Open consultation

The UK’s new product safety framework

Published 31 March 2026

Ministerial foreword

Many of us may not give a second thought to whether the products we buy – on our high street or online – are safe, but product safety matters to every individual and family across the UK. We rightly should be able to take for granted that the products in all our homes and workplaces are safe.

As we build upon the UK’s status as a global leader in innovation and harness the benefits of technology and free trade, our product safety regulations must keep pace to reflect the modern world and grasp new opportunities of the future.

We must build a regulatory system that works for British businesses, attracting investment, driving innovation and delivering growth.

But we have inherited a detailed and lengthy body of law, the complexity of which can hold back businesses – particularly the small and innovative businesses central to this government’s mission to deliver economic growth.

Today I am setting out this government’s vision for a necessary and long overdue upgrade to our product safety framework in the UK.

We will ensure consumers can rely on the products they buy and use being safe by bringing the protections for consumer safety up to date.

We will realise the great opportunities of new online supply chains without this being at the expense of our own high street shops and family businesses.

We will update the rules to reflect the modern world to give our businesses the certainty and clarity they need to grow.

And we will harness technology to give businesses and consumers new and better ways to give and receive product information.

The ambitious set of proposals in this consultation is the first, fundamental step in our comprehensive overhaul of product safety regulation to benefit both businesses and consumers.

It lays the groundwork for further simplification to sweep away unnecessary administrative burdens on businesses and help us meet our ambitious target to cut the administrative costs of regulation for business by 25% over this Parliament.

In doing so we will not only give people confidence in the products they buy and use, but we will enable innovation of the products of tomorrow and make the UK a more attractive place to bring safe, high-quality products to market.

Consultation information

This consultation seeks views on a package of reforms of the product safety framework including updated duties on businesses in the supply chain. The Department has issued a companion consultation document on the enforcement and market surveillance aspects of the framework, and they should be read together. The proposals and questions in this document are in the format ‘A1, A2’ etc. In the enforcement and market surveillance consultation document, they are in the format ‘B1, B2’ etc. Please ensure your answers reference the proposal and questions numbers with the correct letter and number.

Consultation details

Responsible body: Department for Business and Trade (DBT)

Issued: 31 March

Respond by: 23:59pm on 23 June

How to respond

You can respond to this consultation online.

You can read and respond to the enforcement and market surveillance consultation online.

We encourage responses to be made through this online platform to assist our analysis of the responses.

If you cannot respond online, you may send your response by email to: ProductSafetyReform@businessandtrade.gov.uk, using the response form on this page.

If you are responding in writing, please make clear which question each comment relates to.

Written responses can also be sent to:

Product Safety Policy Team
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London SW1A 2DY

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Quality assurance

This consultation has been carried out in accordance with the government’s consultation principles. If you have any complaints about the way this consultation has been conducted, email: enquiries@businessandtrade.gov.uk.

The existing landscape

The existing product safety framework needs an upgrade. The core framework is based on the General Product Safety Regulations 2005 (GPSR 2005), introduced two decades ago, and overlaid with specific regulations for certain product sectors. We live in a world which is vastly different from the turn of the century. Products that once were cutting-edge have long since been discarded or replaced, and the way people buy products has evolved. These regulations have been stretched to their limit.

While the existing product safety regulations work well to protect most people most of the time, there have simply been too many instances of dangerous products being sold to UK consumers, often online, resulting in serious harm. The list of hazardous products continues to grow and includes unsafe e-bike batteries, often used with non-compatible conversion kits and chargers that have resulted in fatal house fires, or products with ingestion hazards such as button batteries and small high-powered magnets that have tragically caused children serious injury and death.

The lack of clear responsibilities for all businesses in the online supply chain risks letting greater numbers of dangerous products reach consumers. It has also created a significant challenge for responsible businesses, who can be undercut by those – often based overseas – gaining an unfair advantage by illegally disregarding product safety compliance. This can be a particular barrier for small and medium-sized businesses, as recognised in ‘Backing your business: our plan for small and medium-sized businesses’. ^{[footnote 1]} The government therefore announced in the 2025 Budget our intention to level the playing field and to consult on using the powers in the Product Regulation and Metrology Act to introduce new requirements on online marketplaces. ^{[footnote 2]}

The rapid growth and evolution of e-commerce

The increase in e-commerce has transformed global supply chains and the way we purchase products. Online marketplaces, which facilitate online third-party sales to UK customers, have rapidly growing sales as a proportion of total retail sales. In March 2024, 25.4% of all UK retail sales occurred online, compared with just 10.8% ten years previously. ^{[footnote 3]}

Traditional retailers have also expanded into online marketplaces, such as Morrisons partnering with Amazon to sell groceries through Amazon’s store front, and B&Q launching their own online marketplace in March 2022. Social media companies have also embraced this new business model including Facebook Marketplace and TikTok Shop, encouraging consumers to buy products direct from feed videos.

We have also seen the emergence of new business types, such as drop-shippers delivering product orders to consumers through third-party procurement services that undertake activities such as stocking, fulfilling and sending products on behalf of the seller. Social media influencers have added to the online shopping environment through affiliate links to advertise sponsored products, such as via Amazon’s influencer programme. We are already seeing the growth of artificial intelligence-powered online shopping, such as Etsy’s partnership with ChatGPT.

We expect the diversity and market share of online marketplaces to continue to grow, with the way that UK consumers purchase products constantly evolving in ways we may not be able to predict. New online marketplace regulations will need to take account of this ever-changing landscape and reflect the complexity of different e-commerce business models in a way that is both effective and proportionate.

The challenges facing our product safety framework cause real harm to people and undermine businesses wanting to trade fairly. We want to reverse this, increase consumer confidence and remove barriers for responsible small and medium businesses to thrive. We cannot do this by staying stuck in the past, preventing new products being sold, closing our market to new ideas, and wishing away the new innovations that have such great potential to improve our lives. By putting in place a clear, simple and modernised core framework, we can improve protection for consumers and users of products and establish the fair markets that are vital to innovation and growth.

Our new vision

The need for a new framework was identified by the Product Safety Review ^{[footnote 4]} that began in 2019 and was endorsed by Parliament in passing the Product Regulation and Metrology Act (referred to as ‘the Act’ in this consultation) in July 2025.

We are already using the powers in the Act to update technical legislation, ^{[footnote 5]} but to deliver a significant step-change that will be felt by businesses and consumers alike we must reconsider the core product safety framework. In this consultation we are proposing a new, modernised and enhanced framework that gives people confidence that what they buy will be safe; thereby supporting growth and giving businesses incentives to invest by providing a level playing field, with clearer responsibilities and a more consistent and streamlined set of regulations. The proposals to streamline and modernise the enforcement regime ^{[footnote 6]} will have wider application beyond product safety to other forms of product regulation enforcement.

The new core product safety framework will require proactive action from everyone in the supply chain to protect consumers, will reflect modern products and supply chains, will capitalise on the opportunities new technology has provided for both businesses and consumers, and will support delivery of the government’s Regulatory Action Plan. ^{[footnote 7]} We have consulted widely on the issues the new framework needs to address, including through the Product Safety Review and during passage of the Act. The proposals for the new framework in this consultation reflect this engagement and consultation.

This consultation sets out our proposals for the new framework, grouped into the following themes.

• Getting the basics right: proposals for the new framework to cover a wider scope of products, updating how a safe product will be defined, and how the safety of a product can be assessed.
• Accountability throughout the supply chain: proposals for the definitions of businesses in scope of the new framework – producers, onward suppliers and online marketplaces – and their core obligations to proactively protect consumers from dangerous products.
• A new approach to product information: proposals to allow product information to be provided more flexibly – both physically and digitally – and to move towards a ‘digital by default’ approach to product information.
• Supporting enforcement activity: proposals for a consolidated set of duties to cooperate effectively with enforcement action.
• Building on the new foundations: proposals for additional tools to manage products posing greater risk of harm and paving the way for further reform of sector and product-specific regulations.

The complementary consultation on enforcement and market surveillance reform includes proposals to simplify and consolidate enforcement powers, introduce civil monetary penalties, and address the enforcement challenges posed by online and international supply chains. These consultations should be read together.

Our proposals will also support trade with the EU and globally, giving businesses more reason to invest and innovate, and will preserve the UK’s status as a global leader in product regulation. While we are conscious of many businesses’ desire to remain in step with our closest trading partners, they will be our own rules, made in the best interests of UK consumers and businesses.

Getting the comprehensive core framework right will bring immediate improvements to consumer safety and businesses. By covering a broader range of products and businesses than the existing regulations, it will also be crucial to enabling further improvements to the whole suite of product safety regulations. It will allow us to find ways to further streamline, enhance and consolidate the complex and overlapping rules that characterise the current regulatory landscape. We will continue to work with stakeholders to review sector-specific product safety regulations, seeking opportunities to:

• improve outcomes for consumers where current regulations have not kept pace with developments in products or supply chains
• remove unnecessary burdens on businesses to unleash innovation and growth
• streamline and consolidate the regulatory landscape, relying by default and where possible on the cross-cutting requirements of the new framework, only retaining or introducing product-specific rules where there is a need to do so
• support trade internationally, including with the EU, and reinforce our commitment to the UK internal market

We have already begun this work to review sector specific legislation through our call for evidence on machinery safety legislation ^{[footnote 8]} in July 2025 and made new regulations using powers in the Act to update the rules for noise emissions from equipment used outdoors ^{[footnote 9]} which come into force in April 2026.

To protect the UK internal market, the new framework will apply across the UK, taking account of the Windsor Framework. This approach will continue to facilitate Northern Ireland’s dual market access to both UK and EU markets today and into the future. Where EU product safety regulations apply, such as the recent EU General Product Safety Regulation, ^{[footnote 10]} parts of the new framework will apply in Great Britain in a complementary way. In collaboration with the Devolved Government in Northern Ireland, we will conduct an assessment of which provisions will apply across the UK before we legislate. We anticipate that the obligations on online marketplaces and the new enforcement powers will apply across the whole of the UK, ensuring that all consumers across the UK benefit from the new product safety framework.

Alongside the new regulatory framework, we will work with businesses, consumer groups, trade associations and others to develop detailed guidance to support compliance and help businesses make best use of the flexibility available to them. We do not believe that guidance should be forever set in stone once published. We will respond to feedback and consider the queries we receive to keep the guidance up-to-date and ensure it is a useful resource.

Getting the basics right

In this section we propose that a wider range of products should be covered by the new framework, how a safe product will be defined, and how the safety of a product can be assessed.

These proposals will protect consumers and other users from harm by:

• Ensuring all products have a baseline level of safety.
• Requiring a more holistic assessment of safety of a product, incentivising hazards and risks to be ‘designed out’ of products.
• The government giving clarity over standards that, if followed, we consider make a product safe, encouraging safer products to be placed on the market.

These proposals will support businesses by:

• Giving clarity over the baseline safety requirement for all products.
• Giving certainty about how to make a product safe through the government’s designation of standards.
• Providing a more comprehensive and explicit set of considerations for assessing safety, enabling businesses to avoid supplying dangerous products and avoid potentially costly product withdrawal or recalls.

Proposal A1: Ensuring all products are safe

We can think of products falling into two categories: consumer products ^{[footnote 11]} which are intended or likely to be used by individuals as consumers; and non-consumer products, which are those supplied to businesses or other organisations (including public and charitable organisations) for their own use, such as machinery or other products used in the workplace. In this consultation we refer to this second group as ‘business products’.

The existing GPSR 2005 and the EU’s General Product Safety Regulation in Northern Ireland cover consumer products, and some sector regulations apply to business products or both business and consumer products. To extend protections from unsafe products to all users, regardless of whether the product was purchased for use in the home or workplace, we propose the new framework will apply to all products, with some specific exceptions where we do not believe the framework should or could be applied, for example because they are out of scope of the Product Regulation and Metrology Act ^{[footnote 12]} or regulated by existing, distinct and targeted regimes. The proposed exceptions are:

• Certain agricultural, aquacultural, horticultural and related products:

  • animals (including fish), animal by-products and products of animal origin
  • animal feed
  • fertiliser
  • plants (including seeds), fruit, and fungi
  • plant protection products
• Food and (insofar as it relates to food safety) food contact materials such as packaging.
• Most aircraft, components of aircraft and products designed for operating or controlling aircraft.
• Military equipment.
• Medicines and medical devices.

Some of the products in scope of the new framework will be regulated by other product safety legislation, including sector-specific regulations such as those listed in the Office for Product Safety and Standards’ (OPSS) A-Z of product safety guidance ^{[footnote 13]} and the Ministry of Housing, Communities and Local Government’s proposed General Safety Requirement for construction products. ^{[footnote 14]} Where products are regulated by other product safety legislation with the same objective (such as where these product or sector specific regulations apply), the other legislation will take precedence over the new framework.

This broader and more comprehensive coverage will help to avoid products falling into the gaps between different sets of regulations, better protecting consumers and law-abiding businesses by reducing the scope for ‘grey areas’. By providing a consistent set of baseline requirements for safety, businesses can have greater confidence and certainty in their obligations, regardless of the product’s end user or type of product they are supplying. ^{[footnote 15]} This will also enable further simplification and streamlining of the product safety regulatory landscape through the sector reviews, as we will be able to rely on the framework to ensure the safety of the products.

We recognise that consumers and users of some products do not – and reasonably could not – expect them to meet the highest safety standards. Antique products, artworks and collectible items, by their very nature, should not be held to the same standards as other products. To facilitate the circular economy, we want to allow products that need to be refurbished or repaired to continue to circulate in the economy. We therefore propose the following exclusions from scope of the new regulations in addition to those set out above, based on the existing exemptions in GPSR 2005 and those that apply in Northern Ireland:

• Antiques and collectibles. Antiques are out of scope of GPSR 2005.
• Artworks.
• Products needing to be repaired, reconditioned or refurbished before use, if the consumer is explicitly informed of this. If the product is re-sold having been repaired, reconditioned or refurbished, it will be in scope. This is consistent with GPSR 2005.

Question A1: Do you agree or disagree with the proposed scope of the regulations, including the exemptions from scope?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A2: Defining a safe product

Across product safety legislation, what it means for a product to be safe is defined in different ways. In regulations for specific sectors, the product usually must comply with essential safety requirements. These requirements will determine what it means for the product to be safe. In the existing GPSR 2005, a safe product is defined without reference to product-specific essential safety requirements as it must cover a wide range of products. Rather, a safe product is:

A product which, under normal or reasonably foreseeable conditions of use including duration and, where applicable, putting into service, installation and maintenance requirements, does not present any risk or only the minimum risks compatible with the product’s use, considered to be acceptable and consistent with a high level of protection for the safety and health of persons. ^{[footnote 16]}

We propose retaining this definition of a safe product in the new framework and applying it to the broader set of products in scope. As is currently the case, the feasibility of obtaining higher levels of safety or the availability of other products with lower risk will not be grounds for considering a product to be dangerous.

While the existing GPSR 2005 only considers health and safety impacts on people, some sector regulations, including the Supply of Machinery (Safety) Regulations 2008, the Pyrotechnic Articles (Safety) Regulations 2015, and the Electrical Equipment (Safety) Regulations 2016 deal with additional risks such as to property, domestic animals or the environment.

For consistency of the definition of a safe consumer product across the UK and with the existing regulatory regime, we do not believe it would be appropriate to extend consideration of these additional risks to all products covered by the new framework. However, we want to ensure the framework in the future can deal appropriately with products where these risks are taken into account, or where the government decides in future they should be taken into account. We therefore propose that the risk of harm to property or domestic animals should be considered where:

• in relation to that product, we have designated a standard ^{[footnote 17]} which provides for the protection of property or domestic animals
• other product safety legislation requires a product to be safe in relation to property or domestic animals

Question A2: Do you agree or disagree with the proposed definition of a safe product?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A3: Updated safety considerations

When determining whether a product is safe, GPSR 2005 requires certain aspects of the product and its users to be considered:

• the characteristics of the product
• the effect of the product on other products, where relevant
• the presentation of the product
• the categories of consumers at risk, in particular children and the elderly

These aspects must be considered whenever a product’s safety is to be assessed, for example by the producer in complying with the general safety requirement, or relevant authorities ^{[footnote 18]} when assessing product compliance. However, these considerations have been outpaced by technological developments and changes in society’s expectations and understanding of safety.

We propose clarifying and updating the full set of considerations that must be taken into account when determining whether a product meets the definition of a safe product. These will only need to be considered where relevant to the product, so a simple and low-risk product will not require an extensive assessment by a producer to determine whether it is safe. This modernised framework will better respond to emerging risks posed by digital technologies, including AI-enabled and smart products, ensuring innovation does not come at the expense of consumer safety.

The EU also updated the considerations for assessing safety in its General Product Safety Regulation that came into force in December 2024. The new and emerging hazards and risks are shared challenges across the globe, and the experience of our closest trading partners and similar economies can be instructive. To ensure that as we update our regulations we enhance product safety, support businesses to continue trading between the UK and the EU, and allow the circulation of goods across the UK, we propose to broadly mirror the considerations for assessing safety in the new EU General Product Safety Regulation.

We therefore propose the considerations for assessing safety in the new framework should include:

• The hazards ^{[footnote 19]} in and risk posed by the product, and the opportunities to eliminate or mitigate them. This should include consideration of:

  • the characteristics and presentation of the product
  • the effect of the product on other products and vice versa
  • the types of consumers likely to be at risk, including children, the elderly or people with disabilities, and the impact of gender differences on health and safety
  • reasonable user expectations of safety
  • the state of the art and technology

Where relevant, the assessment of a product’s hazards and risks should also include:

• whether the product has the appearance of food and is therefore likely to be placed in the mouth, sucked or ingested
• whether the product is likely to be used by or appealing to children even if not intended for use by children
• cybersecurity risks and risks posed by artificial intelligence or machine learning functionality

Where applicable, the assessment should also include:

• relevant voluntary standards produced by the British Standards Institution (BSI), or European or international standards bodies
• relevant voluntary codes of practice

Responsible businesses will already be taking these factors into account under the existing regulatory framework. Bolstering and updating these considerations will support the level playing field our responsible businesses need to thrive by ensuring a more holistic assessment of product safety.

We recognise that different types of products may require different considerations when assessing their safety. There may be different expectations of safety for consumer products than business products. We believe that only mandating the consideration of the various factors of safety where relevant ensures the framework applies flexibly. The safety of a product with fewer inherent hazards which have a lower risk of harm will not require as comprehensive a consideration as one with more inherent hazards which pose greater risk of harm. To create a more comprehensive framework, we therefore intend not to differentiate between product types unless there is a clear reason to do so. We suggest that the considerations we are proposing are all adaptable enough to apply to any type of product which shares those hazards, risks or users.

To further support businesses and relevant authorities in understanding how to consider the safety of a product we will work with them to provide more extensive and detailed guidance. Where appropriate we will also work with trade associations to develop voluntary codes of practice which then must be considered if relevant, or with BSI to develop standards.

Question A3: Do you agree or disagree with the new list of considerations when assessing safety?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A4: Revoking the food imitating products regulations

Updating how the safety of a product is defined and assessed will allow us, over time and where appropriate, to move from product-based requirements to risk-based regulation. We intend to review all these regulations over the next three years, but we believe that we can already start the move towards risk-based regulation and propose to revoke the Food Imitations (Safety) Regulations 1989. We believe that the risks of harm associated with placing in the mouth, sucking or ingesting something that resembles food will be appropriately managed through the new framework without the need for bespoke regulations. The EU has repealed the equivalent EU law for food imitating products, so revoking these regulations will also ensure a consistent position across the UK.

Question A4: Do you agree or disagree with our proposal to revoke the Food Imitations (Safety) Regulations 1989?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A5: Proportionate safety requirements

To get the most benefit from the new framework, it will need to be adaptable to meet the requirements of a wide range of products. While the base framework should be effective in ensuring safety of the majority of products without the need for specific product-based rules, there may be products with greater hazards which we believe should be regulated in a different way. We may therefore decide that some products must meet specified essential safety requirements in addition to the general requirement for the product to be safe under the new framework.

Where the risk of harm is high if a hazardous product does not meet these essential safety requirements, we propose requiring that the product is subject to testing, or to third party conformity assessment of the product before it can be placed on the market. This could be applied in a flexible way for some products, such as is currently the case for toys, where self-certification is permitted if a designated standard is followed, otherwise conformity assessment is required. We may also designate standards that include testing requirements. This is how the existing sector regulations operate and while under the new framework we aim to reduce the need for detailed sector-specific requirements, we believe this is likely to continue to be an appropriate approach where warranted by the risks posed by particular products.

Question A5: Do you agree or disagree that essential safety requirements, testing or conformity assessment may be useful in the new framework?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A6: Using voluntary standards to support businesses

In the new framework, we will not legislate for prescriptive requirements to manage the risks posed by all products. This would inhibit innovation and would be an endless task. Instead, we intend to rely more on risk-based regulation and voluntary standards. The government supports the ‘single national standard model’ whereby the UK’s National Standards Body, BSI, will lead the development of, agree, and then adopt international standards as British Standards, withdrawing conflicting national standards to give a coherent national catalogue. These can help businesses design their products to meet safety, performance or other aims.

Under many UK product safety regulations, the Secretary of State can ‘designate’ voluntary standards or other technical specifications as giving the presumption that, if followed, the product meets one or more of the essential safety requirements in legislation. Designated standards are an integral part of the product safety regulatory landscape with around 3500 designated standards currently supporting regulatory compliance. Use of a designated standard remains voluntary.

We propose replicating the designated standard provision for the new framework to allow the government to give more specific indication to businesses on how they can make their products safe while retaining a flexible, industry-led approach to how this is achieved. While a designated standard would provide a presumption that a product is safe in relation to the risks covered by that standard, the product can still be assessed as being dangerous in light of the risks it poses.

The government will be able to designate a wider range of technical specifications adopted by recognised standardisation bodies, including ‘fast-track’ standards ^{[footnote 20]} to be designated, beyond what can currently be ‘referenced’ under the existing GPSR 2005. This will allow the government and industry to react more quickly to emerging risks and hazards as fast-track standards are developed and published more rapidly than formal standards. Once published they will be able to be designated, possibly as a temporary measure, without needing to wait for a full standard to be produced. This will give businesses clarity more quickly and help avoid harm to consumers and users. The government will also continue to play a central role in requesting or sponsoring the development of fast track and full standards for designation. Whether to follow the standard will remain the decision of the manufacturer, retaining full flexibility as well as giving greater clarity.

This proposal will enable the Government to designate technical specifications produced by UK, European or international standardisation organisations. ^{[footnote 21]} We are also considering whether the Secretary of State should be able to designate standards from another competent standardisation body where appropriate or beneficial for UK businesses and consumers. This could, for example, be where an appropriate national standard does not exist and is not available from the standardisation bodies listed above but is identified elsewhere.

Question A6: Do you agree or disagree with introducing the ‘designation’ mechanism for products covered by the framework?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A7: In what circumstances, if any, might it be appropriate to designate a standard from a competent standards body other than BSI, European standards bodies, or international standards bodies?

Response options: Free text box

Spotlight: Lithium-ion batteries and their use in consumer products

A growing range of consumer products are powered by lithium-ion batteries. For example, e-bikes can be sold as complete products or as conversion kits for pedal bikes. As replacement batteries, chargers or conversion kits can be hard to source on the high street, consumers may be encouraged to source dangerous alternatives for repairs, often bought from third party sellers online at lower cost. Non-compliant or incompatible battery components and the use of batteries outside of their safe design parameters can lead to thermal runaway, causing fires. While many high-profile instances have involved e-bikes, these are not the only products containing lithium-ion batteries with these risks. The proposals in this consultation to enhance the safety of all products should also help make products powered by lithium-ion batteries safer.

To further strengthen the safety framework for battery-powered mobility products, OPSS has commissioned BSI to develop a fast-track Publicly Available Specification (PAS) addressing the technical requirements for battery systems used in e-bikes, e-scooters, and conversion kits. This initiative is a direct response to the increasing prevalence of these products and the associated safety challenges identified in recent years. The primary objective of the PAS is to enhance the safety of battery systems by setting out clear guidance on the selection and installation of safe products, with particular attention to compatibility issues that may arise during repair or upgrade.

We anticipate that the PAS will be published by BSI in 2026. If we designate the PAS, businesses will be able to follow the recommendations set out in the PAS to demonstrate compliance with product safety regulations, supporting a level playing field for responsible suppliers and providing greater assurance to consumers.

OPSS is also engaging with fire and rescue services across the UK to improve the quality of the information it receives regarding e-bike and e-scooter fires. If this information indicates that a different regulatory or non-regulatory intervention may be required, we will consider whether to take further action.

Question A8: Are there any further actions you believe we should be taking to ensure lithium-ion batteries within consumer products are safe?

Response options: Free text box

Accountability throughout the supply chain

In this section we set out the businesses in scope of the new framework – producers, onward suppliers, and online marketplaces – and their core obligations to protect consumers from dangerous products.

These proposals will protect consumers and other users from harm by:

• Clarifying and specifying supply chain actors’ responsibilities to identify, prevent the listing of, and take corrective measures to protect consumers from dangerous products.
• Bringing online sales onto the same footing in relation to product safety as ‘bricks and mortar’ shops, with the added benefit of giving consumers greater confidence in the safety of the products they buy online.
• Requiring all businesses in the online supply chain, including online marketplaces and online sellers, to cooperate with enforcement action.

These proposals will support businesses by:

• Providing a level playing field for ‘bricks and mortar’ and UK-based online retailers compared to those based abroad
• Providing clarity to the new businesses in the supply chain of their roles and responsibilities
• Providing a consistent and clear set of responsibilities in relation to cooperation

Everyone in the supply chain has a proactive role to play in ensuring product safety – from the manufacturers and importers of products who should not put consumers or users at risk, to wholesalers, retailers, e-commerce businesses and fulfilment houses who should act with care to help prevent dangerous products reaching consumers and others. The current outdated regulations have provided insufficient clarity for online marketplaces as well as causing difficulties for relevant authorities taking action against overseas sellers and regulating the sheer volume of non-compliant products both online and entering at the border.

We propose that the new framework will place duties on three categories of supply chain actor: producers, onward suppliers and online marketplaces. These categories will make it clearer for businesses in the new ecosystem that has built up around online and international supply chains and help level the playing field for compliant businesses. These categories will not be mutually exclusive, and businesses may perform multiple supply chain roles dependent on their activities. This is why throughout the proposed framework we have sought to apply consistent or equivalent obligations to the three categories where appropriate, to ensure proportionality and minimal business burden.

Only safe products will be able to be sold online to UK buyers, whether the seller is based in the UK or overseas. Consumers who sell second-hand products are not generally in scope of these definitions. However, where consumers do so as part of a business or commercially, they will be in scope of these definitions and therefore in scope of the new framework.

The “producer” category will follow the precedent of the current GPSR 2005. We propose that this category includes:

• The manufacturer of a product including any other person presenting themselves as the manufacturer by affixing to the product their name, trademark or other distinctive mark, where this person is based in the UK.
• Where the manufacturer is not based in the UK, the manufacturer’s authorised representative established in the UK, if there is one.
• Where there is no manufacturer or authorised representative established in the UK, the importer of a product.
• Where there are none of the entities above, in the case of a distance sale of a product from outside the UK to a customer in the UK, the person making the offer to supply the product or to place it on the market (such as an overseas seller).
• Anyone else in the supply chain whose activities may change – or have contributed to a change in – the risk posed by the product, whether before or after the product has first been placed on the market. This would include someone who modifies a product either physically or digitally.

Our existing GPSR 2005 places obligations on distributors. This is a broad term, including any professional in the supply chain whose actions do not affect the safety of a product. ^{[footnote 22]} Product safety regulations that originate from the EU since they introduced their New Legislative Framework ^{[footnote 23]} (NLF) in 2008 take a different approach. The NLF is the basis for many of our sector regulations as they were introduced while the UK was a member of the EU. It is also the basis of the EU’s General Product Safety Regulation that applies in Northern Ireland which defines a distributor as someone in the supply chain other than the manufacturer or importer who makes a product available on the market. ^{[footnote 24]} It also defines a fulfilment service provider ^{[footnote 25]} as someone who does not have ownership of the product and offers at least two of the following services: warehousing, packaging, addressing and dispatching. This category excludes postal services. We consider these NLF categories to be included within the GPSR 2005 definition of a distributor.

We believe all intermediaries in the supply chain between the producer and the consumer or user have a role to play in product safety. Therefore, we propose retaining the current breadth of the GPSR 2005 distributor category and clarify that this includes fulfilment service providers. To avoid confusion with the categories that apply in Northern Ireland, we propose referring to a business in this category as an “onward supplier”. For consistency across the UK, a business that is a distributor or a fulfilment service provider in Northern Ireland will be an onward supplier under the new regulations in Great Britain.

We are also introducing the category of an “online marketplace”, as defined within the Product Regulation and Metrology Act 2025, and intend to place obligations on the businesses that operate these online services.

Our goals for meeting the challenge of the rise of e-commerce

We will modernise duties for online marketplaces, reflecting their level of control in the supply chain, and for online sellers. These obligations will be introduced in a flexible and proportionate way, informed by industry best practice, to account for the diverse range of existing and emerging business models. The requirements we are proposing to introduce are founded on four principal goals:

1. Safe products: Online marketplaces prevent non-compliant and unsafe products being made available on online marketplaces.
2. Safe sellers: Sellers operating on online marketplaces comply with product safety obligations.
3. Consumer information: Consumers and other customers buying online (including via online marketplaces) have appropriate information, instructions and warnings about products prior to purchase.
4. Cooperation duties: Online marketplaces cooperate with relevant authorities and provide ongoing assurance, including having arrangements to respond to requests and quickly remove known unsafe products from being made available.

The categories of onward suppliers and online marketplaces will capture a broad range of business models, each having different roles in the supply of or facilitating the supply of products. We expect to cover all these businesses in scope of the framework but will consider whether to apply obligations in different ways to different types of onward supplier or online marketplace by tailoring requirements to specific activities.

For example, if we introduce duties for online marketplaces to contact consumers during product recalls, this may only be appropriate or possible for online marketplaces that undertake the activity of facilitating the conclusion of distance contracts, meaning where a sale is agreed and concluded on the site. Similarly, we may only expect those onward suppliers who have a more integral role in the supply chain to undertake certain tasks to demonstrate due care, such as only expecting those who have possession of a product to undertake physical compliance checks.

Proposal A7: Preventing dangerous products reaching consumers

The primary purpose of the new framework will be to prevent consumers and other users encountering dangerous products. All the businesses in the supply chain we propose to define in the new framework – the producers, onward suppliers and online marketplaces – will have duties to proactively prevent the supply of dangerous products, tailored to their activities in the supply chain. Businesses and other organisations who purchase products for their own use, such as products for use in the workplace, will also receive protection under the new framework. While in some respects these differ from the duties that apply in Northern Ireland under the EU’s General Product Safety Regulation, the approach we propose is similar and will enable us to create a more coherent regulatory framework across the whole of the UK.

Producers

We propose replicating the core GPSR 2005 general safety requirement that producers are prohibited from supplying or offering to supply a product unless it is safe. It is for the producer to determine and assure themselves that the product is safe before supplying it, taking into account the definition of a safe product and the considerations in proposal 3. As is the case under the existing GPSR 2005, producers will be required, where reasonable and proportionate to the risks posed by the product, to conduct sample testing of the products they supply to ensure they are compliant. We will provide guidance to help businesses understand when sample testing may be reasonable and proportionate.

In case a product they supply is later alleged to have caused harm or where a hazard has been identified even if no harm has been caused, we also propose that producers must give consumers, users or those to whom they supply products a route to make complaints, and must investigate complaints from consumers, users or others they have supplied the product to, and keep a register of complaints and relevant corrective measures.

Producers will also have obligations to ensure products are appropriately labelled with additional information related to product safety. These obligations are covered in more detail in proposal A12.

Onward suppliers

In GPSR 2005, distributors must act with due care to ensure product safety and compliance. This is a flexible obligation that takes account of the level of intervention different businesses have in the supply chain. We propose to follow this precedent and require that onward suppliers who make a product available or act as a fulfilment service provider act with due care to ensure the products they supply are compliant, and not to supply a product that they know or should have known is dangerous. We expect onward suppliers to have a reasonable level of knowledge of the products they supply and the sorts of hazards and risks these products may pose, including both the acceptable level of risk for the product to be safe and common ways in which the product may have a level of risk that is likely to lead to it being a dangerous product. We would also expect onward suppliers to have processes in place to ensure they are taking due care and carefully considering the compliance of the products they supply.

The actions onward suppliers should take include, but would not be limited to, where relevant:

• Understanding the main hazards and risks involved in the products they supply and the mitigations that are required to make the product safe.
• Checking whether the product they supply is subject to a product safety alert, report or recall. ^{[footnote 26]}
• Where they have possession of the products, undertaking checks of the product to identify any hazards or risks.
• Requiring that a business that supplies them with the product also supplies all applicable safety information.
• Where relevant, transporting and storing the products in a way which ensures they remain compliant and undertaking proportionate checks of whether the product is safe before supplying it.

We do not propose to introduce these specific requirements in the new framework as actions that must be taken will depend on the nature of the products and the onward supplier’s activities. The types of actions we would expect onward suppliers to take will be set out in guidance. The greater the likelihood of the products being supplied being dangerous products (for example because of specific mitigations needed for them to represent an acceptable level of risk and be a safe product) or the more involved the onward supplier is in the supply of the product, in general the more they would be expected to do to demonstrate acting with due care.

Online marketplaces

It is also important that online marketplaces take a proactive approach to prevent non-compliant products being sold on their sites. A reactive approach that relies on relevant authorities to identify and report dangerous products to online marketplaces for them to remove is not sufficient to address the number of non-compliant products sold online or reflect online marketplaces’ influence on supply chains.

We propose that online marketplaces must act with due care to prevent, identify, and remove dangerous products being sold via their platforms. This would include products sold both by businesses (producers and onward suppliers) and by consumers in consumer-to-consumer sales. Steps that online marketplaces could take to comply with this duty include, but may not be limited to:

• Putting processes in place to proactively identify non-compliant products, including before they are made available to consumers, and taking action. This could include activities such as:

  • Conducting risk-based targeted monitoring of their platforms to identify products that are non-compliant, including checking for known dangerous products such as those subject to a product safety alert, report or recall.
  • Establishing a point of contact for customers to report safety concerns, to enable quicker identification of dangerous products. This data should be shared with relevant authorities to help with investigations.
• Putting in place processes to prevent non-compliant products being listed on their sites before they are made available to purchase by UK consumers.
• Developing a product safety plan that assures themselves and relevant authorities that they have implemented sufficient measures to be compliant.

Examples of non-compliant and unsafe products found for sale on online marketplaces

Carbon monoxide alarms

In England and Wales, approximately 40 deaths are reported each year due to carbon monoxide (CO) poisoning. ^{[footnote 27]} An article published by Which? in 2023 revealed that over 1,000 unbranded carbon monoxide (CO) alarms which failed to detect the deadly gas were listed by more than 100 different sellers on major online marketplaces. ^{[footnote 28]}

The investigation by Which? found that in every test of CO or smoke alarms since 2016, unbranded alarms made in China and sold through online marketplaces have repeatedly failed to sound when the gas was present. On the other hand, all the branded alarms tested were able to detect it, regardless of how much of it was in the air. Four major online marketplaces had a total of 149 listings for 5 different alarms that failed to work reliably. For instance, eBay recorded 1,311 sales across 42 different listings.

Toys

The British Toy and Hobby Association (BTHA) has undertaken testing on a range of toys from online marketplaces. Since 2018, it has released multiple reports of its findings from its purchasing programmes, where it has purchased and assessed 620 toys. In its latest report it purchased toys from third party sellers on Amazon, Aliexpress, eBay, Shein, Temu TikTok Shop and Wish. It found that there has been no improvement since 2018 with 90% failing to meet the UK legal safety requirements (81% failing a safety standard and a further 9% were illegal due to markings). ^{[footnote 29]}

We recognise the wide range of online marketplace business models and the need for requirements to be proportionate to their activities and level of control or influence on the supply chain. We anticipate this duty being introduced as one or more outcome-based requirements, allowing online marketplaces to put in place their own processes to meet the obligation in a way that is flexible. However, there may be specific processes or activities that need to be set out in the legislation to ensure that it is effective in reducing dangerous products sold across all online marketplace platforms. We are seeking your views on whether the legislation should require any specific actions.

Question A9: Do you agree or disagree with the requirement that producers must only place safe products on the market?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A10: Do you agree or disagree with the requirement that onward suppliers should act with due care and not supply a product unless it is compliant?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A11: Do you agree or disagree that online marketplaces should be required to act with due care to prevent, identify and remove non-compliant products from their sites?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A8: Giving only compliant sellers access to online marketplaces

Many sellers on online marketplaces – whether producers or onward suppliers, or consumers in the case of consumer-to-consumer sales – provide compliant and safe products to UK consumers. However, there are a proportion of sellers that put consumers, other customers and users, at risk by not meeting their obligations or placing dangerous products on the UK market.

Some non-compliant sellers repeatedly attempt to sell dangerous products, often purposely attempting to evade and confuse regulatory measures, for example by making new accounts to re-sell previously removed items, switching to a different online marketplace platform, incorrectly categorising products to avoid additional checks by the online marketplace, or by creating numerous seller profiles. Online marketplaces’ role in the supply chain means they hold the key to preventing sellers who do not comply with their obligation from having access to UK consumers and customers.

The ease of relisting non-compliant products

A Which? undercover investigation revealed that it was able to list an illegal dangerous heater on Amazon, eBay, Etsy and TikTok Shop in 2024. ^{[footnote 30]} eBay, Etsy and TikTok Shop all failed to identify the unsafe heater. eBay and Etsy only removed the products after it was anonymously reported, yet it took Which? formally notifying TikTok Shop to remove the listing. Amazon identified the unsafe heater as non-compliant and removed it after being on sale for three weeks in total. In a follow-up investigation, eBay correctly identified it as dangerous within 24 hours, Etsy and TikTok Shop removed it when Which? reported it after 6 weeks, and Amazon deactivated the listing due to it being too expensive after 2 weeks and reactivated it once the price was lowered. After this heater was removed by the platforms, Which? was able to relist an identical heater from the same seller on all sites two months later.

We propose that we introduce a duty on online marketplaces to practice due diligence to identify and take action against ‘bad actors’, such as those that repeatedly sell dangerous products or sellers who do not comply with other obligations in product safety legislation. We propose this duty is introduced as a high-level duty of due diligence, to allow different online marketplace providers to develop systems that align with their activities and role in the supply chain.

The activities that we could expect from online marketplaces in order to comply with this duty include, but wouldn’t be limited to:

• recognising sellers with multiple profiles
• issuing warnings and removing sellers with repeated non-compliance
• assuring and verifying seller information, such as by conducting ‘Know your business’ checks
• verifying and keeping up to date seller contact details
• introducing additional checks and monitoring sellers that have previously shown non-compliance
• educating previously non-compliant sellers on their obligations

Of these, we propose introducing a specific requirement for online marketplaces to verify seller contact details to ensure that they are correct and up to date. We believe that an explicit legislative requirement for this activity is vital to ensure up to date and correct contact information for all sellers that supply products in the UK. This is especially important in cases where recall notices need to be issued to prevent harm, as incorrect information could delay the recall notice reaching the correct actors and ultimately leave dangerous products in the hands of consumers, other customers and users. This would apply to both business and consumer sellers. Some online marketplaces already do this, so this would be creating a statutory baseline for existing online marketplaces and new entrants to the market. In situations such as a product recall where customers must be sent information, we would expect collaboration of online marketplaces to inform them (see proposal A10), especially where a seller may not be contactable or cooperative.

Question A12: Do you agree or disagree with the introduction of a requirement that online marketplaces should practice due diligence to identify and take action against non-compliant sellers and sellers that provide non-compliant goods?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A9: Additional tools for managing higher risk products

Additional verification by onward suppliers and online marketplaces

Onward suppliers will need to take due care to supply products only if they are safe. However, we may identify certain categories of products where the risk of harm caused by a dangerous product may be significant. In these cases, we may wish to require onward suppliers to take actions to check product compliance in detail or by following specific procedures. For example, it may be important to verify that the safety information is provided with the product and that it is accurate, or that – where relevant – the product has a declaration of conformity or conformity marking.

Similarly, we propose that the framework includes obligations on online marketplaces to act with due care to identify and remove dangerous products, and to have risk-based processes in place to do so. We could build on this general requirement for certain high-risk products to require online marketplaces to take additional actions that assure themselves that the product being offered for sale is compliant, including before allowing a listing to go live. This could include, for example, test purchasing or reviewing any necessary documentation provided, such as where a product has been conformity assessed. In the case of specific high-risk products, it may also be necessary for online marketplaces to verify that certain consumer information provided on a product listing, including warnings and other safety information, is accurate before allowing the listing to go live. In other cases, we could require online marketplaces to suspend or remove high-risk products from sale that they suspect are non-compliant until they have been assured that the goods meet the relevant safety requirements.

Local presence requirements

In Northern Ireland, many types of products require a ‘responsible person’ based locally in Northern Ireland or in the EU for a product to be placed on the market. We do not believe that this is proportionate for all products, particularly those which pose minimal or low risk, and is not a universal remedy for the challenges with online and international supply chains.

However, we believe a requirement for a responsible person based in the UK may be appropriate for some high-risk products where many of the non-compliant goods in question enter the Great Britain market from abroad. The responsible person would be a producer based in the UK: the manufacturer, their authorised representative or the importer of a product. This would require a business selling from abroad to appoint an authorised representative or reach an agreement with an importer of their products to take on this role.

Question A13: In which situations or for which products do you think additional verification requirements or local presence requirements would be useful?

Response options: Free text box

Proposal A10: Addressing dangerous products in consumers homes and workplaces

There may be situations where a product that is already in the hands of a consumer or user is alleged or found to be dangerous. This may be due to the producer or others in the supply chain not properly considering the safety of the product, or risks that had not been foreseen emerging once in use. We therefore propose introducing requirements on all supply chain actors (producers, onward suppliers and online marketplaces) to, within the limits of their activities, participate in monitoring the safety of the products that they have supplied or facilitated the supply of, and to cooperate in corrective action to protect consumers and users when a potentially dangerous product has been identified. This would extend the existing GPSR 2005 obligations to all supply chain actors in a way that would be reasonable and proportionate.

In order for supply chain actors to meet these obligations, we may require specific actions to be taken immediately on identifying or being made aware of a potentially dangerous product. These may include taking immediate corrective action, informing others in the supply chain, or notifying relevant authorities. This corrective action may include informing consumers and other customers of the risks posed by a product, providing additional instructions for safe installation, maintenance or use, supplying a physical or digital fix for the safety issue, or instigating a product recall.

One of the activities to support corrective action that GPSR 2005 requires is for distributors to keep and produce documentation necessary for tracing the origin of a product. This is vital to enable effective corrective actions to be taken following the identification of potentially dangerous products by helping trace the route the product has taken through the supply chain from producer to consumer. As one specific action to meet the duty to monitor the safety of products and cooperate in taking corrective action, we propose to build on the current regulations and require all supply chain actors to, as far as is reasonable, keep and produce documentation for tracing the origin of the products they have supplied or facilitated the supply of.

Each supply chain actor’s role and requirements will depend on their activities in the supply chain. For example, online marketplaces (where they are also not acting as an onward supplier) may only be required to retain and share information on the sale, such as seller and consumer details. The producer is ultimately responsible for ensuring their products are safe and this includes the responsibility for ensuring appropriate and effective corrective measures are taken.

We therefore propose to retain the existing requirement in GPSR 2005 that producers must do the following in order to effectively monitor the safety of products and act to protect consumers:

• Give consumers, users or others in the supply chain a route to make complaints regarding the safety of a product.
• Investigate complaints of product harm from consumers, users or others they have supplied the product to.
• Take corrective action if needed.
• Keep a register of complaints and relevant corrective measures.

Others in the supply chain with less control over the product, or where we cannot expect complete knowledge of the product or the consumers, may only be expected to provide information to help trace the product, to react to consumer and user complaints, or support relevant authorities or others in the supply chain to identify similar products which may also be dangerous.

Question A14: Do you agree or disagree that we should give all supply chain actors a duty to participate in monitoring of products already supplied and to cooperate in corrective action?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Proposal A11: Ensuring cooperation between businesses and relevant authorities

The growing numbers of products and sellers joining the market, alongside increasingly complex supply chains, have created challenges for relevant authorities to identify and enforce against non-compliance. Cooperation with relevant authorities is vital to support compliance and ensure that consumers and other customers and users are protected. This proposal seeks to build upon the best practice demonstrated by many supply chain actors who already cooperate well with relevant authorities. By creating a statutory duty to cooperate, we are seeking to level the playing field and ensure that all supply chain actors are cooperative with regulatory activity and compliance procedures.

We propose that all supply chain actors (producers, onward suppliers, and online marketplaces) will have a duty to cooperate with relevant authorities. This builds on the existing obligations in GPSR 2005.

For supply chain actors to fulfil this obligation, we may expect or require them to:

• Cooperate in a timely manner with requests from relevant authorities regarding actions to eliminate or mitigate risks that are presented by non-compliant or dangerous products in the supply chain. We may specify a maximum time for responses to certain requests.
• Provide relevant authorities with relevant information to mitigate risks posed by non-compliant or dangerous products, in a timely manner, upon request or as part of an ongoing agreement.
• For online marketplaces, to enable access to their interfaces for online tools operated by relevant authorities for the purpose of identifying non-compliant products or mitigating risks by carrying out regulatory functions.

We recognise the breadth of different businesses in scope of this and consider that it is reasonable and appropriate for this duty to apply proportionately to all, within the limits of their activities.

Given their respective roles in the supply chain, it is important that relevant authorities can easily and quickly contact producers and online marketplaces. We therefore propose requiring producers and online marketplaces to have a single point of contact for relevant authorities. For producers, as their contact details will need to be provided with the product, this could also be the single point of contact for relevant authorities. For online marketplaces, we may expect them to register the single point of contact with relevant authorities and ensure this is up to date. This will enable quick communication on product safety matters, including issuing critical safety notices.

Question A15: Do you agree that all supply chain actors should have a duty to cooperate with relevant authorities and others in the supply chain?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A16: Do you agree or disagree with the proposal for online marketplaces and producers to have a single point of contact?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

A new approach to product information

In this section we propose ways in which product information can be provided more flexibly – both physically and digitally – and seek views on how we can move towards a ‘digital by default’ approach to product information.

These proposals will protect consumers and other users from harm by:

• Making it easier for businesses to provide more detailed information to their customers, consumers and other users, with appropriate safeguards.
• Giving customers, consumers and other users more ways of engaging with product information, which may also allow easier access over the long term to product safety information, including for second-hand products.

These proposals will support businesses by:

• Providing greater flexibility over how product information can be provided, supporting innovation and reducing costs.
• Aligning the approach with product information requirements for UKCA-marked products.

Proposal A12: Our ‘digital by default’ ambition

The UK product safety framework requires specific product information to be physically provided, either affixed to the product or its packaging, or included in accompanying documentation. This information serves different primary purposes, such as:

• Product information for traceability: This includes details such as the producer’s details (or in the case of UKCA-marked products, the manufacturer or importer’s details and conformity marking). This information may also be relevant to consumers and customers for identifying the responsible business in the event of a product issue, query or product recall.
• Product information for consumers’ and other customers’ or users’ use: This includes safety warnings, product instructions, and other information for the consumer to safely interact with the product from the point of purchase.

Where there are no more specific requirements on product labelling and consumer information, we propose that the producer will need to ensure information is provided with their products. As currently under GPSR 2005, this should include warnings, safety information and instructions for safe use of the product; the batch or serial number, or other identifier; and their name and contact details.

As part of the broader commitment to cut unnecessary burdens and simplify product regulation, the government has announced a package of labelling reforms for certain products where the UKCA or CE marking applies. This will allow important information, such as the UKCA marking and importer details, to be provided in different formats, as well as digitally.

Building on these reforms, we are now proposing to give greater flexibility over how products must be labelled in the framework. Our ambition is to allow product labelling and product information to be ‘digital by default’, only requiring physical labelling by exception or on demand.

Information provided digitally can be easier to access, update and personalise. For example, by enabling translation into different languages, or offering audio formats for visually impaired users.

In some cases, digital formats may also allow consumers, other customers and users to access fuller and more detailed information that is not appropriate or can’t be physically included on the product or packaging, or with the product. For example, there has been significant stakeholder concern about chemical hazards that may be present in some products. While we do not propose to require all ingredients and chemicals present in all products to be identified in consumer information, we would already expect consumer safety information to include ingredients where they are known to be potentially harmful and instructions on how to avoid these harms. We propose to retain the current requirement to provide information needed to use the product safety.

For example, if known allergens are known to be present in a product, and there is a risk that people will come into contact with them in a way which could lead to an allergic reaction, these should be identified. If chemicals have the potential to be harmful where there are high levels of exposure, instructions on use to ensure exposure remains at safe levels should be included.

We also believe that digital labelling could support businesses that face challenges fitting extensive information onto small or constrained products or packaging, or those managing multiple language requirements. The growing volume of information can be difficult to present physically, especially for small products like cosmetics and electronics. Feedback from these sectors suggested that a digital approach could help maintain and improve transparency while supporting sustainable packaging practices.

We propose that product information can be provided in the following ways, where there are no specific requirements in sector regulations or standards that are being followed:

• A product identifier such as a serial or batch number must be provided physically on the product or its packaging, or where that is not reasonable, can accompany the product.
• The producer’s name and contact details for customers, users and relevant authorities can be provided physically or digitally. If provided physically, it can be on the product, on its packaging, or can accompany the product.
• Safety information, safety instructions and warnings can be provided physically or digitally. If provided physically, it can be on the product, on its packaging, or can accompany the product. Some sector regulations or standards may require safety information such as warnings to be provided on the product or packaging. In this case, the specific rules for that product will have priority and the information must be provided physically.

Where information is provided digitally, the digital label (such as a QR code) must be placed on the product or its packaging. It should also be stated clearly with the digital label what information can be accessed and, in the case of safety information provided digitally, that it should be read before use of the product. The EU’s General Product Safety Regulation does not permit digital labelling, so products being sold in Northern Ireland would need to be labelled physically. The European Commission is also currently consulting on expanding digital labelling. Before we legislate, we will consider developments in the EU and in Northern Ireland. Where the EU introduces requirements for products sold in the EU to have a digital product record, we will seek to support UK businesses by ensuring the same ‘data carriers’ (such as QR codes and NFC and RFID tags ^{[footnote 31]}) permitted for these will also be able to be used for digital labelling.

In providing greater flexibility for digital labelling, we recognise the importance of ensuring that all consumers, other customers and users can access essential product information, regardless of their digital confidence or access to technology. Any move toward digital provision must be accompanied by appropriate safeguards and mitigations to ensure inclusivity. For example, consumers who have limited internet access, or who are less confident using digital platforms, must still be able to understand how to safely use or assemble products. We propose that producers will be required to ensure the digital information remains accessible through the label for the expected lifetime of the product, including life-extending repair or refurbishment and taking account of the rise of the circular economy.

We also propose that we require all producers and onward suppliers who sell products directly to consumers (including online) to provide, for no additional cost to the consumer or customer, a physical copy of the safety information on request, either at the point of sale or after sale. This should be provided in the format preferred by and accessible to the consumer: in person where the business has a physical presence, by post or in printable format by email.

Question A17: Do you agree or disagree with the proposal for information that must be provided on or with the product?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A18: Do you agree or disagree with the proposed types of information that can be provided digitally?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A19: What, if any, protections would be necessary to ensure that consumers with limited digital access or low digital confidence online are not disadvantaged?

Response options: Free text box

Spotlight: Safe period products

Recent scrutiny, driven by media and advocacy groups, has led to concerns about the presence and potential leaching of harmful chemicals and traces of heavy metals in period products, both internal (such as tampons and menstrual cups) and external (including pads and panty liners).

During the passage of the Product Regulation and Metrology Act, we committed to consult on period products. As part of that we have engaged with industry, other government departments and non-governmental organisations. To contribute to our consideration of period products, an internal literature review has been undertaken to assess the presence of hazardous chemicals in period products and their potential health risks. This review found that across all categories, chemical levels were consistently low. Conservative exposure models showed that the risk is well below thresholds of concern, suggesting minimal toxicological risk.

There have been calls for specific regulation of period products, rather than relying on GPSR 2005 or UK REACH ^{[footnote 32]} which provides the baseline controls on the use of chemicals in products sold in Great Britain – whether chemical substances on their own, in a mixture or in an article, such as a car, furniture or clothing.

Following our literature review and wider conversations, we consider that under the new framework we should make better use of standards and codes of practice rather than introduce additional detailed product-specific regulations, which may not keep up with product innovations. To contribute to this, we are supporting the development of an international safety standard (ISO 25130 Menstrual Products) which will standardise risk assessments and testing for period products. It is expected to be in effect by 2028 and we anticipate that once it has been approved, it would then be designated.

In addition, the proposal to introduce digital labelling would also enable more information to be provided more easily to consumers.

Question A20: Are there any further actions you believe we should take beyond the existing and proposed requirements to ensure period products are safe?

Response options: Free text box

Proposal A13: Giving online consumers the right information at the right time

The consumer experience online is unlike shopping on the high street, where consumers can interact with physical packaging to see safety warnings, ingredient lists and age recommendations. However, product safety legislation has been unable to keep pace with the changes to e-commerce as consumer information requirements on packaging do not currently extend to online sales. While in general products must be as described in the online listing and fit for purpose, some product listings online have limited information relevant to the product’s safety. This can impact a consumer’s or other customer’s ability to make a fully informed purchasing decision.

It is also important for online marketplaces to make clear to consumers whether a product is being sold by a third party or by the online marketplace itself. Research conducted by the OPSS suggests that consumers are not always clear whether a product is being sold by the online marketplace or a separate third-party seller. This can mislead consumers, especially where an online marketplace’s reputation and brand may create a ‘halo effect’ that increases consumer trust of the product’s safety in a way that may overshadow the reality of a product’s compliance from a third-party seller. ^{[footnote 33]} The UK has a robust consumer protection regime, including provisions in the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The DMCCA, prohibits unfair commercial practices including misleading actions or omissions of material information that are likely to impact consumers’ transactional decisions. Our proposals build on this by ensuring that consumers and other customers shopping online are provided with specific product safety information that is necessary to make safe and informed purchases.

We propose to introduce obligations for producers or onward suppliers selling online to provide consumers and other customers with safety information. This would be required across all online sales, including sales on online marketplaces, to provide clear and equal obligations and consistent expectations of what information needs to be available to UK consumers and other customers before purchase. It can also be useful for relevant authorities where it is difficult to find product information. The obligation would apply to products being placed on the market for the first time and to second-hand products being resold. We do not believe that it would be proportionate for non-business sellers to be required to provide this information. We therefore propose to exempt non-business sellers from this obligation. This approach is in keeping with the broader product safety legal framework which does not typically apply duties to non-business sellers.

The information that we propose must be provided clearly and accessibly on the online product listing is only the following items, which we consider to be most important for consumers and other customers to see at the point of sale:

• The name and contact information of the seller and, if different, the producer (or where defined in product safety regulations, such as in some existing sector regulations, the manufacturer).
• Information to identify the product including the product identifier number and images of the product in its current condition.
• Product warnings and other safety information that must be provided physically on the product or its packaging as required by product safety regulations or designated standards (if applied to the product by the manufacturer).
• Compliance markings including conformity assessment and standards markings.

Any other information that could inform the purchase of a product. We could consider including composition of a product, such as whether the product uses AI or includes AI driven features.

As we review sector regulations, we will identify whether any other pieces of information contained in those regulations will also need to be provided online. As many online sales occur via online marketplaces, it is important that their online interfaces are designed in a way that makes safety information easily accessible to customers. We propose to require online marketplaces to design their online interface in a way that allows third-party sellers to provide the required information in a format that is clear and accessible for customers. This would ensure that information is displayed in an accessible manner and the same information is provided for sales on online marketplaces as for other online sales.

It may be the case that it is vital for some information to be provided for customers to make an informed decision regarding a purchase on an online marketplace. Therefore, we will consider whether online marketplaces should be required to prevent a product listing from going live without specific information or be required to verify such information. We will also consider whether any information is vital in specific circumstances, such as for high-risk product listings (see proposal A9).

Question A21: Do you agree or disagree with the proposed information that producers and onward suppliers selling products online should provide on an online listing?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A22: Do you agree or disagree that online marketplaces should be required to design their interface to allow sellers to provide customer information?

Response options:

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please explain your answer.

Response options: Free text box

Question A23: Should online marketplaces introduce additional steps, such as verifying certain product information or making some information mandatory before listings are published?

Response options:

• Yes
• No
• Not sure

Please explain your answer

Response options: Free text box

Building on the new foundations

This package of reforms modernises, simplifies and strengthens the core rules that will apply to all products to protect consumers and other users. These proposals will bolster the requirements for producers of potentially dangerous products that are not regulated by sector or product specific regulations to consider the risks these products pose. Whether it is fire hazards, ingestion hazards, or chemical hazards, producers will be responsible for ensuring their products are safe. The government will be able to designate a wide range of standards which if followed provide a presumption of conformity and will work with industry to create codes of practice. It will be easier for businesses to provide comprehensive safety information for consumers and users.

Proposal A14: Consolidating and simplifying the regulatory landscape

This is only the first step we can take to move from a product requirement-centred regulation to risk- and outcome-based regulation, and our ambition is to go further. As reviews of sector specific product regulations go forward, our aim is that more products may be regulated in part or in full by the new core framework. This could take various forms, including relying on the new framework for procedural requirements and retaining only the essential product safety requirements from existing sector regulations, or replacing these with new regulations that apply to all products sharing the same hazard and risk of harm.

We have already begun reviewing over 2,000 pages of sector-specific regulations to identify opportunities for reform to protect consumers and end users, and support innovation, investment and growth. While we will consult on any proposals to amend specific sector regulations, in this consultation we are interested in your views on provisions in sector regulations ^{[footnote 34]} that are:

• Better incorporated into the new framework. This may be because they are cross-cutting issues or where we can move from product requirement-based regulation to risk or outcome-based regulation. Where this is the case, the tools set out in proposals A5 or A9 could be used to manage the risks posed by those products. Alternatively, there may be procedural requirements which are unnecessary in addition to those contained in the new framework.
• Better delivered through standards that can be designated, for example where specific product requirements in legislation are holding back innovation.
• Better replaced by guidance, such as where the outcomes are not essential for safety and more flexibility would be helpful to both businesses and consumers.
• Better removed completely, such as where the requirements or procedural obligations are unnecessary, disproportionately burdensome, or detrimental to consumer safety.

Question A24: Do any of the provisions in existing sector regulations fit these categories?

Response options:

• Yes
• No
• Not sure

If you responded ‘Yes’, please provide details of the provisions and your reasons. If you consider that any of the additional tools in proposals A5 or A9 may be helpful for the relevant products, you may include this in your response.

Response options: Free text box

Proposal A15: Preparing for the products of the future

Artificial intelligence (AI) presents significant opportunities to improve safety, efficiency, and user experience across a wide range of products. At this stage of evidence‑gathering, we are considering AI‑enabled products in their broadest sense ranging from consumer appliances such as smart washing machines that optimise water and energy use based on load type, to connected home devices, children’s toys, and even industrial machinery. However, we need to ensure the new framework considers the potential risks from AI. The new framework will need to address risks of harm linked to automated decision-making and adaptive behaviour, ranging from products such as smart home devices and toys to autonomous quality control robots used in industry.

To fully realise AI’s potential, the government launched the AI Opportunities Action Plan in January 2025. AI has a wide range of applications and huge potential and that is why we believe the vast majority of AI systems should be regulated based on their use, by existing relevant authorities who understand how AI is being deployed in their sectors. In response to the AI Action Plan, the government has committed to work with relevant authorities to boost their capabilities. Through well‑designed and implemented regulation, we can ensure that AI is developed and used responsibly, delivering benefits for people, businesses and communities. ^{[footnote 35]}

The Product Regulation and Metrology Act 2025 enables regulation of AI when it is a component of a physical product (rather than regulating the AI in its own right), particularly where it affects safety. It introduces new powers to support adaptive regulation of emerging technologies, including software and internet-connected devices. We are actively examining the implications of AI in products and how best to use the Act’s powers to address emerging risks. Future regulatory updates will be shaped by stakeholder consultation and evidence on how AI affects consumer and user safety.

Innovation and challenges

Unlike traditional physical products, AI systems can evolve and adapt throughout their operational life, potentially in ways that are unpredictable or not foreseen at the point of use. This creates new types of risk, such as decisions made by the product that affect safety, including harmful unintended consequences, harm intentionally inflicted by the AI system, and security vulnerabilities. It also brings a wider range of risks to the fore in physical products, including physical risks, data security, and possible psychological harms. These risks need to be managed in a way that enables AI‑driven growth and innovation, while recognising that there is an inherent trade‑off in ensuring that users and consumers are appropriately protected.

Supply chains and national quality infrastructure

AI is, of course, not just being embedded in the products themselves, but is increasingly shaping how those products are manufactured, marketed, delivered, and assessed for compliance. From predictive maintenance in factories to AI-driven logistics, AI is becoming integral to the entire product lifecycle. This has significant implications for national quality infrastructure (NQI) systems, which must now adapt to ensure that standards, testing, certification, and market surveillance remain robust and trustworthy in an AI-enabled economy.

Current work and research on AI-enabled products

We are actively working to identify both the actual and potential risks that AI may pose when integrated in physical products. This includes examining how AI might affect a product’s safety, its performance, and compliance, whether embedded in the product itself or used in its design, manufacture, or testing. We are keen to gather robust evidence and insights from stakeholders to inform our approach and ensure that regulatory frameworks remain fit for purpose in an AI-enabled world. We are also seeking views on the implications of AI through the sector reviews.

Home robots

Home robots should allow consumers to automate many repetitive, dangerous, or physically demanding tasks that humans traditionally handle. They are manufactured to be able to negotiate the home, including climbing the stairs, lifting items like bins or washing baskets, and using tools. As well as having the potential to perform chores, such as laundry, cooking, washing, and moving items, some home robots will be designed to support vulnerable people with walking, standing, bathing and rehabilitation from injury. When these home robots also include AI, they will also be able to learn new functions, or even new behaviours from their owners. While many of the capabilities described remain at the trial or emerging phase of development and represent functionality far more advanced than current consumer devices such as robot vacuum cleaners, they are expected to move closer to mainstream consumer products over the next few years.

As under the existing GPSR 2005, the new framework will require producers to ensure that products are safe for the consumer, and product-specific legislation (such as for electrical and electronic equipment, toys, and medical devices) may also apply to these products. Specific risks presented by some home robots may be identified that require more specific regulation, on a sectoral, hazard-based, or cross-cutting basis. For example, personal carrier robots should ensure passengers are sitting correctly before setting off. This could be covered by specific regulations similar to the UNECE regulations adopted by the EU for seatbelt reminder systems to be mandatory for all seats in cars produced after 2019.

Despite the novel nature of these products, standards are already available that specify requirements and guidelines for the design, protective measures that should be taken, and consumer information for the proper use of home robots. For example, the International Organisation of Standardisation’s ISO 13482 is a specific standard for mobile servant robots, physical assistant robots, and person-carrier robots. There may also be the potential for similar standards for home robots to become UK Designated.

We would like to understand perceptions and experiences of these new AI enabled products (AIEP). We want to hear about:

• Your experience or knowledge of actual or potential harms from AIEP, as well as the capability of AI to improve the safety of products.
• Any examples of designing, testing and monitoring AIEP – or the type of AI-enabled products you anticipate manufacturing or selling in the future.
• Your experiences with current regulatory frameworks as they apply to AIEP.
• Your experience or knowledge of consumers who may be at greater risk of harm from AIEP.
• Any suggestions for how the UK can develop a proportionate approach that protects consumers while supporting business innovation.

Question A25: Are you aware of any data or evidence on the types of AI-enabled products that are likely to be manufactured in the future?

Response options:

• Yes
• No
• Not sure

If you responded ‘Yes’, please detail the data or evidence you are aware of.

Response options: Free text box

Question A26: What do you think are the current or potential harms associated with AI-enabled products?

Response options: Free text box

Question A27: How can we ensure that the reformed product safety framework effectively addresses the unique challenges posed by AI-enabled products and digital innovations, while supporting innovation?

When responding to the question, please consider:

• Is the framework proposed in this consultation sufficient?
• Are any additional sector-specific provisions required?
• What new approaches might be needed to safeguard consumers while supporting innovation, and how could measures such as consumer information, standards, quality assurance, data governance, documentation requirements or human oversight improve the safety of AI‑enabled products?

Response options: Free text box

Question A28: Considering that the role of AI can adapt and evolve across a product’s entire life cycle, how can regulation best account for this?

Response options: Free text box

Next steps

The government will consider responses and publish a response within 12 weeks of the closing date of the consultation. We will then bring forward regulations to implement the decisions taken. We will consider what transitional arrangements are required to enable products that are compliant before the new regulations come into force to continue to be supplied and to protect the status of standards currently ‘referenced’ under GPSR 2005.

Implementation guidance

Following publication of the government’s response to this consultation, we will work closely with all interested stakeholders to develop comprehensive and useful guidance for businesses and relevant authorities, including updating the OPSS’ Product Safety Risk Assessment Methodology (PRISM). ^{[footnote 36]} Our ambition is to provide clarity and certainty to everyone, allowing consumers and users of products to be assured of the safety of the products they are buying, whether online or on the high street.

Reviewing the patchwork of sector regulations

Implementing this new framework is the first step in the government’s plans for reform to the product safety regulatory landscape that will benefit both businesses and consumers. We will continue our programme of sector reviews to assess the current patchwork of regulations, working in partnership with industry and consumer groups, building on what works and updating what doesn’t.

Footnotes

1. Backing your business: our plan for small and medium-sized Businesses (2025). The policy commitment can be found within the policy annex. ↩

2. Throughout this consultation, the term “online marketplace” is used to reference the online service that facilitates the marketing of products, as well as the business entity or person who (i) controls access to an online marketplace, (ii) controls the contents of an online marketplace, or (iii) acts as an intermediary for a person who controls such access or contents. ↩

3. Internet sales as a percentage of total retail sales (2025) – ONS website ↩

4. Government response to the Product Safety Review and next steps (2024) ↩

5. The government has made the Noise Emission in the Environment by Equipment for Use Outdoors (Amendment and Transitional) Regulations 2025 which come into force in April 2026. ↩

6. In the accompanying consultation Product regulation: market surveillance and enforcement. ↩

7. A new approach to ensure relevant authorities and regulation support growth ↩

8. Machinery safety legislation: call for evidence ↩

9. The Noise Emission in the Environment by Equipment for Use Outdoors (Amendment and Transitional) Regulations 2025 ↩

10. The EU’s updated General Product Safety Regulation – Europa website ↩

11. In the existing General Product Safety Regulations 2005, a consumer product is defined as a product which is intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them and which is supplied or made available, whether for consideration or not, in the course of a commercial activity and whether it is new, used or reconditioned and includes a product that is supplied or made available to consumers for their own use in the context of providing a service. ↩

12. A product for the purposes of the Product Regulation and Metrology Act 2025 is defined in Section 1(7) of the Act. The products excluded from scope of the Act are detailed in the Schedule. ↩

13. Product safety for businesses: A to Z of industry guidance ↩

14. If relevant to you, we encourage you to also respond to the Consultation on the General Safety Requirement for Construction Products. ↩

15. In this consultation, we use the term ‘supply’ to refer to ‘marketing’ which is defined in the Product Regulation and Metrology Act 2025 as “making available on the market”. ↩

16. The definition of a safe product is provided in Regulation 2 of the General Product Safety Regulations. ↩

17. For more information on designated standards, see proposal A6. ↩

18. In this consultation, the term ‘relevant authority’ means an enforcement authority or a market surveillance authority. ↩

19. The Product Safety Risk Assessment Methodology referred to as PRISM provides further detail of the hazards to be considered. ↩

20. Fast track standards include Publicly Available Specifications (PAS) which are a specific form of standard that can be developed quickly but is not considered a full British standard. ↩

21. The British Standards Institution (BSI), European Committee for Standardisation (CEN), European Committee for Electrotechnical Standardisation (CENELEC) and European Telecommunications Standards Institute (ETSI) or by international standardising bodies (including the International Organization for Standardization (ISO), International Electrotechnical Commission (IEC) and International Telecommunication Union (ITU). ↩

22. Where someone in the supply chain affects the safety of a product, they would be classified as a producer rather than a distributor. ↩

23. The EU’s New Legislative Framework (NLF) – Europa website. The EU is considering reforms to the NLF. We will take note of the outcome of that process and whether that has implications for our new framework. There is no indication that the review of the NLF will lead to changes in the definitions of the supply chain actors. ↩

24. The concept of making available on the market is defined by the EU as: “any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge”. ↩

25. The EU’s updated General Product Safety Regulation which applies in Northern Ireland under the Windsor Framework defines a fulfilment service provider as: “any natural or legal person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved, excluding postal services as defined in Article 2, point (1) of Directive 97/67/EC of the European Parliament and of the Council, parcel delivery services as defined in Article 2, point (2) of Regulation (EU) 2018/644 of the European Parliament and of the Council, and any other postal services or freight transport services”. ↩

26. Product Safety Alerts, Reports and Recalls ↩

27. Carbon monoxide poisoning: How common is it? – National Institute for Health and Care Excellence (NICE) website ↩

28. Killer carbon monoxide alarms still on sale through online marketplaces – Which? website ↩

29. Still Toying with Children’s Safety (Appendix 1) – British Toy and Hobby Association (BTHA) website ↩

30. How we were able to easily list illegal products for sale on online marketplaces – Which? website ↩

31. NFC (near-field communication) and RFID (radio frequency identification) are two technologies that allow communication between devices near each other. NFC or RFID tags can store product information which can be read by a compatible device such as a mobile phone. ↩

32. UK REACH is the responsibility of the Department for Environment, Food and Rural Affairs (Defra). Enforcement of UK REACH is done by the Health and Safety Executive (HSE). More information on UK REACH is available on the HSE website. ↩

33. Online Marketplaces Consumer Journeys (2025) ↩

34. See for reference the list of regulations in Annex A of the Government response to the Product Safety Review and next steps. ↩

35. AI opportunities action plan (2025) ↩

36. The current Product Safety Risk Assessment Methodology (PRISM) ↩