> 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 :)

I do not believe that any corporate lawyer would think that. It does not read like that in neither plain english nor legalese.

Maybe the misunderstanding stems from the related common misuse of "as soon as possible" as "immediately"?

A corporate lawyer would, however, always suggest to minimize/reduce/delay any legal obligations so as to minimize risk of liability, regardless of whether said obligation is easy to comply with or not.