000
                                                                                 Meat and meat products (other than poultry)

 980
                                                                                      Poultry meat and poultry meat products

 960                                                                                                            Feed materials

                                                                                                         Fish and fish products
 940

                                                                                                         Fruits and vegetables
 920
                                                                                                 Nuts, nut products and seeds
                      19

                                 19

                                                     19
           18

                  20

                             20

                                                 20
       20

                  1

                             2

                                                 3
       4

                 Q

                            Q

                                                 Q
       Q

                                                                                                                                  0

                                                                                                                                        20

                                                                                                                                             40

                                                                                                                                                  60

                                                                                                                                                       80

                                                                                                                                                            0

                                                                                                                                                                 0

                                                                                                                                                                      0

                                                                                                                                                                            0
                                                                                                                                                            10

                                                                                                                                                                 12

                                                                                                                                                                      14

                                                                                                                                                                            16
                                                 NUMBER OF RECALLS BY COUNTRY OF NOTIFICATION

                             140

                             120

                             100

                                 80

                                 60

                                 40

                                 20

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ANALYSIS
 Our diets are changing, with more and more people favouring so-called
 ‘planet-friendly’ foods such as vegetables, ‘clean’ meats and low-impact
 protein from chicken and fish. Despite the increase in recalls due to mercury
 poisoning, it is encouraging to see that the number of recalls over the year
 is on track to be lower than in 2018 as a whole, with 233 fish or fish products
 recalled so far this year compared to 330 for the whole of last year.

 The poultry situation, however, is not quite as rosy, with 231 recalls in the
 category for the year so far, compared to 265 for the whole of 2018. With
 consumer attitudes likely to favour more fish and poultry in the year ahead –
 we anticipate a steady growth in recalls in this area.

 Meanwhile, the introduction of ‘clean’ meats to the marketplace is a trend to
 watch for in Q4 and 2020, with the likes of the Beyond Burger and Impossible
 Burger likely to make an impact over the coming months, with fast food
 chains among those to adopt the veg-based burgers to make an effort to
 react to increasing consumer demand. However, health claims linked to
 these products are already being challenged – something that’s sure to see
 regulators cast a close eye over the content and quality of the products.

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TOY
SPOTLIGHT
Q3 2019 OVERVIEW
It was a quarter of surprises for toy recalls, with Hungary and the UK
submitting far more alerts than the previous half of the year. And while the
first six months of 2019 looked slightly more positive for recalls of plastic
dolls, in Q3 the number of recalls of this product is on the rise again.

Looking at broader trends with the potential to impact toy recalls, the
dangers presented by chemical contamination remain a big risk to
consumers, with notices placed on everything from toy slime to plastic
dolls – both including chemicals harmful to not only children, but the wider
environment.

As we approach the festive season and the must-have toys for 2019 are
announced, it’s worth considering any potential red flags for manufacturers
and consumers to consider, and to see if learnings from last year have been
put into effect. January saw a surge of post-Christmas recalls of some of
the most popular gifts, including hoverboards and toy slime, so it will be
interesting to see whether manufacturers have taken appropriate action.

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DEEP DIVE
     In Europe, children’s toys must pass rigorous health and safety checks before being allowed on the market, and while
     the system does generally protect young people, some products slip through the net as supply chains are globalised
     and online marketplaces make it hard for consumers to know whether an item is genuine.

     Ensuring a child’s safety is at the forefront of every parent’s mind.         With only a few months until Christmas, this year’s must-have toy lists are
     Parents should not need to wonder whether toys are safe for their child.      being published, with the products predicted by leading retailer Smyths
     Unfortunately, seemingly harmless toys and other children’s products can      Toy Store including Barbie, NERF, Paw Patrol and LEGO in addition to some
     pose serious health risks.                                                    brand new toys such as figurines from some of the year’s hit films.

     The toy industry has been plagued with risks posed by the presence of         With toys including everything from plastic dolls to plush animals and
     phthalates, a harmful chemical present to make plastics more flexible,        puzzle sets, each year sees a number of counterfeit copycat products
     durable, and soft, and with the potential to impact a child’s reproductive    become available – especially when official products have sold out. These
     system and liver if ingested.                                                 products don’t follow regulations but are still able to be sold on third-
                                                                                   party online marketplaces that don’t have testing requirements.
     The increasing chemical risk can be somewhat explained by the resurgence      As noted by Inc., “this has in turn spawned a vast ecosystem of
     in popularity of toy slime, with many products tested found to contain the    counterfeiters, scammers, and knockoffs, an ecosystem that poses
     chemical boron. However, the fact that the EU tests products for boron can    an existential threat to businesses that lack the financial resources or
     be of some comfort to consumers, with countries including the US having       manpower to do full-time IP enforcement”.
     no such testing measures in place. One example concerning pink ‘Unicorn
     Poo’ resulted in the withdrawal of all the products from sale, not just the   The marketplace is arguably one of the most active and perhaps the
     affected batch.                                                               most difficult for parents to keep a close eye on, while the sheer number
                                                                                   and variety of products makes it nigh on impossible to regulate every
     We predicted earlier in the year that toy slime would be one product that     single product being sold online. What manufactures can do is stress the
     we expected to see more recalls from as consumers become aware of the         importance of buying from regulated sellers to consumers, and not to
     dangers present, which is perhaps why more alerts have been placed as         compromise on cost or quality.
     product testing becomes more rigorous.

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SAFETY GATE INSIGHT
 After an encouraging second quarter with 106 recalls, in the last three
 months we’ve seen alerts rise again, with 158 submitted. However, this is still
 significantly less than Q1, with post-Christmas alerts placed resulting in a
 high spike.

 Similarly to what we have seen in previous quarters, plastic dolls (17) and toy
 slime (15) were the products with the most recalls, with the latter up from 10
 recalls in Q2 – suggesting that the chemical risk associated with certain toy
 slime products is still very much present, and is something which should be
 paid attention to as we approach the festive season.

 While a spike was observed in recalls placed from the UK, it was Hungary
 and Poland that topped the list of notifying countries, placing 24 each –
 with Hungary suffering a huge spike in the past three months. The majority
 of these recalls were for plastic dolls with phthalate present, a chemical
 which may harm the health of children, causing possible damage to the
 reproductive system.

 Chemical risks similar to the above were by far the most common reason
 behind recalls in Q3 2019, with a huge jump from 39 placed in Q2 to 76
 in Q3 – a rise of 95%. Second to chemical risk was choking, with 40 alerts
 placed in the time period analysed. As we predicted, recalls with a risk to the
 environment have seen a significant decrease, down from 42 placed in the
 first half of the year to just 8 in Q3. However, this is still much higher than
 the entirety of 2018 and could be indicative of a wider trend as the world
 becomes more aware of the environmental impact of certain products and
 materials.

 We can expect further pressure on regulators to ensure contaminants are not
 present in toys in the future, given the potentially devastating outcomes.

32
NUMBER OF RECALLS BY COUNTRY OF NOTIFICATION                                             NUMBER OF RECALLS BY RISK TYPE

30                                                                                         80

                                                                                           70
25

                                                                                           60
20

                                                                                           50
15
                                                                                           40
10
                                                                                           30
5
                                                                                           20
0
                                                                                           10
                                                     ia
     d

              ry

                        m

                                   y

                                         en

                                                           ly

                                                                     k

                                                                              d

                                                                                      ce
                                 an

                                                                    ar
     an

                                                                          an
                                                          Ita
                                                    ak
                       do
              ga

                                                                                  an
                                         ed

                                                                    m
                              rm
    l

                                                                         nl
                                                  ov
 Po

          un

                     ng

                                                                                  Fr
                                       Sw

                                                                en
                                                                                            0

                                                                         Fi
                              Ge

                                              Sl
          H

                   Ki

                                                                D
                   d
               ite

                                                                                                 al

                                                                                                                 g

                                                                                                                                l

                                                                                                                                                s
                                                                                                                                ta

                                                                                                                                               rie
              Un

                                                                                                               in
                                                                                                 ic

                                                                                                                              en
                                                                                                              ok
                                                                                                em

                                                                                                                                               ju
                                                                                                                           m

                                                                                                                                           In
                                                                                                            Ch
                                                                                           Ch

                                                                                                                            n
                                                                                                                         ro
                                                                                                                         vi
                                                                                                                       En
                              NUMBER OF PLASTIC DOLL RECALLS

30
                                                                                                       PRODUCT                       Q3 2019
25
                                                                                                        Plastic doll                      17
20
                                                                                                        Toy slime                         15
15
                                                                                                      Squeezable toy                      14
10
                                                                                                         Soft toy                         10
 5
                                                                                                         Toy gun                          5
 0
                                                                                                        Plastic toy                       5
       18

                            18

                                                19

                                                                  19

                                                                                    19
     20

                          20

                                              20

                                                                20

                                                                                  20
     3

                          4

                                              1

                                                                2

                                                                                  3
     Q

                        Q

                                          Q

                                                                Q

                                                                                  Q

                                                                                                                                                     33
ANALYSIS
 Toy slime has been a focus of Spotlight for several quarters now with 52
 recalls over the course of the year so far compared to just 15 for the entirety
 of 2018. However the public awareness of issues relating to the product
 means it is likely that the recalls in this market are beginning to plateau, with
 other more traditional toys to make a comeback this year. And while Q3 2018
 did show an increase in slime recalls to 18, we believe this is a legacy issue in
 reaction to increased media coverage, with 21 recalls of slime in Q1 and 13 in
 Q2.

 Yet to be revealed at the time of writing, but the impending Star Wars movie
 is also likely to add to this market, with a fresh line of merchandise expected
 as anticipation of the film builds.

 However, the awareness of chemical threats is unlikely to go away, with
 continued environmental protests taking place across the world it is likely
 that scrutiny on what is used to make toys will grow. However, with the
 increasing number of counterfeiters and scammers creating genuine looking
 markets on e-commerce platforms, it is important that governments take
 greater action to ensure the product that reaches consumers is what they
 expect. Perhaps not in time for this Christmas, we anticipate greater emphasis
 on this in 2020.

34
35
ELECTRICAL
GOODS
SPOTLIGHT
Q2 2019 OVERVIEW
It’s been a sparky few months in the electronics industry, with Q3 the highest of the year far
for recalls, up by 50 to 51%. Unexpectedly, Hungary leapt to the top of the table, placing 14
recalls between July and September. After a very quiet start to the year, this influx of activity
is surprising.

While USB chargers continue to be at top the list of the most commonly recalled product
type for electronics, the number of alerts has decreased from 10 in Q1 to six alerts submitted
in Q3. Additionally, there have been a number of new entrants to the recalled product list,
including hot plates, insect killers and LED hydroponics lights, each with two recall notices.

A broader look at the electronics industry reveals an abundance of new technology which
has the potential to impact the recall market as regulators struggle to keep up with the pace
of innovation. One such trend is the rise in popularity of smart home devices and other
connected products creating a threat of cyber-attacks – with some products designed to
steal information. As connection-enabling 5G infrastructure is implemented more broadly,
we will look at how this might impact the recall market.

A second trend is a rise in sales of ‘killer chargers’. With electric shock the predominant
reason for recall in the electrics market (34 notifications placed in Q3 alone), the past quarter
has seen a huge spike in reports of ‘killer chargers’ and fake electronics sold under the guise
of safe brands to unsuspecting consumers on the online marketplace – with these products
not meeting safety standards.

Fake chargers are also causing a stir for more sinister reasons, with reports revealing
lightning cables with the potential for hackers to remotely take over computers.

38
39
DEEP DIVE
With the rise of smart devices and technology innovations, issues surrounding cybersecurity are beginning to pose different
risks, even new risks, to the ones observed at the moment.

The full implementation of 5G infrastructure is expected to exponentially                failing its safety test. When they took the chargers apart, permitted distances
drive the growth of smart devices, at the same time giving rise to the threat            between components were too small, leading to an electric shock risk.
from cyber criminals exploiting connected devices to gain access to personal
information.                                                                             There are far too many sub-par products with serious risks making their way
                                                                                         into consumers’ homes. Which? has taken its findings to the Office for Product
According to new research by the SAM Seamless Network’s Threat Assessment                Safety & Standards (OPSS) to “ensure that online marketplaces take their
Lab, smart home security cameras are the most vulnerable smart devices,                  responsibilities seriously and do not become an unpoliced wild west”.
making up almost half (47%) of overall hacking attempts. Coming in a close
second were smart hubs like Google Home and Amazon Alexa.                                To link back to the first trend on cybersecurity, recent headlines have revealed
                                                                                         that certain ‘fake’ chargers come with a new type of ‘Trojan horse’ capability,
Leading industry expert Matt Wixey, a cyber-security researcher for PWC,                 with specially designed lightning cables being sold containing a wireless
warned that hackers are now sophisticated enough to turn in-home, unsecured              hotspot that a hacker can use to connect to the user’s device and then run
devices such as smart speakers, headphones and laptops into “offensive”                  commands on the computer, putting the victim’s files and personal information
weapons by playing ear-damaging audio.                                                   at risk.

Although the headlines are worrying, it’s essential that manufacturers take note         This is a developing story, first brought to the attention of the world by an
and start thinking seriously about cyber threats as we may soon begin to see a           anonymous hacker in August, who revealed it at the Def Con cybersecurity
large number of products being recalled due to personal data safety issues.              convention. This highly sophisticated form of hacking can be extremely difficult
                                                                                         for consumers to detect due to the fact that it looks like a legitimate cable and
While USB connectors remain at the top of the list of products recalled in the           works just like one too. The hacker/security expert sold out of the cables within
electronics industry for the third quarter of the year, what we may begin to see         hours of launching them.
is a rise in recalls linked to sales of ‘fake’ chargers, which have the ability to not
only compromise phones and computers, but can also put the consumer at                   For manufacturers, urging consumers to purchase from trusted third-party
serious risk.                                                                            sites and from the manufacturer themselves can help mitigate risks, however as
                                                                                         online marketplaces continue to offer what look like identical products at lower
Increasing sales of fake USB chargers could be partly down to the fact that it’s         prices, it’s becoming increasingly difficult for consumers to tell the difference.
extremely difficult to tell the difference between authorised and unauthorised
products, especially when purchasing from an online marketplace. Which? put              With hackers continuously finding new ways to access data, we can expect to
this to the test with several lookalike Apple products – with eight out of 11            see recalls of this nature rise in line with risks of electric shock, burns and fire.
40
41
SAFETY GATE INSIGHT
The third quarter of the year revealed a spike in the number of electronic appliances recalls, jumping from 34 in the last quarter to
51 between July-September.

The majority of the recalls were due to risk of electric shock (34), and the item with the most risk was again a USB charger, with six
alerts placed – double that of the second-most recalled items in the category, hairdryers and multiplug sockets. However, at the
same time, it is worth noting that the number of USB chargers recalled has been decreasing since the beginning of the year.

Although certified electrical items adhere to stringent safety regulations, it’s the ‘fake’ items that pose risk, which when tested fail
to comply with the Low Voltage Directive, which ensures that electrical equipment within certain voltage limits provides a high
level of protection for European citizens. So even though recall numbers of USBs are decreasing, the risks are still present and
ever-changing, so manufacturers cannot rest on their laurels.

Looking at geographic concentration, Hungary, quite unexpectedly, replaced the UK as the country placing the most alerts in Q3.
Following Hungary and the UK, the highest numbers of recalls came from Bulgaria (5) and Italy (4). Finland and Sweden, countries
that at the beginning of the year placed at the top of the table for recall alerts placed, have remained low for another quarter,
suggesting that this was a spike rather than an ongoing trend.

Interestingly, new on the list of the product types with more than one recall in three months are hot plates, insect killer and LED
hydroponics lights. Although this is the first appearance for each and therefore cannot be seen as a growing trend, it’s something
we will be looking out for, particularly as consumer interest in indoor gardening grows and sales of hydroponic lights increase to
reflect this trend.

Finally, in Q3 there were three electronic recalls submitted due to environmental risks. This is the highest number of recalls of
this type that we have seen this year, with two alerts due to environmental risks submitted in Q1 and none in Q2. The results are
fluctuating and as such we cannot yet determine if this will be a continuing trend, however it’s an area we will continue to monitor.

42
NUMBER OF RECALLS BY COUNTRY OF NOTIFICATION                                                 NUMBER OF ELECTRONIC RECALLS

                  16                                                                                             60

                  14
                                                                                                                 50

                  12
                                                                                                                 40
                  10

                                                                                                                 30
                    8

                    6                                                                                            20

                    4                                                                                            10

                    2
                                                                                                                  0

                                                                                                                          19

                                                                                                                                                      19

                                                                                                                                                                              19
                    0

                                                                                                                      20

                                                                                                                                                  20

                                                                                                                                                                          20
                                                                                                                      1

                                                                                                                                                  2

                                                                                                                                                                          3
                                                                                                                  Q

                                                                                                                                                 Q

                                                                                                                                                                      Q
                        ry

                                   m

                                            ia

                                                  ly

                                                            a

                                                                      ia

                                                                                d

                                                                                       ia

                                                                                                  lic

                                                                                                             y
                                                                                                         an
                                                            ni

                                                                            an
                                                 Ita
                                        ar

                                                                   en

                                                                                         t
                                 do
                        ga

                                                                                                   b
                                                                                      oa
                                                        ua

                                                                                                pu

                                                                                                        rm
                                       lg

                                                                           nl
                                                                 ov
                    un

                               ng

                                                                                                                                    TOTAL

                                                                                    Cr
                                                                                                                                                           USB CHARGERS
                                                       th
                                       Bu

                                                                           Fi

                                                                                             Re

                                                                                                       Ge
                                                                 Sl
                  H

                              Ki

                                                       Li

                                                                                         h
                             d

                                                                                        ec
                         ite

                                                                                      Cz
                        Un

                                             NUMBER OF RECALLS BY RISK TYPE

                                                                                                                               PRODUCT TYPE                         Q3 2019
               Burns, Fire
                                                                                                                                 USB charger                              6

             Environment                                                                                                          Hair dryer                              3

                                                                                                                               Multiplug socket                           3
     Burns, Electric shock
                                                                                                                           Mains extension lead                           2

Burns, Electric shock, Fire                                                                                                      Insect killer                            2

                                                                                                                                  Hot plate                               2
            Electric shock
                                                                                                                           LED Hydroponics light                          2
                              0

                                       5

                                                 10

                                                            15

                                                                      20

                                                                                25

                                                                                             30

                                                                                                        35
ANALYSIS
 Toy slime has been a focus of Spotlight for several quarters now with 52
 recalls over the course of the year so far compared to just 15 for the entirety
 of 2018. However the public awareness of issues relating to the product
 means it is likely that the recalls in this market are beginning to plateau, with
 other more traditional toys to make a comeback this year. And while Q3 2018
 did show an increase in slime recalls to 18, we believe this is a legacy issue in
 reaction to increased media coverage, with 21 recalls of slime in Q1 and 13 in
 Q2.

 Yet to be revealed at the time of writing, but the impending Star Wars movie
 is also likely to add to this market, with a fresh line of merchandise expected
 as anticipation of the film builds.

 However, the awareness of chemical threats is unlikely to go away, with
 continued environmental protests taking place across the world it is likely
 that scrutiny on what is used to make toys will grow. However, with the
 increasing number of counterfeiters and scammers creating genuine looking
 markets on e-commerce platforms, it is important that governments take
 greater action to ensure the product that reaches consumers is what they
 expect. Perhaps not in time for this Christmas, we anticipate greater emphasis
 on this in 2020.

44
45
CLOTHING
SPOTLIGHT
Q3 2019 OVERVIEW
Europe is home to some of the world’s top producers of textiles and fashion goods. It
exports over 60% of production outside of Europe, accounts for 10% of EU export and
employs around 5million people.

Clothing recalls are relatively small in comparison to categories like food and drink. Yet
they continue to make the headlines because, more often than not, many recalls in this
category are deemed to pose a serious risk to children.

Looking at this quarter in isolation, there were 42 recalls. Cyprus was the country that
notified most often (24), followed by Germany (8), Romania (6) and Bulgaria (4). On
closer inspection, 35 of the total recalls were in the children’s clothing category.

Much the same as in Q2, risk of injury (25) was the most common reason for items of
clothing being recalled, followed by chemical risk (9), up from three in Q2.

As we predicted in Q2, chemical risks are on the up. And while on the face of it, a
rise from three to nine recalls does not seem like a lot, the fact is that there is a trend
appearing that has the potential to grow further in the coming months and years.

48
49
DEEP DIVE
In July this year, retail giant River Island took steps to recall a
number of garments over fears that they had been manufactured
using high levels of harmful chemicals.

The fashion retailer issued warnings around three products – a playsuit,
cami top, and a hoodie. These items were sold in 2018, which meant the
retailer had no way of removing the items alone. It had to provide its
customers with detailed information on the dangers posed.

In a statement, River Island said these products contained lead in excess of
legal safety levels and present a serious risk to the health of anyone wearing
or handling the product.

The company then went on to recall two more garments which included a
dress and a blouse, over concerns that these items could contain cadmium
in excess of legal safety levels. Customers were told to stop wearing the
products immediately and to keep them away from children. While the
levels were only fractionally above the limits, River Island put the safety of
its customers first and recalled the products.

In a follow up statement, River Island said that it was working with its
suppliers to find out how it happened and to make sure it does not happen
again. This is the first time this year a major retailer has recalled a product
like this. Until now it has been more commonplace for these items to be
seized on entry to the country.

And while we expect more instances like this to happen in the future,
reassuringly fashion houses and retailers are looking into their supply chain
and coming up their own quality control processes to combat the use of
dangerous chemicals in manufacturing facilities.

50
51
SAFETY GATE INSIGHT
 While the volume of clothing related recalls in Q3 (42) is up on the previous
 quarter, if compared to the same period in 2018, the numbers have gone
 down (83).

 In terms of items recalled, girls dresses (7) and children’s dresses (5) were
 the two most significant. In Q2 children’s trousers topped the leader board,
 however there were only four recalls of this item in Q3.

52
NUMBER OF RECALLS BY COUNTRY OF NOTIFICATION                                             NUMBER OF RECALLS PER PRODUCT CATEGORY

                  30                                                           Leather gloves

                  25
                                                                               Girl’s swimsuit

                  20
                                                                              Child’s trousers

                  15
                                                                           Child’s clothing set

                  10
                                                                                  Child’s shirt

                    5
                                                                                 Child’s dress

                    0
                                                                                   Girl’s dress
                          us

                                        y

                                                    ia

                                                                 ia
                                    an

                                                  an

                                                             ar
                        pr

                                   rm

                                                            lg
                                                m
                    Cy

                                                                                                  0

                                                                                                            1

                                                                                                                 2

                                                                                                                          3

                                                                                                                              4

                                                                                                                                       5

                                                                                                                                               6

                                                                                                                                                    7

                                                                                                                                                            8
                                                            Bu
                                             Ro
                                 Ge

                                                                                                                 NUMBER OF CLOTHING RECALLS
                           NUMBER OF RECALLS PER PRODUCT CATEGORY
                                                                                            100

Injuries, Strangulation                                                                      80

        Strangulation                                                                        60

              Choking                                                                        40

             Chemical                                                                        20

               Injuries                                                                       0
                                                                                                      18

                                                                                                                     18

                                                                                                                                  19

                                                                                                                                               19

                                                                                                                                                            19
                                                                                                  20

                                                                                                                  20

                                                                                                                              20

                                                                                                                                           20

                                                                                                                                                        20
                          0

                               5

                                        10

                                             15

                                                       20

                                                            25

                                                                      30

                                                                                                  3

                                                                                                                 4

                                                                                                                              1

                                                                                                                                           2

                                                                                                                                                        3
                                                                                                  Q

                                                                                                                 Q

                                                                                                                              Q

                                                                                                                                           Q

                                                                                                                                                        Q
                                                                                                                                                                 53
ANALYSIS
 The swift action taken by River Island in recalling clothing that came to the
 market with too high levels of cadmium was welcome, but is a bold warning
 that the issues relating to clothing coming into the marketplace are far from
 resolved. While there was a steady reduction from 83 recalls in Q3 2018 to 71,
 by Q4 and just 35 by Q1 2019 and 32 by Q2, the slight increase demonstrates
 that there is no room for complacency.

 Part of this reduction could be partly attributed to the backlash against fast
 fashion, however, it remains to be seen whether the reduction is purely down
 to consumer habits changing or more down to manufacturers being more
 proactive at the point of manufacture given the number of recalls in recent
 years.

 Meanwhile, issues associated with injury risk persist, something that will be a
 particular concern for parents, with many of these risks associated with loose
 cords or pieces of fabric. Once again, the focus will fall upon retailers to due
 diligence and ensure their products are safe for the market – something that
 appears to be happening with increasing frequency.

 The festive period and change of season will of course lead to a swathe
 of new products to market, but we anticipate any increase to be relatively
 moderate in line with the past 12 month’s trends.

54
55
MEDICAL DEVICE
SPOTLIGHT

The following data is the most complete view of European
medical device recall data that currently exists. However
the information was gathered only from the government
websites of the following countries: UK, France, Ireland,
Portugal, Germany, Italy, Spain, Denmark and Greece.
Q3 2019 OVERVIEW
Geographically speaking, the third quarter of the year has seen a lot of
movement in countries placing alerts of medical device recalls, with a big
increase in the number of recalls notified by Denmark and Germany. Italy,
which topped the list in the previous review period, has seen alerts fall by
43% in Q3 (181 vs 104).

In Europe, Germany tops the list of countries manufacturing devices that
have been subject to recall (99), followed by the UK (66). However, this dwarfs
in comparison to the USA, which was the country of origin for 158 medical
device recalls in Q3.

Recalls due to quality issues remain the most common, with 257 alerts placed
in the past three months. The past quarter has also revealed an increase
in the number of medical device recalls due to software issues, which is
something we’ll explore in more depth in the next section of the report.

58
59
DEEP DIVE
     While recall alerts placed for medical devices have decreased over the past quarter, alerts placed because of software
     issues have been gradually increasing since the beginning of the year.

     Looking at data from the US, software is currently the most common                 There is an evidenced need for stricter security regulations, with
     issue causing medical device recalls in America, and while European data           companies like Johnson & Johnson withdrawing its Animas OneTouch
     cannot confirm it just yet, it’s expected that this trend will be replicated       Ping after vulnerabilities were detected in the insulin pump system’s
     in countries around the world as devices continue to advance. A report             cybersecurity. Pacemakers, insulin pumps and other medical devices using
     from Transparency Market Research, estimates global medical device                 software called IPnet have been identified as having potentially hackable
     connectivity will reach $33.5 billion this year.                                   software.

     As noted in Medical Device Network, referring to the US, “software is              The growing need for manufacturers to protect their devices from
     driving incredible advancements in medical technology and opening up               security threats has led the Advanced Medical Technology Association to
     exciting opportunities for decentralised healthcare. But, at the same time         develop five principles to make sure devices are as secure as possible: an
     software is also the leading cause of device recalls and failures prompting        effective cybersecurity risk management program; system-level security;
     calls for a shift in focus”.                                                       coordinated disclosure; information sharing and consensus standards;
                                                                                        regulatory requirements and education.
     Failures of software have resulted in a number of recalls due to patient
     safety being put at risk, for example the UK issued an alert on a Dialog+          Although software vulnerabilities are something which should be at the
     haemodialysis machine due to risk of malfunction of the temperature                forefront of every recall manager’s mind, the prevailing reason for recalls
     sensor, meaning the temperature of dialysis fluid could be incorrect, and          in this category remains quality issues, which includes everything from the
     therefore would affect treatment.                                                  breakage of components to defects in vital mechanisms.

     As well as risk to patient safety, there are also wider security issues at play.   What we can predict here is that with the new quality standards coming
     In July, France’s National Agency for the Safety of Medicines and Health           into effect next year, quality control will be high on the agenda for
     Products (ANSM) developed draft recommendations on the cybersecurity               manufacturers, and we can expect to see levels of testing and standards
     of medical devices, addressing best practices and appropriate standards.           raised in preparation for this.

     These new regulations are in line with Europe’s medical device and in-vitro
     diagnostic regulations due to come into effect in May 2020 as the first CE-
     marking legislation to introduce a security requirement.

60
61
GOVERNMENT INSIGHT
 In total there were 593 recalls placed in Q3 2019 for medical devices across
 Europe, down from 647 in Q2 but up from 309 in Q1 – which could be a sign
 that recalls are returning to a steadier level after a mid-year jump. However, it is
 too early to know this for certain.

 In comparison to the first two quarters of the year, in the last three months
 there was a big increase in the number of recalls notified by Denmark (159 in
 Q3 compared to 62 in Q2). Similarly, the number of notifications coming from
 Germany has increased from 162 in Q2 to 236 in Q3, positioning the country on
 the top of the list. Italy, which topped the list in the previous review period (181
 recalls in Q2), submitted just 104 medical device alerts in this quarter.

 Quality issues remained the most common reason for recalls in Q3, with 257
 alerts placed. However, this is drastically lower that the 510 placed in Q2,
 suggesting companies are putting more focus on their testing procedures to
 prepare for the new EU regulations coming into effect in 2020. The volume of
 recall alerts related to software issues (Q1: 41, Q2: 52 and Q3: 91) have been
 steadily increasing, as did recalls due to mislabelling (Q1: 18, Q2: 17, Q3: 26).

                        RISK TYPE                        Q3 2019

                        Quality Issue                       257

                       Software Issue                       91

                     Mislabelling Issue                     26

                  Outside of Specifications                 10

                           Other                            209

62
NUMBER OF RECALLS BY COUNTRY OF NOTIFICATION

250

200

                                                                                                                                    NUMBER OF RECALLS BY COUNTRY OF ORIGIN
150

100
                                                                                                                                Denmark
 50
                                                                                                                                 Sweden
 0
                                                                                                                             Switzerland
         y

                   k

                                ly

                                           om

                                                                                      nd
                                                           e

                                                                            al

                                                                                                    n

                                                                                                            ce
      an

                 ar

                                                             c

                                                                                                 ai
                             Ita

                                                                          g
                                                          an

                                                                                                          ee
                                                                                    la

                                                                                               Sp
                                                                       tu
                m

                                           gd
  rm

                                                                                 Ire

                                                                                                        Gr
                                                        Fr
             en

                                                                        r
                                          n

                                                                     Po
Ge

                                       Ki
             D

                                                                                                                             Netherlands
                                      d
                                     ite
                                 Un

                                                                                                                      Republic of Ireland

                                     NUMBER OF MEDICAL DEVICE RECALLS                                                             France

                       700                                                                                                          Italy

                       600                                                                                               United Kingdom

                       500
                                                                                                                                Germany

                       400
                                                                                                                 United States of America
                       300

                                                                                                                                            0

                                                                                                                                                50

                                                                                                                                                        0

                                                                                                                                                                 0

                                                                                                                                                                             0
                                                                                                                                                       10

                                                                                                                                                                15

                                                                                                                                                                        20
                       200

                       100

                         0
                                 9

                                                                 9

                                                                                               9
                                1

                                                                1

                                                                                               1
                             20

                                                             20

                                                                                            20
                             1

                                                            2

                                                                                           3
                             Q

                                                            Q

                                                                                           Q

                                                TOTAL                            SOFTWARE ISSUES
                                                                                                                                                                         63
ANALYSIS
 The introduction of new quality standards in 2020 will be a welcome
 development for patients and caregivers alike. However, the enforcement of
 these regulations in the EU is the loudest warning yet that manufacturers will
 have their feet held to the fire if they don’t improve standards themselves.

 While this should, in the long-term, lead to a reduction in quality issues
 over the coming year and indeed for the rest of 2019, we are anticipating
 an increase in software issues as the unintended consequences of updating
 programming to comply with the latest regulations continues. Whether or
 not these software issues dissipate will depend entirely on how simple the
 new measures are to implement.

 Once again, the shadow of Brexit looms, and there will be significant
 uncertainty over which labelling requirements the UK will adhere to if it leaves
 without a deal. As such, we anticipate a possible spike in labelling problems
 in Q4. Whether or not this continues into 2020 will largely depend on how
 the UK’s health service realigns – based entirely on whether its constitutional
 crisis is resolved.

64
65
PHARMACEUTICAL
SPOTLIGHT

The following data is the most complete view of European
pharmaceutical recall data that currently exists. However
the information was gathered only from the government
websites of the following countries: UK, France, Ireland,
Portugal, Germany, Italy, Spain, Denmark and Greece.
Q3 2019 OVERVIEW
 Recalls in the Pharmaceuticals category are often big news due to the fact they are
 destined for human consumption. Reassuringly the manufacture and production of
 pharmaceuticals in Europe is highly regulated by the European Medicines Agency
 (EMA). This means that the medicines which do make their way into our cabinets arrive
 with a high degree of safety and quality assurance. However, 100% safety can never be
 fully guaranteed for any product, irrespective of its purpose.

 Looking at recall data for Q3 2019, there were 99 pharmaceutical recalls from July until
 the end of September, down from 122 notifications in Q2. On closer inspection one of
 the largest recalls in Q3 was for products containing Ranitidine, a drug used to treat
 indigestion, heartburn and acid reflux. The reason for the decision to call the drug in
 was that both the US Food and Drug Administration (FDA) and the European Medicines
 Agency (EMA) wanted to investigate the presence of N-nitrosodimethylamine (NDMA) –
 a substance that could cause cancer in humans.

 While this sounds alarming, the reality is that this substance is found in water and
 foods that we consumer every day. And health authorities have said that there is no
 immediate risk. This illustrates how cautious pharmaceuticals companies are when it
 comes to the quality of their product and indeed the threat of potential reputational
 issues. We believe that many industries like pharmaceuticals are going above and
 beyond to ensure they remain sustainable during a time of widespread political unrest.

68
69
DEEP DIVE
     In our Q2 update, we reported that political unrest – namely Brexit – could potentially disrupt the supply and regulation of
     medicines in Europe.

     The news in late September that the European drug delivery systems market          Taking the UK as an example, in the event of a no-deal Brexit, the Government
     is expected to experience 6.7% growth from 2019-2027 was received by our           has published various technical notices to help big pharma companies take
     team with cautious optimism.                                                       appropriate action. In September two senior NHS bosses for England and
                                                                                        Wales said that they are confident that medicine supplies will be maintained
     Growth in Europe’s drug delivery systems is expected for two reasons – rising      in the event of a no-deal Brexit. However, those operating the pharmaceuticals
     investment in R&D and a swell in chronic disease conditions across Europe.         industry have called on the Government for more information on border
     We want to explore how this is likely to affect regulatory recalls across Europe   procedures.
     in the coming months and the impact those could have on market the recent
     positive market projections.                                                       Chronic conditions such as cardiovascular disease, cancer, respiratory diseases
                                                                                        and diabetes are on the rise and are the leading cause of death in Europe.
     The pharmaceuticals industry is core to the European economy, with the             Until such a time that investment in prevention outweighs investment in
     largest contributors including the UK, Germany and France. This is why these       treatments, the number of people living with chronic diseases will continue to
     three countries feature most often on the recall barometer – both in terms         rise, which will of course put added pressure on the pharmaceuticals industry
     of notifications and countries of origin. Looking particularly at investment       to meet demand. And when demand outstrips supply – something has got to
     into research and development, a paper by PwC – Economic and societal              give. Although, we are not quite there yet.
     footprint of the pharmaceuticals industry in Europe: June 2019 – stated that
     IP incentives and quicker market access are leading factors influencing R&D
     investment decisions. It also noted that members of the European Federation
     of Pharmaceuticals Industries and Associations (EFPIA) believe that if these
     IP incentives were phased out, it would lead to a reduction in their R&D and
     commercial footprint.

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