August 7, 2025
The UK’s Product Regulation and Metrology Act 2025 received Royal Assent and became law on 21 July 2025. Although the Act will not immediately introduce substantive changes for product safety, it grants the UK government the powers to develop secondary legislation to address modern safety issues and technological developments.
One key area that will be addressed with secondary legislation is online marketplaces. The UK government seeks to hold online marketplaces accountable for dangerous products sold through their platforms and to create a level playing field with brick-and-mortar stores. This is part of a broader trend embraced by regulators in the EU through the General Product Safety Regulation (GPSR) and in the U.S., where responsibilities for online marketplaces have expanded.
Key details
One of the first targets for secondary legislation will be online marketplaces. The government intends to create a proportionate regulatory framework that requires online marketplaces to:
- Prevent unsafe products from being made available to consumers
- Ensure that sellers operating on their platform comply with product safety obligations
- Provide relevant product safety information to consumers
- Cooperate closely with regulators
The UK government identified several other areas for potential reform or further review. These include cross-cutting hazards, the regulation of higher-risk product sectors, the introduction of civil monetary penalties, whether to diverge from or mirror EU requirements, and technological changes such as automation of machinery, 3D printing, and augmented reality.
The Act’s application goes beyond just physical products to also include intangible components such as software. By government estimates, this change could expand the scope of secondary legislation to include approximately 300,000 UK businesses.
Since the Act is only enabling legislation, it will be several months before businesses face any new concrete requirements. The Secretary of State will need to gain parliamentary approval of any secondary legislation. As legal experts with Gowling WLG note, “This framework approach allows for responsive, targeted regulation that can adapt to emerging technologies and evolving safety challenges without requiring primary legislation for each new development.”
Any secondary legislation is likely to develop alongside other emerging regulatory frameworks, as well as with the UK’s pro-innovation approach to AI and other new technologies. For example, the UK government made multiple references to lithium-ion batteries in its press release about the Act, including pointing back to the statutory guidelines on lithium-ion battery safety for e-bikes that were introduced in December.
Looking ahead
The EU GPSR may serve as a blueprint for some of the secondary legislation introduced under the Act, particularly around new requirements for online marketplaces. However, the new measure leaves a pathway open for the UK government to diverge even further from EU product safety laws.
All UK companies, and those with operations or partnerships in the country, should closely follow developments related to the Act and its secondary legislation. The legal experts suggest that companies with software components in their products, who will be subject to the Act under the “intangible” definition, should evaluate potential exposure to new digital product safety requirements.
Additionally, businesses should review their supply chains agreements. The framework’s broad scope may affect supplier relationships and contractual arrangements, particularly for complex products with multiple components.
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