You still have me a bit confused. It's pretty much always the "manufacturer" who does recalls. In the case of an automobile, the "vendor" (car dealership), would be the one actually doing the repairs. (OK, in this scenario, "new", "used", or, "refurbished" are all out of context, moot points if you will, as the car is simply not going to be replaced).
AFAIK, "vendors" don't do recalls, they act as the agent of the manufacturer.
So, I can see new, never sold stock being exchanged by Samsung, having the batteries replaced, and returned to dealers as "new". (it is, after all, "new").
What I can't picture is a phone which has been in a customer's hands, exchanged, and then being sold as "new".