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".
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".