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Freshfields Risk & Compliance

| 2 minute read

The UK’s Product Regulation and Metrology Act enters into force

The UK’s Product Regulation and Metrology Act (the Act) received Royal Assent on 21 July 2025, with the majority of the Act coming into force on the same day. On 22 July 2025, the Government also released an accompanying Code of Conduct, which provides some further detail on how it intends to use its new powers. 

Since our previous update, the legislation has undergone relatively minor changes as it has passed through the Parliamentary process. We describe these further below. But the Act, as enabling legislation, remains intentionally high-level, and we are now waiting for draft secondary legislation to be published that will confirm the approach that the UK will take to matters covered by the Act.

The Act is split into three broad sections:

  1. Product regulation (sections 1 to 4): These provide that the Secretary of State may introduce regulations to reduce or mitigate the risks presented by products, ensure that products operate efficiently or effectively, and ensure that products for weighing or measuring operate accurately. One notable change from the legislation as originally proposed is that installers of products are now expressly in scope. As noted previously, certain products are excluded from these powers – including food, medicines, medical devices and (a new addition) aircraft and aircraft components. 
  2. Metrology (sections 5 and 6): The metrology provisions enable the Secretary of State to standardise units of measurement and regulate the quantities in which products may or must be sold. 
  3. Supplementary provisions (sections 7 to 11): These address several matters, including the sharing of information by relevant authorities to oversee and enforce the provisions, consequential amendments to existing regulations, and (a new addition) matters relating to devolution. 

The press release accompanying the news that the Act had received Royal Assent confirms that a key area of focus for the upcoming secondary legislation will be online marketplaces. The Government has said it intends to introduce requirements for a “proportionate regulatory framework” for online marketplaces “at the earliest opportunity”, but no concrete timeline has been confirmed.  

Beyond this, Government ministers indicated in Parliamentary debates during the passage of the Act that they expect relatively few substantive changes to be introduced through the powers granted in the Act – “no more than half a dozen uses of the powers a year”. This may suggest that these powers will be used (at least at first) on a targeted and dynamic basis to address novel products and supply chains. However, the accompanying Code of Conduct, refers to an ambitious list of areas for potential reform or further review, including divergence from EU requirements, the regulation of higher risk product sectors, digital labelling and the introduction of civil monetary penalties in consumer product safety cases. 

Although the Act does not deal with the issue of product liability, Ministers have indicated that the Law Commission has been tasked with conducting a full and comprehensive review of product liability and will make suggestions for reform. The Commission’s report is expected at some point in 2026.

Given that much of the detail of the reforms will be contained in secondary legislation, it will be important for businesses covered by the proposals to monitor announcements closely and engage with future consultations on draft regulations. 

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brexit, consumer, consumer protection, product liability, regulatory, tech media and telecoms