---
title: "EU GPSR incident and recall triage workflow"
canonical_url: "https://www.sorena.io/artifacts/eu/general-product-safety-regulation/incident-and-recall-triage-workflow"
source_url: "https://www.sorena.io/artifacts/eu/general-product-safety-regulation/incident-and-recall-triage-workflow"
author: "Sorena AI"
description: "A concrete EU GPSR workflow for product-safety incident intake, dangerous-product assessment, Safety Business Gateway notification, recall notices, marketplace coordination, and evidence records."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU General Product Safety Regulation"
  - "EU GPSR"
  - "Regulation (EU) 2023/988"
  - "Safety Business Gateway"
  - "product safety recall"
  - "dangerous product triage"
---
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---

# EU GPSR incident and recall triage workflow

A concrete EU GPSR workflow for product-safety incident intake, dangerous-product assessment, Safety Business Gateway notification, recall notices, marketplace coordination, and evidence records.

*Workflow* *EU*

## EU General Product Safety Regulation incident and recall triage workflow

Use this workflow when a complaint, test result, accident report, marketplace notice, authority contact, or supplier escalation suggests that a consumer product made available in the EU may be dangerous.

It keeps the triage focused on GPSR duties: incident intake, risk assessment, Safety Business Gateway notification, withdrawal or recall decisions, consumer communications, marketplace coordination, and evidence records.

EU GPSR incident and recall triage starts when the team receives safety information about a consumer product: an accident, complaint, test failure, marketplace report, supplier notice, authority request, or monitoring signal. The useful output is not a generic compliance memo; it is a case file showing what product is affected, who is the responsible economic operator or marketplace contact, whether the product is dangerous, what notification or corrective action was taken, what consumers were told, and what evidence supports each decision.

## 1. Intake the incident and lock the product identity

Open a case as soon as the signal alleges a safety issue, accident, or dangerous product. Record the product exactly as it is sold: name, brand, type, model, batch or serial number, barcode, packaging description, images, listing URL, marketplace offer identifier, countries where it was made available, and the economic operators in the supply chain.

Classify the notifier role before anyone submits through the Safety Business Gateway. GPSR accident and dangerous-product notifications are for the concerned economic operators and online marketplace providers; third-party submission is not the ordinary route. If an importer, distributor, fulfilment service provider, marketplace, or responsible person knows the facts before the manufacturer, the case file should show how the manufacturer or responsible person was informed.

- Create an intake record with the complaint, accident account, photos, test reports, order records, sales channels, and affected Member States.
- Identify whether the product is already with consumers, still only in the supply chain, or both; that distinction drives recall versus withdrawal planning.
- Preserve consumer-contact data, product registration data, and marketplace buyer data only for the safety purpose needed to contact affected consumers.

Sources for this answer:

- [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R0988-20230523&ref=sorena.io) - Supports intake records because GPSR requires product identification, complaint and accident investigation registers, recall and corrective-action records, and supply-chain notification when safety issues are identified.
- [European Commission Safety Business Gateway](https://webgate.ec.europa.eu/safety-business-gateway/?ref=sorena.io) - Explains that Safety Business Gateway submissions are reserved for the economic operators and online marketplace providers concerned by the notified product.

## 2. Decide whether the product is dangerous and what risk record is good enough

The triage owner should separate three questions: what is the defect or safety issue, how that defect can harm consumers, and what evidence supports the risk level. The Safety Business Gateway form expects a risk description, risk category, risk level, and any laboratory, visual test, certificate, or risk-assessment document available.

Do not block notification just because the team has not completed a formal risk assessment. The Safety Business Gateway manual states that determining the risk level is not required for notifying a dangerous product; if the notifier cannot assess the level, the form allows an Unknown risk level. Market surveillance authorities can reach a different conclusion from the notifier's grading.

- Attach the defect description, consumer-use scenario, injury or incident details, complaint pattern, test results, non-compliance evidence, and any standards or legal requirements used.
- Use the risk categories in the Gateway workflow, such as choking, electric shock, chemical risk, burns, or another relevant category, rather than broad labels like quality issue.
- Record whether the risk is Serious, High, Medium, Low, or Unknown, and why the selected level may change when authority feedback or new test evidence arrives.

Sources for this answer:

- [Commission Delegated Regulation (EU) 2024/3173 on Safety Gate risk assessment and notification requirements](https://data.europa.eu/eli/reg_del/2024/3173/oj?ref=sorena.io) - Provides the Safety Gate notification data model for risk descriptions, test evidence, risk assessment, incidents, corrective measures, product identity, and traceability information.
- [European Commission Safety Business Gateway](https://webgate.ec.europa.eu/safety-business-gateway/?ref=sorena.io) - Supports the dangerous-product and accident notification workflow and explains how business submissions can feed Safety Gate alerts.

## 3. Notify accidents and dangerous products through the Safety Business Gateway

If the case involves an accident caused by a product, Article 20 requires notification through the Safety Business Gateway without undue delay from when the manufacturer knows about the accident. The notification must include the product type, identification number, and accident circumstances if known; serious health effects, injuries, other bodily damage, illnesses, chronic health effects, or death are within the accident-notification rule.

If the case is a dangerous product rather than an accident, Articles 9, 11, 12, and 22 still drive Safety Business Gateway notifications by manufacturers, importers, distributors, responsible persons, and providers of online marketplaces according to their roles. The case owner should submit with the information available, then keep the Case ID, submission number, PDF copy, translation status, and later updates in the evidence record.

- Complete Gateway sections for the notifying economic operator or marketplace provider, product identity, accident or safety issue, risk assessment, and corrective actions already taken or planned.
- For accident cases, capture how the product was used, the injury or consequence, the date of the accident, and whether more than one person was affected.
- For incomplete cases, state missing information plainly and plan updates instead of waiting for every supply-chain document before submitting the core notification.

Sources for this answer:

- [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R0988-20230523&ref=sorena.io) - Article 20 is the source for accident notification through the Safety Business Gateway; Articles 9, 11, 12, and 22 support dangerous-product notifications by the relevant operators and marketplaces.
- [European Commission Safety Business Gateway](https://webgate.ec.europa.eu/safety-business-gateway/?ref=sorena.io) - Explains the business-facing Gateway for reporting dangerous products and accidents to Member State market surveillance authorities.

*Recommended next step*

*Placement: after workflow evidence section*

## Turn GPSR incident triage into an evidence-ready recall file

Use Sorena to structure product identity, risk evidence, Gateway submissions, corrective actions, recall notices, marketplace actions, and follow-up records in one cited workflow.

- [Open Research Copilot](/solutions/research-copilot.md): Answer EU GPSR scope, notification, and recall questions with cited outputs.
- [Talk through implementation](/contact.md): Review your incident intake, recall notice, marketplace process, and evidence model.

## 4. Choose withdrawal, recall, warning, or other corrective action

Once the product is treated as dangerous or potentially dangerous, assign a corrective-action owner and decide which measure reduces or eliminates the risk. GPSR distinguishes withdrawal, which prevents a product in the supply chain from being made available, from recall, which aims to achieve return of a product already made available to consumers.

A single case may need more than one action. For example, the team may withdraw unsold inventory, recall units already with consumers, warn consumers about safe use while replacement parts are prepared, and ask marketplaces to remove or disable offers. Keep each action separate with scope, duration, responsible company, start date if available, results, and the consumer-facing message.

- Use withdrawal when the affected stock is still in warehouses, shops, fulfilment centres, distributor channels, or marketplace listings and can be stopped before reaching consumers.
- Use recall when affected units have already reached consumers and return, repair, replacement, refund, or another Article 37 remedy is needed.
- Use safety warnings when consumers must receive information for safe use, including through direct notices and public channels where not all affected consumers can be identified.

Sources for this answer:

- [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R0988-20230523&ref=sorena.io) - Supports corrective-action decisions because manufacturers, importers, and distributors must take necessary measures including withdrawal or recall as appropriate and inform consumers and authorities.
- [European Commission Safety Business Gateway](https://webgate.ec.europa.eu/safety-business-gateway/?ref=sorena.io) - The Gateway corrective-action section distinguishes withdrawal from recall and asks notifiers to describe each action separately.

## 5. Draft the consumer notice without weakening the risk message

When recall information is provided in writing, GPSR Article 36 requires a recall notice that consumers can easily understand in the language of each Member State where the product was made available. The notice should help consumers identify the product, understand the hazard, stop using it, obtain the remedy, and contact the business for more information.

Avoid phrasing that lowers perceived risk. The GPSR and the recall-notice template warn against words such as voluntary, precautionary, discretionary, in rare situations, in specific situations, or statements that there have been no reported accidents. The notice should be accessible and, online, essential identification information shown in pictures should also be available as machine-readable text.

- Headline the notice Product safety recall and include product pictures, name, brand, batch or serial numbers, and where consumers can find identifiers on the product.
- State why the product is dangerous, what consumers should do immediately, the available remedy such as repair, replacement, or refund, and a free phone number or interactive online service.
- Publish through direct consumer contact where possible, then use wider channels such as the website, social media, newsletters, retail outlets, mass media, and marketplace interfaces when affected consumers cannot all be identified.

Sources for this answer:

- [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R0988-20230523&ref=sorena.io) - Articles 35 and 36 define direct consumer notification, public recall notices, recall-notice contents, accessibility, language, and risk wording requirements.
- [Commission Implementing Regulation (EU) 2024/1435 on the recall notice template](https://data.europa.eu/eli/reg_impl/2024/1435/oj?ref=sorena.io) - Establishes the GPSR recall notice template, including product identification, hazard, consumer action, remedy, and contact sections.

## 6. Coordinate marketplaces, authorities, and evidence updates

For online sales, involve marketplace contacts early. Providers of online marketplaces must register with the Safety Gate Portal, keep product-safety internal processes, process product-safety notices, cooperate with authorities and economic operators, publish recall information on their interfaces, directly notify affected consumers who bought through their interfaces, and report certain dangerous products or accidents through the Safety Business Gateway.

Close the triage only after evidence records show the product identity, risk rationale, notification status, corrective actions, consumer communications, marketplace actions, and follow-up updates. Safety Gate notification rules expect updates, modifications, or withdrawals of corrective measures to be notified, and the Gateway can relate a later submission to an earlier Case ID.

- Keep marketplace removal orders, trader notifications, buyer-notification proofs, listing URLs, unique offer identifiers, and evidence of recall publication on the marketplace interface.
- Keep Safety Business Gateway Case ID, submission number, submitted PDF, authority correspondence, missing-information log, related-case references, and any update submissions.
- Track recall effectiveness with return rates, consumer contacts, complaint and injury trends, marketplace response, supply-chain confirmations, and reasons for expanding, adjusting, restarting, or closing the action.

Sources for this answer:

- [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R0988-20230523&ref=sorena.io) - Article 22 supports marketplace coordination duties, including direct consumer notification, recall publication, cooperation, dangerous-product notification, accident cooperation, and supply-chain identification.
- [Commission Implementing Regulation (EU) 2024/1459 on the Safety Gate Portal interoperable interface](https://eur-lex.europa.eu/eli/reg_impl/2024/1459/oj?ref=sorena.io) - Supports marketplace monitoring workflows because registered marketplace providers may link their interfaces to Safety Gate Portal information already made publicly available.
- [Commission Delegated Regulation (EU) 2024/3173 on Safety Gate risk assessment and notification requirements](https://data.europa.eu/eli/reg_del/2024/3173/oj?ref=sorena.io) - Supports evidence updates because Safety Gate notifications include corrective measures, product identity, traceability information, reported accidents, and updates to measures.

## Primary sources

- [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R0988-20230523&ref=sorena.io) - Primary GPSR source for dangerous-product duties, accident notification, Safety Business Gateway reporting, marketplace coordination, direct consumer notice, recall notices, and evidence records.
  - Quote: "through the Safety Business Gateway"
- [European Commission Safety Business Gateway](https://webgate.ec.europa.eu/safety-business-gateway/?ref=sorena.io) - Commission source for business reporting of dangerous products and accidents, eligible submitters, downstream Safety Gate use, and recall notice expectations.
  - Quote: "report dangerous products and accidents"
- [Commission Delegated Regulation (EU) 2024/3173 on Safety Gate risk assessment and notification requirements](https://data.europa.eu/eli/reg_del/2024/3173/oj?ref=sorena.io) - Source for risk assessment criteria and Safety Gate notification fields covering risk descriptions, tests, incidents, corrective measures, product identification, and traceability.
  - Quote: "criteria for assessment of the level of risk"
- [Commission Implementing Regulation (EU) 2024/1435 on the recall notice template](https://data.europa.eu/eli/reg_impl/2024/1435/oj?ref=sorena.io) - Source for the GPSR product safety recall notice template and required consumer-facing sections.
  - Quote: "template for a recall notice"
- [Commission Implementing Regulation (EU) 2024/1459 on the Safety Gate Portal interoperable interface](https://eur-lex.europa.eu/eli/reg_impl/2024/1459/oj?ref=sorena.io) - Source for online marketplace access to the Safety Gate Portal interoperable interface and downloads of public Safety Gate Portal information.
  - Quote: "providers of online marketplaces"

## Related Topic Guides

- [EU GPSR Applicability Test for Consumer Products](/artifacts/eu/general-product-safety-regulation/applicability-test.md): Determine whether the EU General Product Safety Regulation applies to a product, sale channel, operator role, online listing, used product, or responsible-person setup.
- [EU GPSR Compliance Checklist](/artifacts/eu/general-product-safety-regulation/checklist.md): Concrete EU GPSR checklist for consumer product safety assessment, technical documentation, traceability, labels, online listings, accidents, recalls, and corrective actions.
- [EU GPSR compliance obligations](/artifacts/eu/general-product-safety-regulation/compliance.md): EU GPSR compliance guide covering safety assessment, technical documentation, responsible persons, traceability, marketplace listings, accident reporting, recalls, and evidence.
- [EU GPSR deadlines and compliance calendar](/artifacts/eu/general-product-safety-regulation/deadlines-and-compliance-calendar.md): Calendar of grounded EU GPSR timing duties: 13 December 2024 application, accident notices, marketplace takedowns, recall notices, remedies, and regular product-safety checks.
- [EU GPSR Economic Operator Duties](/artifacts/eu/general-product-safety-regulation/economic-operator-duties.md): Role-by-role GPSR duties for manufacturers, importers, distributors, EU responsible persons, traceability records, corrective action, accidents, recalls, and Safety Business Gateway escalation.
- [EU GPSR economic operator roles: manufacturer, importer, distributor](/artifacts/eu/general-product-safety-regulation/economic-operator-roles.md): Classify GPSR roles for consumer products and map manufacturer, importer, distributor, fulfilment provider, responsible person, and online marketplace duties to evidence.
- [EU GPSR FAQ: scope, listings, recalls, reporting](/artifacts/eu/general-product-safety-regulation/faq.md): FAQ on GPSR consumer-product scope, economic operator duties, EU responsible person, online marketplace listings, Safety Business Gateway reporting, recalls, and evidence.
- [EU GPSR Imported Products Guide](/artifacts/eu/general-product-safety-regulation/imported-products.md): GPSR importer guide covering EU responsible-person checks, traceability, technical documentation, online offers, dangerous-product action, recalls, and Safety Business Gateway reporting.
- [EU GPSR Marketplace Notice Handling](/artifacts/eu/general-product-safety-regulation/marketplace-notice-handling.md): How online marketplaces should handle GPSR authority orders, product-safety notices, Safety Gate checks, seller communications, evidence, and escalation.
- [EU GPSR Marketplace Notice Response Workflow](/artifacts/eu/general-product-safety-regulation/marketplace-notice-response-workflow.md): Concrete GPSR workflow for online marketplace product-safety notices, authority orders, takedowns, seller and consumer notification, Safety Gate Portal checks, and Safety Business Gateway evidence.
- [EU GPSR Online Listing Obligations](/artifacts/eu/general-product-safety-regulation/online-listing-obligations.md): GPSR online listing obligations for EU consumer-product offers: required product, manufacturer, responsible-person, warning, safety, traceability, and marketplace evidence fields.
- [EU GPSR online listing release workflow](/artifacts/eu/general-product-safety-regulation/online-listing-release-workflow.md): Release workflow for EU GPSR online product listings: product scope, responsible person details, warnings, traceability, safety evidence, marketplace checks, and monitoring.
- [EU GPSR Online Marketplace Obligations](/artifacts/eu/general-product-safety-regulation/online-marketplace-obligations.md): GPSR obligations for online marketplaces: contact points, Safety Gate registration, authority orders, product-safety notices, listing data, recall cooperation, accident notifications, and records.
- [EU GPSR penalties and enforcement exposure](/artifacts/eu/general-product-safety-regulation/penalties-and-fines.md): source-linked EU GPSR enforcement guide covering Member State penalties, market surveillance powers, corrective actions, marketplace orders, recalls, and evidence records.
- [EU GPSR Product Recall Notice Template](/artifacts/eu/general-product-safety-regulation/product-recall-notice-template.md): A GPSR recall notice template for EU consumer products, covering product identifiers, affected batches, risk wording, consumer actions, remedies, contact routes, channels, accessibility, and evidence records.
- [EU GPSR Product Safety Assessment Record](/artifacts/eu/general-product-safety-regulation/product-safety-assessment.md): Build a concrete GPSR product safety assessment covering product characteristics, foreseeable use, vulnerable consumers, warnings, standards, tests, incidents, risk level, corrective action, and documentation.
- [EU GPSR recall effectiveness evidence](/artifacts/eu/general-product-safety-regulation/recall-effectiveness.md): GPSR recall effectiveness guide for direct consumer notice, recall notice content, remedies, channel monitoring, marketplace cooperation, and Safety Gate evidence.
- [EU GPSR Recalls and Incident Management](/artifacts/eu/general-product-safety-regulation/recalls-and-incident-management.md): GPSR recall and incident management guide covering accident notification, Safety Business Gateway reporting, recall notices, consumer communication, marketplaces, and evidence records.
- [EU GPSR requirements for consumer products](/artifacts/eu/general-product-safety-regulation/requirements.md): Core EU GPSR requirements for consumer product safety: scope, risk assessment, operator duties, EU responsible person, traceability, online listings, marketplaces, accidents, recalls, Safety Gate, and evidence.
- [EU GPSR Risk Evaluation Criteria](/artifacts/eu/general-product-safety-regulation/risk-evaluation.md): GPSR risk evaluation criteria for consumer products: foreseeable use, vulnerable consumers, standards, warnings, serious risk signals, corrective action, and evidence.
- [EU GPSR safety assessment workflow](/artifacts/eu/general-product-safety-regulation/safety-assessment-workflow.md): A GPSR workflow for consumer product safety assessment: scope intake, hazards, standards, warnings, vulnerable users, documentation, incident triggers, recalls, and evidence.
- [EU GPSR Safety Gate and Safety Business Gateway](/artifacts/eu/general-product-safety-regulation/safety-gate-and-business-gateway.md): source-linked guide to GPSR Safety Gate public alerts, Safety Business Gateway submissions, accident reporting, marketplace duties, evidence fields, and notification timing.
- [EU GPSR Scope and Covered Products](/artifacts/eu/general-product-safety-regulation/scope-and-covered-products.md): Scope guide for Regulation (EU) 2023/988 covering consumer products, distance sales, used and reconditioned goods, exclusions, Union harmonisation overlap, and evidence to keep.
- [EU GPSR sector-law fallback and overlap](/artifacts/eu/general-product-safety-regulation/sector-law-fallback.md): How the EU GPSR applies when sector-specific Union product safety law also applies, including residual safety risks, online listings, recalls, evidence, and market surveillance.
- [EU GPSR Traceability and Documentation Records](/artifacts/eu/general-product-safety-regulation/traceability-and-documentation.md): source-linked GPSR record checklist for product identifiers, manufacturer and importer details, technical documentation, online offers, responsible person evidence, incidents, and recalls.
- [EU GPSR Traceability Records](/artifacts/eu/general-product-safety-regulation/traceability-records.md): Build GPSR traceability records for product identifiers, economic operators, online listings, safety evidence, incidents, recalls, and retention checks.
- [GPSR vs DSA marketplace duties for dangerous products](/artifacts/eu/general-product-safety-regulation/gpsr-vs-dsa-marketplaces.md): Compare GPSR marketplace duties with the DSA touchpoints referenced by GPSR Article 22 for product listings, takedown, recalls, incidents, and evidence.
- [GPSR vs LVD, EMC, and RED: overlap and fallback](/artifacts/eu/general-product-safety-regulation/gpsr-vs-lvd-emc-red-sector-rules.md): Compare GPSR fallback duties with LVD, EMC, and RED sector rules for consumer products, traceability, recalls, online marketplaces, and evidence records.
- [GPSR vs Market Surveillance Regulation: Article 4, controls, recalls](/artifacts/eu/general-product-safety-regulation/gpsr-vs-market-surveillance-regulation.md): Compare GPSR with Regulation (EU) 2019/1020 for responsible-person coverage, market-surveillance controls, evidence requests, unsafe products, recalls, and authority workflows.
- [GPSR vs Product Liability Directive](/artifacts/eu/general-product-safety-regulation/gpsr-vs-product-liability-directive.md): Compare GPSR preventive product-safety duties with EU product-liability exposure using grounded rules on recalls, warnings, traceability, accidents, and evidence.
- [How are dangerous product risk levels assessed under the EU GPSR?](/artifacts/eu/general-product-safety-regulation/faq/dangerous-product-risk-levels.md): FAQ on GPSR and Safety Gate dangerous-product risk levels: serious risk, evidence, corrective measures, recall, withdrawal, and notification records.
- [How does the GPSR apply to used or refurbished products? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/used-and-refurbished-products.md): FAQ on when used, repaired, reconditioned, or refurbished consumer products fall under the EU GPSR, including exclusions, operator duties, evidence, and online listings.
- [What GPSR information must appear in online Product Listings? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/product-listings.md): Direct EU GPSR FAQ answer on Article 19 online offer content: manufacturer details, EU responsible person, product identifiers, warnings, and listing evidence.
- [What must online marketplaces do when a GPSR product safety issue is reported? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/marketplace-takedowns.md): EU GPSR FAQ on marketplace takedown orders, product-safety notices, Safety Gate Portal checks, Safety Business Gateway reporting, and evidence records.
- [What should a GPSR recall notice include? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/recall-notices.md): What EU GPSR recall notices must tell consumers, how the EU model notice structures the message, and how Safety Business Gateway and Safety Gate evidence fits the recall record.
- [What should a GPSR safety evidence pack include? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/safety-evidence-packs.md): EU GPSR FAQ covering the records to keep for product risk assessment, technical documentation, traceability, tests, warnings, incidents, recalls, online listings, and marketplace operators.
- [When must businesses report GPSR product accidents? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/accident-notification.md): EU GPSR FAQ explaining accident notification triggers, who reports, Safety Business Gateway use, required information, evidence to keep, and timing without fixed day-count claims.
- [Which products does the EU GPSR cover? | General Product Safety Regulation FAQ](/artifacts/eu/general-product-safety-regulation/faq/covered-products.md): Direct EU GPSR FAQ on covered consumer products, exclusions, online offers, used and refurbished products, and how GPSR interacts with specific EU product-safety law.
- [Who is the GPSR Article 16 responsible person? | EU GPSR FAQ](/artifacts/eu/general-product-safety-regulation/faq/responsible-person.md): Direct FAQ answer on when the GPSR requires an EU-based responsible economic operator, which operator can fill the role, and what contact details must appear online.


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