Product Regulation and Metrology Act 2025: Scope, Key Themes and Future Outlook

On 21 July 2025, the Product Regulation and Metrology Act 2025 (the “Act”) received Royal Assent, marking a significant legislative milestone in the UK’s post-Brexit regulatory landscape. The Act has the ultimate aim of establishing a new legal framework for regulating the marketing and use of products in the UK, as well as rules around units of measurement and product quantities. Following Royal Assent, the Department for Business and Trade (“DBT”) described the Act as a significant step towards enhancing safety standards across online marketplaces and strengthening protections for the public against unsafe or dangerous products.

Fundamentally, the main function of the Act comes in empowering the Secretary of State to make secondary legislation aimed at establishing product safety requirements, which will require parliamentary approval. Therefore, this is an “enabling” piece of legislation rather than a prescriptive framework at this stage.

Scope and Coverage

The Act applies broadly to the majority of consumer products placed on the UK market, including everyday goods such as toys, cosmetics, and industrial equipment. Crucially, the Act also extends its reach to the digital dimension of products; explicitly recognising intangible components such as software within its framework. This means that product requirements can now apply not only to physical characteristics and components, but also to digital elements embedded in or associated with a product. 

Accordingly, this marks a significant shift in UK product safety law, particularly for businesses involved in software development, digital-physical manufacturing, or operating online marketplaces. Businesses involved in these sectors must now prepare for a more complex regulatory environment, where compliance obligations may vary between UK and EU markets, and where digital features are subject to the same scrutiny as physical components. The Act sits alongside other emerging legislation, such as the recently enacted Data Use and Access Act (which we outline here), which further signals the UK’s intent to modernise its approach to digital governance, transparency, and consumer protection. 

Enhanced Consumer Safety and Digital Innovation

While the full detail of the Act will be revealed through secondary legislation, it establishes a number of key foundational elements aimed at strengthening consumer protection. 

To guide the responsible use of the new powers given to the Secretary of State, the Government has issued a Code of Conduct for policy makers, which outlines key principles for developing future regulations. These include:

• proportionality, ensuring that rules are appropriate to the level of risk; 
• evidence-based policy, requiring decisions to be grounded in data and stakeholder input; and 
• transparency and accountability, mandating clear engagement with affected parties. 

The Code of Conduct also signals the UK’s intent to modernise its product safety framework in line with technological advancements and changing consumer expectations, as well as to keep consumer safety at the heart of regulatory reform. A key area of reform is the exploration of digital labelling, which could allow product information, such as safety warnings, compliance data, and environmental impact details, to be delivered electronically. This innovation has the potential to reduce packaging waste and enable more dynamic and relevant communication with consumers, particularly in online retail environments.

Beyond digital labelling, the Code outlines broader reforms aimed at making the regulatory system more agile and innovation-friendly, whilst protecting consumer interests and preventing the sale of dangerous products. This is particularly critical in the context of online marketplaces, where product origin and safety can be difficult to verify. In a press release, the DBT confirmed its intention to introduce new responsibilities for these platforms, including obligations to:

• prevent unsafe products from being made available to consumers
• ensure that sellers operating on their platform comply with product safety obligations
• provide relevant information to consumers;
• and cooperate closely with regulators. 

These measures are especially relevant given the rise in safety incidents involving e-bikes and lithium-ion batteries. According to the DBT’s press release, the Office for Product Safety and Standards (“OPSS”) received reports of 211 fires involving e-bikes and e-scooters in 2024, averaging nearly one incident every 1.7 days. The London Fire Brigade accounted for the majority of these reports, with many incidents traced back to unsafe lithium-ion batteries purchased through online marketplaces, highlighting the urgent need for stronger oversight and accountability in the e-mobility and digital retail sectors. As a result, the e-mobility and battery sectors can expect detailed regulatory attention under the new framework.

EU Alignment and Divergence

It is important to understand the origins of this legislative framework and the policy rationale driving its development. Historically, the UK’s product safety framework has been rooted in EU-derived legislation. However, since Brexit, the need to modernise this framework has grown more urgent as the EU continues to evolve its own regulatory standards. An example which illustrates this evolution is in the EU’s General Product Safety Regulation (“GPSR”), which came into force in December 2024. The GPSR replaces the previous directive and introduces a directly applicable, uniform framework across EU member states, with enhanced obligations for manufacturers, online marketplaces, and other economic operators, including stricter risk assessments, improved traceability, and stronger consumer protections.

The UK’s Product Regulation and Metrology Act 2025 reflects both a continuation of shared principles and suggests strategic divergence from the EU. It grants ministers the power to align with EU rules where appropriate, particularly in areas like environmental impact and digital safety, while retaining the flexibility to diverge. For UK businesses trading with the EU, this creates a more complex compliance landscape; potentially requiring separate safety documentation, risk assessments, and labelling when trading in both UK and EU markets.

Looking Forward

Much of the substantive impact of the Act will depend on the secondary legislation that follows. The powers granted to the Secretary of State under the Act are broad, but the specific product requirements, enforcement mechanisms, and compliance obligations will only become clear once these powers are exercised. 

However, for businesses with the appetite to get ahead of the curve, now is the time to begin preparing. A prudent step might be to assess the recent changes to the EU product safety regime, including the General Product Safety Regulation and the Product Liability Directive. While this is particularly relevant for UK businesses trading in the EU, which must already navigate dual compliance obligations, we anticipate that the UK’s product safety regime will likely mirror the EU regime in a number of areas. By anticipating likely areas of convergence or divergence, businesses can position themselves to respond strategically once UK secondary legislation is introduced.

We will continue to monitor the development of secondary legislation and provide updates as further details become available.

If you would like any further information or have any questions about the contents of this article, please contact Richard Hugo, Victoria McCarron or another member of our Commercial & Technology team.