nit: "without undue delay" does not mean "immediately" under any legal interpretation, only that the timeline should not be longer than necessary. This leaves a lot of wiggle-room in favor of the manufacturer, and mainly rules out that they go "eh, we'll look at all these in half a year maybe".
As long as they start the process and it is not absurd from an industry standards perspective, they should be good. They can have slow processes, including being a good bit slower than their peers, without running afoul of "without undue delay".
> nit: "without undue delay" does not mean "immediately" under any legal interpretation, only that the timeline should not be longer than necessary. This leaves a lot of wiggle-room in favor of the manufacturer, and mainly rules out that they go "eh, we'll look at all these in half a year maybe".
Well, the corporate lawyers think otherwise at those corporations, so I'm not sure how much your interpretation counts :)
They have literal 24 hour and 72 hour deadlines. Obviously, they might put a blind eye to it if you are reliable but delayed the reporting by a day, but the 24 hour and 72 hour deadlines are a fact. You have to initiate the reporting immediately.