UK Government Launches Consultation to Overhaul Existing Product Safety Regime

On 31 March 2026, the UK Government's Department for Business and Trade and the Office for Product Safety and Standards launched a consultation¹ on a proposed new product safety framework for the United Kingdom, exercising powers granted by the Product Regulation and Metrology Act 2025 (the "Act"). The consultation proposes a new core regulatory framework to replace the General Product Safety Regulations 2005 ("GPSR 2005"). If adopted, this would be the most significant overhaul of the United Kingdom's product safety regime in two decades.

The Government's proposals include regulation of AI-enabled products and digital-by-default labelling, forming part of a growing trend of updating existing legislation and regulations to keep up with the rapid development of new technologies. The proposals also see to address address the modern realities of digital and globalised supply chains, and enhance consumer protection—without imposing unnecessary burdens on businesses. A key theme of this consultation is the move towards a more risk-based and proportionate regulatory framework that is intended to reduce compliance costs for low-risk products while maintaining robust protections where risks are higher. The consultation also explores shifting the balance between prescriptive regulation and industry-led standards.

For multinational manufacturers and digital platform operators, the direction of travel is clear: more targeted regulation, increased scrutiny of online sales channels, greater data transparency, and enhanced enforcement coordination. While the consultation remains at a formative stage, businesses should begin preparing now for material changes in both compliance obligations and litigation risk.

We have summarised below the key proposals and their potential impact on businesses operating in the United Kingdom.

Summary of Key Proposals

1. Broader scope and updated safety standards: The new framework would apply to all consumer and business products with limited exceptions for products which are governed under separate regimes (e.g., food, medicines, medical devices, military equipment). The criteria for assessing safety would be significantly updated to include cybersecurity risks, risks posed by AI or machine learning functionality, and specific hazards relating to children, the elderly and persons with disabilities. The Government would gain expanded powers to designate voluntary industry-led standards which, if followed, would provide a presumption of safety.
2. New supply chain obligations: Three categories of supply chain actor would bear duties under the new framework: producers, onward suppliers (replacing "distributors" under GPSR 2005 and expressly including fulfilment service providers), and online marketplaces. Producers would be prohibited from placing unsafe products on the market and would be required to conduct sample testing, investigate complaints, and maintain a complaints register. Onward suppliers would be required to act with "due care" and not supply products they know or should know to be dangerous. Overseas sellers offering products to UK consumers via distance sales would be treated as producers.
3. Online marketplace accountability: Online marketplaces would be required to act with due care to prevent, identify and remove dangerous products from their platforms, and to practise due diligence against repeat offending sellers—including verifying seller contact details and conducting "Know your business" checks. For higher-risk products, additional verification obligations may apply, and a requirement for a UK-based "responsible person" is under consideration.
4. Digital-by-default labelling and consumer information: Safety information, producer contact details and other product information may be provided digitally (e.g., via QR codes), with physical labelling required only by exception or on request. Producers selling online would be obliged to include specified safety information in product listings, and online marketplaces would need to design their interfaces to facilitate clear disclosure of such information.
5. AI-enabled products: The Act enables regulation of AI when it is a component of a physical product. The Government is actively gathering evidence on how to address post-sale risks including those related to automated decisions, security vulnerabilities, and other potential harms.

Impact on Businesses

The proposed reforms, if adopted, will likely give rise to significant practical and legal implications for businesses operating in or supplying products to the UK market. If the proposals are adopted, manufacturers, importers, distributors, fulfilment service providers and online marketplace operators should expect their legal obligations to expand in scope and specificity.

Businesses that currently classify their products as "business products" outside the remit of GPSR 2005 should note that the proposed framework would apply to all products, including those used in commercial and workplace settings. Further, the broadened safety assessment criteria encompassing cybersecurity, AI functionality and vulnerabilities affecting particular consumer groups would require updated product risk assessments.

The proposed reforms represent a material shift in the United Kingdom's approach to product safety regulation. Our cross-practice team, spanning regulatory, commercial, technology and consumer law, is well placed to help our clients assess the impact of these proposals on their operations and develop forward-looking compliance strategies. For further information, please get in touch with one of the authors or your usual Mayer Brown contact.