UK Government’s consultation on reforms to the product safety framework

On 31 March 2026, the UK Government’s Department for Business and Trade (“the DBT”) launched a consultation on a package of reforms to the UK’s product safety framework including updated obligations on businesses in the supply chain. It proposes a redesigned core regime to replace and modernise the UK’s current product safety framework under the General Product Safety Regulations 2005 (“GPSR 2005”).

Since the GPSR 2005 was introduced two decades ago, the way organisations buy and sell products has changed dramatically: e-commerce is now a major route to market, and new business models (such as online marketplaces, fulfilment services and drop‑shipping) have reshaped how products move from overseas manufacturers to UK homes and workplaces.

In what is said to be part of the government’s plans for reform to the product safety regulatory landscape, the DBT’s consultation sets out proposals for the new framework, grouped into the following themes:

1. Getting the basics right
2. Accountability throughout the supply chain
3. A new approach to product information
4. Supporting enforcement activity
5. Building on the new foundations

We explore the proposals below. This consultation should be read alongside the Government’s companion consultation on market surveillance and enforcement aspects of the reformed framework which we have blogged about here.

What are the proposals?

Getting the basics right

Under the proposals, the new framework would apply to all products (i.e. both consumer and business products) with limited exceptions and exclusions. This would extend the baseline protections beyond the GPSR 2005’s current consumer focus, the intention being to extend protections to users whether products are bought for use in the home or in the workplace.

The consultation lists a specific and limited range of excluded products, such as medicines and medical devices, agricultural products and food. These excluded products are already regulated by existing, distinct and targeted regulatory frameworks and therefore would fall outside the scope of this proposed new framework. It is acknowledged that where products are regulated by other product safety legislation with the same objective, the other (sector-specific) legislation will take precedence over the new framework.

Concept of ‘safe’ products

In addition, across existing product safety legislation, what it means for a product to be “safe” in law is defined in different ways. The DBT proposes to retain the GPSR 2005 definition of a “safe product” but apply it across the expanded product scope. The consultation proposes an updated, clearer set of safety considerations when assessing products, capturing modern risks and expectations, including risks posed by cybersecurity, AI and machine learning functionality.

Accountability throughout the supply chain

The consultation states that all intermediaries in the supply chain between the producer and the consumer or user have a role to play in product safety. The DBT proposes to create three categories of supply chain actor: producers, onward suppliers (replacing and expanding the current “distributor” concept and explicitly including fulfilment service providers) and online marketplaces (i.e. a website, app or other online platform feature that facilitates the marketing of products in the UK). It proposes the following duties:

• For producers, the DBT proposes to replicate the core GPSR 2005 general safety requirement that producers are prohibited from supplying or offering to supply a product unless it is safe;
• For onward suppliers, the DBT proposes to follow the precedent set by the GPSR 2005 by requiring 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; and
• For online marketplaces, the DBT proposes that they must act with due care to prevent, identify and remove dangerous products being sold via their platforms.

These categories will not be mutually exclusive, and businesses may perform multiple supply chain roles depending on their activities. Consumers who sell second-hand products are not generally in scope of these definitions.

To ensure that online marketplaces provide compliant and safe products to UK consumers, the DBT proposes to introduce a duty on online marketplaces to practice due diligence to identify and take action against “bad actors”, i.e. those who repeatedly sell dangerous products or sellers who do not comply with other obligations under product safety legislation.

The DBT proposes to introduce requirements on all supply chain actors to, within the limits of their activities, participate in monitoring the safety of products that they have supplied or facilitated the supply of, and to cooperate in corrective action to protect consumers and users when potentially dangerous products are identified. In order to do this, the DBT proposes to retain certain existing requirements from the GPSR 2005 for producers.

A new approach to product information

The current UK product safety framework requires specific product information to be listed, either affixed to the product or its packaging, or included in accompanying documentation. Where there are no more specific requirements on product labelling and consumer information, the DBT propose that the producer will have to ensure certain information (such as warnings, safety information, and instructions for safe use) is provided with their products.

The DBT proposes introducing greater flexibility over how product information can be provided and how products must be labelled in the framework, including a requirement that producers ensure that digital information must remain accessible for the expected lifetime of the product, and a requirement that all producers and onward sellers provide consumers a physical copy of safety information at no extra cost in certain circumstances.

For online sales, the consultation proposes obligations on producers and onward suppliers selling online to ensure key safety information is available on the online listing, and proposes requiring online marketplaces to design interfaces that enable sellers to present required information clearly and accessibly.

Supporting enforcement activity

We discuss the enforcement aspects of the reformed framework in detail here.

The DBT also proposes to introduce a statutory duty on all supply chain actors to cooperate with relevant authorities. On this, it proposes that producers and online marketplaces should have a single point of contact for authorities, to support faster and more consistent regulatory engagement. For some high-risk products where many of the non-compliant goods in question enter the GB market from abroad, the DBT considers that a requirement for a responsible person based in the UK may be appropriate.

Building on the new foundations

As reviews of sector specific product regulations go forward, the DBT’s 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.

In connection with this, the DBT are particularly interested to hear from those with views on sector regulations that are:

• better incorporated into the new framework, for example, because they may contain duplicative procedural requirements 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; and
• better removed completely, such as where the requirements are no longer necessary.

Further, the Product Regulation and Metrology Act 2025 (“the 2025 Act”) enables regulation of AI when it is a component of a physical product, particularly where it affects safety. The DBT note that the new core framework will need to consider the potential risks from AI, such as the risks of harm linked to automated decision-making and adaptive behaviour. The DBT is examining how best to use the 2025 Act’s powers to address these emerging risks.

Comparison with the EU framework (GPSR 2025)

In relation to the roles and responsibilities of supply chain actors, the consultation details some notable differences to the current EU product safety framework. For instance, under the EU General Product Safety Regulation 2025, a product cannot be placed on the EU market unless there is an EU‑based “responsible person” (economic operator), which can be one of either: the manufacturer (EU‑established), importer, authorised representative, or fulfilment service provider (in some cases). Therefore, a non‑EU business must ensure EU establishment via an economic operator before selling into the EU.

By contrast, the consultation does not expressly mandate the need to appoint a responsible person (or authorised representative). Rather, it applies a cascading definition of supply chain roles and the “producer” category will follow the precedent of the current GPSR 2005. So, where the manufacturer is not based in the UK, the manufacturer’s authorised representative established in the UK, is deemed to be the producer. Where there is no manufacturer or authorised representative established in the UK, the importer of a product would acquire producer responsibilities. However, where neither a producer, its authorised representative or an importer are based in the UK, then the person ‘making the offer to supply the product or to place it on the UK market’ would hold producer responsibility. In practice, this would mean that a company outside the UK can sell directly into the UK without appointing a UK entity, and that company will itself bear producer obligations if no UK intermediary exists.

As explained above, the GPSR explicitly requires the appointment of an EU based responsible person in situations where a manufacturer, distributor or importer are not based in the EU and cannot fulfil that role. Therefore, the proposed UK approach represents a significant difference to the EU position on supply chain roles and responsibilities. A perceived benefit of the UK approach would be reduced friction for cross‑border trade and reducing mandatory intermediary compliance costs. However, non-UK businesses should be mindful of inadvertently acquiring producer responsibilities in situations where no other UK based onward suppliers are engaged.

Who should engage with the consultation?

Any business or organisation involved in placing products on the UK market (for home or workplace use) may wish to engage in this consultation, particularly where they have practical experience of product safety issues arising from modern supply chains and online sales. Stakeholders who are likely to be affected and who may wish to consider participating include:

• Manufacturers and brand owners.
• Importers and authorised representatives.
• Distributors, retailers, and fulfilment service providers.
• Online marketplaces.
• Trade associations, standards bodies and conformity assessment stakeholders.
• Public bodies and enforcement stakeholders.

Responses can be submitted via an online survey, by email or on paper. The consultation opened on 31 March 2026 and will close at 23:59 on 23 June 2026. Further details are available here: https://www.gov.uk/government/consultations/product-regulation-the-uks-new-product-safety-framework/the-uks-new-product-safety-framework

What is next?

Once the consultation closes, the DBT will consider responses and publish a response within 12 weeks, before bringing forward regulations to implement the decisions taken. Brodies’ Health and Safety team will monitor the consultation outcome and publish further updates as DBT’s response and any draft regulations emerge.

While the final shape and timing of any legislative changes will depend on the consultation outcome, in the meantime, organisations should review the consultation details and consider which supply-chain role(s) they perform and review and strengthen their product safety risk assessment and due‑care processes, with a view to planning for the potential changes that may lie ahead.

If you would like to discuss this consultation or any other aspect of Health and Safety, please get in touch with Brodies’ Health and Safety team or your usual Brodies contact.