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Thought Leadership

UK Government Launches Consultation on the Product Safety Framework

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The UK Government has launched a major consultation on the future of product safety regulation. The consultation is formed in two parts:

  1. The proposed new product safety framework, which you can respond to here; and
  2. The market surveillance and enforcement aspects of the proposed new framework, which you can respond to here.

The consultation is seeking input from businesses, consumer groups and any interested stakeholders in product safety regulation. It is open until 11.59 on 23 June 2026.

This represents the next step in the modernisation of a framework currently governed by the General Product Safety Regulations 2005 (“GPSR”), which many see as no longer fit for today’s products, supply chains and online markets. For businesses involved in manufacturing, importing, distributing or selling products in Great Britain, the consultation provides important insight into the direction of regulation, and offers an opportunity to contribute to it.

Background – the Product Safety Review and PRAM

In 2023 the Department for Business and Trade and the Office for Product Safety and Standards (“OPSS”) conducted the Product Safety Review. That review identified significant gaps in the existing regime:

  • The GPSR is not sufficiently flexible to rapidly respond to emerging products and related risks, such as emerging technologies;
  • There needs to be clearer and greater regulation of online marketplaces to match that of brick-and-mortar stores. Under the GPSR many unsafe and non-compliant products can be easily sold online;
  • The current framework does not respond well to complex modern supply chains, in that roles such as fulfilment service providers and other intermediaries are not captured by regulatory obligations; and
  • There is a growing divergence between the EU and Great Britain’s frameworks, creating complexity for businesses to navigate, which in turn increases the cost of compliance and threatens innovation.

In response, Parliament passed the Product Regulation and Metrology Act 2025 (“PRAM”), which granted the Government powers to introduce new product safety rules through secondary legislation. 

The EU framework – and why it matters

A key driver for reform is the growing mismatch between the EU’s General Product Safety Regulation and the GPSR.

The EU GPSR, which became applicable in December 2024, significantly expands the scope of product safety regulation. It expressly covers online marketplaces, imposes obligations on a wider group of “economic operators” (including fulfilment service providers), and addresses modern risks such as cybersecurity and digital product information. It also aims to ensure that products sold online are subject to the same safety expectations as those sold offline. 

By contrast, Great Britain is not bound by the EU GPSR and currently lacks equivalent, up‑to‑date provisions in several of these areas. The Government has acknowledged that this divergence risks leaving regulatory gaps, particularly for products sold via online channels and complex international supply chains, and for businesses operating across Great Britain and Northern Ireland. 

Overview of the consultation

The consultation, published on 31 March 2026, seeks views from businesses, trade bodies, consumer organisations and other stakeholders. It runs alongside the companion consultation on enforcement and market surveillance aspects of the proposed regime.

The product safety framework consultation sets out four proposal groups, covering:

  1. The scope of the new framework and how it can be modernised;
  2. The core safety duties that should apply across supply chains;
  3. How safety should be assessed and communicated, including product information and warnings; and
  4. How product safety should be enforced, including the powers which should be given to regulators to identify and prevent unsafe products. 

The Government is clear that responses will inform secondary legislation made under PRAM, rather than immediate changes to the law.  

What this could mean in practice for businesses

Although the consultation does not set final rules, several practical implications are already apparent.

  1. First, duties are likely to increase and broaden, with clearer and more explicit obligations applying to a wider range of supply‑chain participants, not just manufacturers. Businesses that currently see themselves as “intermediaries” may find themselves directly in scope;
  2. Secondly, online marketplaces are firmly in focus. The Government has signalled that platforms controlling access to online sales environments will be expected to play an active role in product safety;
  3. Thirdly, the framework is likely to be more risk‑based, taking account of specific safety risks (for example, lithium batteries, connected products or cybersecurity vulnerabilities) rather than relying on traditional product categories; and
  4. Finally, while the UK is not simply copying the EU regime, the proposals strongly suggest that elements of the EU GPSR will be used as a reference point. For businesses operating across both Great Britain and EU markets, this may offer some welcome convergence, but it will still require careful analysis of where regimes align, and where they do not.

If you would like to discuss the implications of any matters discussed in this article, please contact Brian Wong or Jemimah Lack.

We live in a world vastly different from the turn of the century, and the way people buy products has evolved. There are simply too many instances of dangerous products being sold to UK consumers, often online, resulting in serious harm.

https://www.gov.uk/government/consultations/product-regulation-the-uks-new-product-safety-framework

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