The Cooley products team brings you a roundup of the highlights from Europe in 2024 and what to look out for in 2025.
2024 was another huge year for products law. In the European Union, a number of significant laws entered into application, and we saw an unprecedented number of new laws complete the law-making process, as the 2019 – 2024 mandate of the European Commission came to an end. The UK also took its first legislative steps to reform the UK product safety framework. In this blog, the Cooley products team brings you a roundup of our highlights from 2024 and what to look out for in 2025.
2024 year in review
We saw a number of game-changing laws start to apply in the EU, including the:
- General Product Safety Regulation
- RED Common Charger Directive
- Ecodesign for Sustainable Products Regulation (ESPR)
- Batteries Regulation
An unprecedented number of new laws completed the final stages of the law-making process and will start to apply after various transition periods, including the:
- Artificial Intelligence (AI) Act
- Cyber Resilience Act
- Revised Product Liability Directive
- Directive on common rules promoting the repair of goods (Right to Repair Directive)
- Directive on empowering consumers for the green transition
- Regulation on Prohibiting Products Made with Forced Labour on the Union Market (FLR)
- Revised Environmental Crime Directive
- Revised Construction Products Regulation
- Packaging and Packaging Waste Regulation
- Critical Raw Materials Act
- Revised regulation on the classification, labelling and packaging of substances and mixtures (CLP Regulation)
- Revised Waste Shipments Regulation
The European Commission has started work on secondary legislation and other measures to implement these new rules, alongside continuing to progress existing work programs – e.g., in the areas of eco-design and chemicals.
The European Commission also published its fitness check of EU consumer law on digital fairness, expected to lead to an upcoming legislative proposal.
In the UK, we saw the:
- Product Regulation and Metrology Bill introduced into the UK Parliament, followed by the government response to the consultation on the UK Product Safety Review and publication of two calls for evidence on potential areas of reform using new powers under the bill.
- Product Safety and Metrology, etc. (Amendment) Regulations 2024 passed and entered into application – extending recognition of certain products that meet EU requirements “indefinitely” beyond the December 31, 2024, deadline for the GB market.
- Digital Markets, Competition and Consumers Act completed the law-making process.
- Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 introduced into the UK Parliament and completed the law-making process.
- Government response to the consultation on proposed reforms to the UK Waste Electrical and Electronic Equipment (WEEE) Regulations published.
We also saw proposed UK legislation to introduce digital labelling and extend easements for importer labelling notified by the previous government to the World Trade Organization in May, but not carried forward by the new government in that form following the election.
What to expect in 2025
There are a number of significant proposals presented during the previous mandate of the European Commission that carried over with work continuing in the European Parliament and Council. These include the:
- Proposed Toy Safety Regulation
- Proposed Green Claims Directive
- Proposed Customs Reform package
- Proposed AI Liability Directive
- Proposed revision of the Waste Framework Directive
The new European Commission commenced on 1 December 2024 and is expected to continue work on several long-awaited initiatives, alongside new proposals, which are expected to include the:
- Proposed ‘universal’ PFAS (per- and polyfluoroalkyl substances) restriction
- Proposed revision of REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)
- Proposed Delegated Act under the Radio Equipment Directive on software that alters the safety or compliance of a device (reconfigurable radio systems)
- Proposed revision of the Textiles Regulation
- Proposed new Circular Economy Act
- Proposed new Digital Fairness Act
However, draft legislation for some of these is not expected until 2026 at the earliest.
A lot of the European Commission’s work also is expected to focus on the rollout of recently passed laws – e.g., working on secondary legislation, guidance and other actions. We’re closely following this in a number of areas – including for the ESPR, with publication of the working plan (setting out product priorities) and various pieces of secondary legislation (e.g., setting out details and format for the disclosure of unsold consumer goods discarded and derogations to the ban on the destruction of unsold clothing, accessories and footwear), alongside preparation of the first Delegated Acts on textiles and steel (laying down new performance and information requirements) and work to roll out the new Digital Product Passport system.
In the UK, the government is expected to:
- Start using new powers to make secondary legislation under the Product Regulation and Metrology Bill as soon as that legislation is passed by the UK Parliament.
- Present legislation making targeted reforms to the UK WEEE Regulations and publish plans for more wider-ranging reforms as part of a drive towards a circular economy.
We’ll also be monitoring any progress on the long-overdue consultation on the UK Battery Regulations.
Alongside these changes, the increased focus on enforcement and international co-operation we’ve seen over recent years looks set to continue.
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