In subrogation cases where the insured’s damages were caused by a defective product, the fact that the product at issue is or was subject to a recall announced by the Consumer Product Safety Commission (CPSC) may help to establish that the product was defective when it left the manufacturer’s possession and control. On June 20, 2024, the CPSC announced the following recalls related to products that present fire hazards:

1. myCharge Recalls POWER HUB All-In-One Portable Chargers Due to Fire and Burn Hazards; Sold Exclusively at Costco. According to the CPSC’s website, “[t]he recalled portable chargers can overheat while charging, posing fire and burn hazards.”
2. Goal Zero Recalls Yeti Link Modules with EC8 Cables Due to Fire and Burn Hazards. According to the CPSC’s website, “[t]he connection between the Yeti Link Expansion modules and the cables can overheat and melt, posing fire and burn hazards.”
3. StyleCraft Recalls Instinct Cordless Hair Clippers Due to Fire and Burn Hazards. According to the CPSC’s website, “[t]he lithium-ion battery in the recalled clippers can overheat, posing fire and burn hazards.”
4. Orly Recalls Lavender Scented Candles in a Round Wooden Bread Bowl Due to Fire and Burn Hazards; Sold Exclusively at Cracker Barrel Old Country Store. According to the CPSC’s website, “[t]he candle’s flames can reach excessive heights and can ignite the bowl, posing fire and burn hazards.”