GRI 416 Customer Health & Safety

The two GRI 416 disclosures

416-1 Assessment of the health and safety impacts of product and service categories: The percentage of significant product and service categories for which health and safety impacts have been assessed for improvement. This is a coverage metric — how comprehensively have you assessed what risks your products pose to customers?

Assessment methods vary by sector: clinical trials and pharmacovigilance (pharmaceuticals); food safety hazard analysis and critical control points (HACCP) for food and beverage; toxicological testing and safety data sheets for chemicals; electromagnetic compatibility and electrical safety testing for electronics; and crash testing and safety certification for automotive.

The disclosure requires the percentage of categories assessed — not the results of those assessments. Companies with comprehensive product safety assessment programmes covering 100% of significant product categories can disclose accordingly, even if assessments have identified hazards requiring management.

416-2 Incidents of non-compliance concerning the health and safety impacts of products and services: Total number of incidents of non-compliance with regulations and/or voluntary codes concerning health and safety impacts of products and services. Broken down by: incidents of non-compliance with regulations resulting in a fine or penalty; incidents of non-compliance with regulations resulting in a warning; incidents of non-compliance with voluntary codes.

Product safety and ESRS S4

ESRS S4 (consumers and end-users) covers consumer impacts — including product safety as one of the material topics for companies with direct consumer relationships. GRI 416 and ESRS S4 cover overlapping ground.

GRI 416-1 assessment coverage maps to ESRS S4 policies and actions for product safety — demonstrating that safety assessment is systematic rather than reactive.

GRI 416-2 incidents of non-compliance map to ESRS S4 incidents disclosure — though ESRS S4 frames this more broadly as adverse impacts on consumers rather than specifically regulatory non-compliance.

For CSRD companies also using GRI: your ESRS S4 product safety disclosures provide the content for GRI 416. Extract from ESRS S4 and reformat for GRI — minimal duplication of effort.

Product recalls: Product recalls are one of the most significant product safety events — financially (recall costs, lost revenue, litigation) and reputationally. GRI 416-2 incidents of non-compliance typically include recalls where regulatory requirements were breached. ESRS S4 more broadly covers remediation of consumer harm — including voluntary recalls where no regulatory breach occurred.

Product safety management systems — the 416-1 foundation

A robust 416-1 disclosure requires that your product safety assessment approach is systematic — not just ad hoc testing of individual products when problems arise.

For food companies: HACCP (Hazard Analysis and Critical Control Points) is the global standard for food safety management. ISO 22000 and FSSC 22000 provide certification frameworks. HACCP coverage across all product categories provides the assessment foundation for GRI 416-1.

For pharmaceutical companies: GMP (Good Manufacturing Practice) compliance and pharmacovigilance systems for post-market surveillance provide the framework. Regulatory approval processes (EMA, FDA) involve comprehensive safety assessment as a prerequisite.

For consumer electronics: CE marking in the EU requires safety assessment against relevant standards. UL listing in the US provides equivalent certification. IEC standards provide the technical framework.

For chemical companies: REACH Registration includes chemical safety assessment — the registration dossier documents hazard and risk assessment for substances above 1 tonne/year. SDS (Safety Data Sheets) communicate safety information for hazardous substances.

For GRI 416-1 disclosure: calculate the percentage of significant product/service categories that have gone through a formal safety assessment process. 'Significant' categories are those with the highest revenue, widest distribution, or highest inherent risk — define significance criteria clearly and apply consistently.

Frequently asked questions