Recall campaign instructions
Recall campaign instructions for vehicle manufacturers, manufacturers’ representatives, importers and distributors.
If a vehicle is discovered to have a non-conformity or defect causing a serious risk, the vehicle manufacturer, the manufacturer’s representative, importer or distributor (“economic operators”) should take the corrective measures necessary to bring the vehicle into conformity (i.e. to ensure it meets requirements), to withdraw it from the market or to recall it, as appropriate.
The legal requirements concerning recall campaigns are laid down in EU framework regulations (2018/858, 168/2013 and 167/2013) or the Finnish Vehicles Act (82/2021), depending on the vehicle category.
A recall campaign must also be started if a vehicle has been notified in the SafetyGate alert system maintained by the European Commission and has been assessed to represent a serious risk. Traficom monitors weekly reports and contacts economic operators in Finland with enquiries, if necessary.
Traficom also monitors the ICSMS system for market surveillance. Via the ICSMS platform, authorities in EU countries can exchange information about products they have tested or investigated and share test results and any non-conformities discovered.
Economic operators must report to Traficom all active recall campaigns that affect vehicles in Finland.
Vehicle manufacturers may also organise service campaigns on account of minor defects or shortcomings. These campaigns do not need to be notified to Traficom.
The recall obligation concerns all vehicle categories defined in the Vehicles Act. It applies to vehicles that have been approved for road transport in Finland and are used in Finland. The obligation concerns both vehicles subject to prior notification and individually imported vehicles.
The obligation to take corrective measures also applies to vehicles, systems, components, separate technical units, parts or equipment that cause a serious risk or have a non-conformity. The step-by-step instructions below concern, where applicable, those vehicle categories that do not need to be registered (e.g. bicycles and light electric vehicles) and other above-mentioned products used in road traffic. Economic operators must reach as many as possible of those consumers who have bought the product by contacting them individually or by making information about the campaign publicly available.
Vehicles registered in the Åland Islands do not need to be included in the recall campaign notification.
Economic operators must ensure that recall campaigns are completed within a reasonable time.
OTA (OVER-THE-AIR) RECALL CAMPAIGNS
This document provides instructions for carrying out OTA (Over-the-Air) recalls. Introduced as an alternative to a traditional recall, an OTA recall is a procedure in which the vehicle holder is notified of a recall electronically. In an OTA recall, the software of a vehicle system is updated over the air to bring the vehicle into conformity or make it so that the vehicle no longer causes a serious risk due to the software after the update.
OTA recalls must be notified to Traficom in accordance with the procedures prescribed by section 178 of the Vehicles Act (see the instructions below).
RECALL CAMPAIGN NOTIFICATION
Recall campaign notification (xls, 31 KB)Implementation of a vehicle recall campaign under assignment
If the implementation of a recall campaign is entrusted to another economic operator, the assignment must be evidenced by a valid power of attorney, from which the validity of the authorization can be verified. The authorization may be granted either for an indefinite period or for a fixed term.
Instructions for recall campaigns
- Step 1
Find out which vehicles are affected by the recall cam-paign
Request from the manufacturer a list of the vehicle identification numbers (VINs) of all vehicles worldwide that are included in the recall campaign.
- Step 2
Find out whether there are any vehicles in Finland that are affected by the recall campaign
Check the economic operator’s databases or the Transport Register to determine whether there are vehicles covered by the recall campaign in Finland.
If no vehicles covered by the recall campaign are found in the economic operator’s own databases, contact Traficom’s contracted direct marketing service provider Ulkoinen verkkopalvelu. to determine whether any such vehicles are registered in the Finnish Transport Register. If vehicles are found in the Finnish Transport Register, proceed to the next step. If no vehicles are found in the Finnish Transport Register, there is no need to initiate the recall campaign.
- Step 3
Inform Traficom about the campaign
Inform Traficom of the initiation of the recall campaign using the Excel notification form above. The Excel form must be submitted via Traficom’s e-services Ulkoinen verkkopalvelu..
- Step 4
Send the recall notice
Send the recall notice to the vehicle user by letter or by electronic means of communication.
If the recall is to be sent by letter, before dispatching the recall letters, obtain information on all vehicles covered by the recall campaign that are registered in the Finnish Transport Register from Traficom’s contractual partner providing direct marketing services. The contractual partner must be clearly informed that the matter concerns a statutory recall campaign, as this affects the disclosure of address information from the Transport Register. Send the direct marketing service provider’s contractual partner a list of the vehicles subject to the corrective action. Based on the list provided, the contractual partner offering direct marketing services will retrieve the addresses of the owners and keepers of all vehicles registered in the Finnish Transport Register. The recall letter must comply with the model set out in (EU) 2024/1435 Ulkoinen verkkopalvelu.. Editable recall letter template Ulkoinen verkkopalvelu.. During the data extraction process, Traficom is notified of vehicles whose users have a non-disclosure for personal safety. Traficom will send the repair recall directly to those users and will not disclose the personal data of individuals subject to such protection to third parties.
If the recall is sent by electronic means of communication, identify the vehicles covered by the recall campaign from the relevant databases before sending the recall notice. For recalls sent by electronic means of communication, the template in regulation (EU) 2024/1435 must be used. The template format in (EU) 2024/1435 may only be deviated from where its use is not possible due to the limitations of the communication method; however, the information requirements of the template cannot be deviated from. When a recall is carried out by electronic means of communication, efforts must be made to ensure that the recall notice is sent to the current user of the vehicle. Before issuing the final recall notice, the economic operator may also send the vehicle user a recall notice in accordance with paragraph 4.
- Step 5
Last recall
The last recall must be sent by letter if not all vehicles have been repaired within a reasonable time. A period exceeding three years cannot be considered reasonable (Government proposal 177/2020).
Request from Traficom the attachment and reference number to be included in the recall letter. Send the attachment and the reference number to be included in it via Traficom’s e-services. Ulkoinen verkkopalvelu.
Before sending the final recall letter, obtain information on all vehicles registered in the Finnish Transport Register from Traficom’s contractual partner providing direct marketing services. Send the contractual partner providing direct marketing services a list of the vehicles for which the corrective action has not yet been completed. Based on the list provided, the contractual partner offering direct marketing services will retrieve the addresses of the owners and keepers of all vehicles registered in the Finnish Transport Register. Vehicles that have been individually imported shall also be included in the gathering.
Clearly inform the contractual partner that the matter concerns a statutory recall campaign, as this affects the address information that may be disclosed from the Finnish Transport Register. During the data extraction process, Traficom is notified of vehicles whose users have a non-disclosure for personal safety. Traficom will send the repair recall directly to those users and will not disclose the personal data of individuals subject to such protection to third parties.
Send the recall letter, together with Traficom’s attachment, to the vehicle user. The recall letter must comply with the template set out in the Regulation. Editable template Ulkoinen verkkopalvelu..
Ending a recall campaign if all vehicles have been repaired:
- Step 1
Notify Traficom of the completion of the recall campaign
Submit a notification to Traficom when all vehicles have been repaired and that the recall campaign has been completed. The notification must be submitted via Traficom’s e-services Ulkoinen verkkopalvelu.. Based on the notification, Traficom will record an end date for the campaign.
Ending a recall campaign when not all vehicles have been repaired:
- Step 1
Submit a list of unrepaired vehicles to Traficom
Submit a list of unrepaired vehicles to Traficom via Traficom’s e-services Ulkoinen verkkopalvelu. nine weeks after the final recall letter has been sent. Traficom will add a restriction entry for the unrepaired vehicles in the Transport Register and record the campaign’s end date.
The restriction entry will result in a rejection at the next periodic, registration or control inspection. The restriction entry is made pursuant to section 178 of the Vehicles Act (82/2021).
- Step 2
Removal of the restriction entry
The manufacturer's representative or an authorised brand shall prepare a statement on the corrective action carried out under the recall campaign. The statement shall be submitted at the next vehicle inspection, upon which the restriction entry shall be removed and the vehicle approved at inspection. For vehicles not subject to periodic inspection, the restriction entry is also removed at an inspection station.
The public nature of recall campaigns
Information on recall campaigns is public. Traficom maintains a database of recall campaigns Ulkoinen verkkopalvelu., which is updated regularly based on notifications submitted by manufacturers and their representatives.