[co-author: Srishti Chhajer]
The UK's product safety and liability regime is undergoing its most significant transformation in decades, with the UK Product Regulation and Metrology Act coming into force and the Law Commission launching a review of the UK's product liability framework.
On 21 July 2025, the UK Product Regulation and Metrology Act received Royal Assent, creating a flexible, domestic framework designed to respond quickly to technological change and market needs. This legislation gives the UK Government a powerful tool to adopt select aspects of the EU's expanding product regulation framework but only where it is considered in the best interests of UK businesses and consumers.
Just weeks later, on 31 July 2025, the Law Commission launched a full-scale review of the UK's product liability regime, the first since the Consumer Protection Act 1987. The review comes at a time when the EU's new Product Liability Directive (EU) 2024/2853 has already entered into force on 9 December 2024. EU member states now have until 9 December 2026 to implement the directive into their national laws, after which the new rules will apply to products placed on the market or put into service. The UK is not bound by this regime post-Brexit, but the timing adds weight to calls for the UK to modernise its own framework.
Taken together, these reforms are far more than procedural adjustments. They demonstrate the Government's appetite to modernise and strategically reset the UK's regulatory landscape, with significant implications for every business involved in designing, manufacturing, importing, distributing, or selling products in the UK.
Product Liability Review – outdated laws, modern risks
The Consumer Protection Act 1987 was written in an era before AI-driven devices, complex global supply chains, and digital products. The Law Commission has noted that the current framework has “not kept pace” with developments and is increasingly ill-suited to addressing issues such as software defects, embedded AI decision-making, and cybersecurity vulnerabilities.
The review aims to ensure the liability regime keeps pace with innovation, clarifying how the law applies to digital products, strengthening consumer access to redress, and balancing safety obligations with space for product innovation. While the Law Commission has not yet detailed the exact scope or nature of the review, it is expected to begin later this year, with a consultation paper following stakeholder engagement.
The UK Product Regulation and Metrology Act — a new agile domestic framework
The Product Regulation and Metrology Act gives the Government sweeping powers to regulate the safety, performance, and measurement accuracy of products placed on the UK market. While the Act itself does not make immediate substantive changes, it creates a streamlined legislative framework that will allow the Government to bring forward secondary legislation more quickly. The true impact of the Act will only become clear once this secondary legislation is drafted and implemented.
Designed for adaptability, the Act moves away from fixed, static rules in favour of a responsive, targeted regulatory model. Its scope covers the full product lifecycle (from design and production, through marketing and use, to resale, recycling, and disposal) ensuring that regulatory oversight is a continuous obligation, not just a one-off hurdle at market entry.
The Act applies to risks affecting human health, domestic animals, property, and even electromagnetic disturbance. It empowers ministers to set technical standards, update conformity assessment and traceability requirements, and modernise enforcement tools and penalties.
A notable feature is the creation of a framework to align UK rules with EU product-related laws when it is in the UK's interests to do so. The Government has been quick to dismiss suggestions that this represents a “backdoor” to EU membership, framing it instead as a pragmatic tool to adopt beneficial EU approaches while retaining full discretion.
Government’s stated priorities for secondary regulation: what to expect
The Department for Business and Trade has outlined its focus areas for future regulations under the Act. These include:
- Digital labelling to replace or supplement physical labels, allowing product safety and compliance information to be provided via QR codes or online.
- Strengthened market surveillance and enforcement, including improved information-sharing between regulators and expanded civil and criminal sanctions.
- Addressing emerging technological risks, such as AI safety, automation, advanced manufacturing methods, and cybersecurity vulnerabilities.
- Introducing a proportionate regulatory framework for online marketplaces and other new business models in the supply chain.
While the Act allows for UK-specific standards, its built-in flexibility to align with international, and particularly EU, standards will be critical for businesses trading across the UK, EU, and Northern Ireland under the Windsor Framework.
The road ahead
The combination of the Product Regulation and Metrology Act and the Law Commission's product liability review represents a rare moment of coordinated reform. The two initiatives are interconnected: the Law Commission's recommendations could directly influence how the Government uses its new powers, potentially accelerating the pace of regulatory change.
For businesses, the direction of travel is clear: product compliance in the UK is set to become more proactive, more technologically attuned, and more demanding of supply chain transparency. Businesses should monitor developments closely and engage in the Law Commission's review to ensure their interests are represented.
Those who invest early in digital compliance tools, enhanced traceability systems, and cross-border regulatory alignment will not only stay ahead of the curve but may find opportunities in shaping and thriving under the UK's next-generation product safety and liability regime.
The groundwork is being laid now. Forward-thinking businesses should see this as a moment to prepare — and to lead.
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