Product

Horizon scanning

Product Regulation and Metrology Bill (PRAM) – the biggest change to UK product safety regulation in 40 years

What is happening?
On 17 July 2024, the Product Regulation and Metrology Bill (the Bill) was announced as part of the King's Speech. The Bill is an enabling act which is likely to be passed in Spring 2025, with the key secondary legislation which will contain the substantive regulatory change, likely to start coming into force in Autumn 2025.

The focus of the legislation will be to overhaul the regulation of product safety in the UK and bring it into the 21st century, allowing it to deal with ever-changing supply chains and technological advances in products.

The Bill is seen, by regulators, as a pivotal moment in regulation of product safety and an opportunity to bring about significant change for the first time in 40 years.

The Bill will impact regulators and businesses, especially those who operate online marketplaces, manufacture lithium-ion batteries or products that contain Artificial Intelligence (AI).

Why does it matter?

The significance of the Bill is that it will potentially lead to a deluge of secondary legislation which will change the regulation of product safety. The Bill allows the UK to adopt EU standards on product safety whilst maintaining flexibility to deviate from EU regulations when it is in the interests of UK businesses and/or consumers. This will potentially allow the UK to keep pace with the EU, which has a significant head start in terms of changes to product regulation with the implementation of the Product Liability Directive

and the General Product Safety Regulations, which came into force on 13 December 2024.

It will also be interesting to watch how the tension between the UK's desire to harmonise with the EU on certain issues, whilst protecting the interests of UK businesses and consumers, unfolds as secondary legislation is implemented.

The main aims of the Bill and its secondary legislation will be to:

ensure regulators are suitably able to challenge new and emerging business models, including online marketplaces
enable improvements to compliance and enforcement
enable legislation to adapt to new technology, such as AI, in a more efficient manner.

Justin Madders MP, who is responsible for the Bill, said that the legislation will "allow for agile and robust regulatory measures for products….placed on the UK market."

Without further resourcing, regulators will face challenges in enforcing the secondary legislation that comes into force. However, online marketplaces should take these changes seriously as it will likely have a significant impact on the way they operate and the relationships they have with their sellers.

“Online marketplaces should take these changes seriously as it will likely have a significant impact on the way they operate.”

What actions should you take?
Businesses and regulators will need to closely monitor the secondary legislation that follows from the Bill which could cover a number of different issues including (but not limited to) online marketplaces, AI and products that use lithium-ion batteries.

The OPSS have indicated an interest in opening a dialogue with online marketplaces who may wish to engage in discussions to assist with their understanding on how any secondary legislation will impact their business models and responsibility for product safety in the future.

Key dates

Spring and Autumn 2025

Gavin Reese
Partner
+44 7802 961815
gavin.reese@rpclegal.com

Andrew Martin
Associate
+44 7849 310904
andrew.martin@rpclegal.com