Product Safety, Regulatory and Liability Reform in the UK. The UK Product Regulation and Metrology Act and the Law Commission Review

2025 saw some significant changes in the UK’s Product Safety and Liability regime with the implementation of the UK Product Regulation and Metrology Act and the Law Commission’s launch of its full-scale review of the UK’s product liability regime.

Whilst these steps may seem to just concern procedural updates, taken together and when viewed next to the European Union’s new Product Liability Directive and General Product Safety Regulations, it is clear that there is strong intention within the UK for product legislation to be modernised. We discussed this renewed focus and the implications for businesses and insurers alike in this article.

The UK Product Regulation and Metrology Act

On 21 July 2025, the Product Regulation and Metrology Act received Royal Assent. It provides 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 empowers the Secretary of State to make future regulations (i.e. by way of secondary legislation). In addition, it creates the framework to align UK rules with EU product-related laws when it is in the UK's interests to do so.

Whilst 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, the true impact of the Act will only become clear once this secondary legislation is drafted and implemented.

The Law Commission’s launch of its full scale review of the UK’s product liability regime

Just weeks after the UK Product Regulation and Metrology Act received Royal Assent, the Law Commission launched a full scale review of the UK’s product Liability regime - Product liability – Law Commission. The objective of this review is to consider the operation of the existing product liability regime set out in the Consumer Protection Act 1987, particularly in relation to digital products and emerging technologies such as AI, to determine what law reform might be required to ensure that the product liability regime is fit for purpose. The deadline for stakeholders to return the initial scoping questionnaire expired on 31 December 2025 and the next stages will involve public consultation for reform in 2026.

The Consumer Protection Act 1987 has been in place for almost 40 years and it is no surprise that following the significant change being implemented by the European Union with the new Product Liability Directive, the UK is also reviewing and considering proposals for reform.

Whilst EU member states now have until 9 December 2026 to implement the new Product Liability directive into their national laws, the UK is not bound by this regime post-Brexit. Despite this, it is clear that the timing of the EU’s new directive has added strength to those calling for the UK to modernise its own product liability framework.

Product safety regulations and product liability legislation is undergoing a renewed focus within the UK and, whilst businesses in the UK may be breathing a sigh of relief that the UK has not followed the EU’s steps in amending legislation wholesale via the new Product Liability Directive, what we can see is that there is a strong appetite politically within the UK Government and the Law Commission to address product safety issues and to modernise and reset the UK’s regulatory and liability landscape in respect of products.

This renewed focus has implications for every business involved in manufacturing or supplying products and the UK and it is important that businesses stay in front of those changes and even contribute to those reviews to ensure that their interests are considered.

In the event that support is required for businesses with any aspect of this article or any issues arising from product safety or product liability claims more generally, please contact Clyde & Co's Product Liability, Safety and Recall Team led by Partners, Peter Barnes and Charlotte Kelly.