The UK’s Office for Product Safety and Standards (OPSS) published two consultations proposing sweeping reforms to the UK product safety framework. In this blog, the Cooley products team considers the key proposals – from an expanded scope and new online marketplace duties to digital labelling flexibility and a consolidated enforcement toolkit featuring civil monetary penalties – and flags why they could be important to you.
On March 31, 2026, the UK’s national product safety regulator, the Office for Product Safety and Standards (OPSS), published its long-awaited consultations setting out proposals to reform the UK product safety framework. The proposals are split across two consultations – one on the framework itself and one on enforcement:
- Product regulation: the UK’s new product safety framework
- Product regulation: market surveillance and enforcement framework
Why does this matter?
These proposals form part of a programme of work intended to deliver the most significant overhaul of the UK product safety framework in a generation. The consultations offer stakeholders a real opportunity to advance issues, such as digital labelling, and to advocate for simplification and reduced business burdens. For some topics, this may be the only chance to provide input before secondary legislation is introduced under the Product Regulation and Metrology Act 2025 (PRAM Act). For potentially impacted businesses, now is the time to engage – either to voice support or concern, or propose clarifications.
Headlines of what’s included in the proposals
Getting the basics right
EU alignment: Northern Ireland (NI) will continue to follow certain European Union product safety rules in accordance with the Windsor Framework. The consultation notes that the new UK framework is expected to apply in Great Britain (GB) in a complementary way to EU rules applying in NI, and that UK proposals will “support trade with the EU”, all pointing to some level of EU alignment. However, several proposals envision a different approach to that of the EU – in short, we see the potential here for a level of conflict and confusion.
Reforms to core framework rules: The first consultation addresses the UK’s product safety framework, proposing reforms to the rules in the UK’s General Product Safety Regulations 2005 (UK GPSR). The UK GPSR acts as a baseline “safety net”, where there are no specific provisions with the same objective in other product safety legislation. This consultation will be followed by reviews of sector-specific legislation (i.e. governing UKCA/CE-marked products) that overlay the core framework, to be carried out over the next three years. Whatever is agreed in the core framework will therefore have far-reaching implications.
Expanded scope: A key proposal is expanding the UK GPSR beyond consumer products to cover all products, including nonconsumer workplace products, with some exemptions. This is a wider scope than the EU GPSR (focused on consumer products); however, it is not seeking to cover stand-alone software (which EU GPSR does, albeit not expressly within the legislation itself; this is instead confirmed in guidance). As with the EU regime, sector-specific legislation with the same objective would continue to take precedence over the new baseline framework. Arguably, the category of nonconsumer workplace products not already covered by sector-specific legislation is likely to be very narrow. However, the proposals could still affect these products where they introduce new pre-market or post-market obligations not addressed by existing sector-specific regimes.
Updates for new technology products: The proposals include updating the factors relevant for assessing product safety, including cybersecurity and artificial intelligence/machine learning risks – broadly in line with the EU GPSR’s broadened view of “safety”.
Accountability throughout the supply chain
Reframed supply chain actors bringing online marketplaces into view: The consultation proposes duties for three categories of supply chain actor:
- “Producers” (UK-based manufacturers/own-branders, UK-authorised representatives, importers, overseas sellers for distance sales direct to UK consumers, and others whose activities affect product risk)
- “Onward suppliers” (distributors and fulfilment service providers)
- “Online marketplaces”
For online marketplaces, the proposals include new duties to act with due care to prevent, identify and remove dangerous products, and to practise due diligence to identify and take action against “bad actors” on their platforms. These are framed as high-level, outcomes-based duties – giving marketplaces flexibility in how they comply aligned with their activities and role in the supply chain. The consultation includes nonexhaustive examples of compliance steps but does propose mandating verification of seller contact details. These duties sit alongside other targeted reforms, including requiring online marketplaces to design their interfaces to enable third-party sellers to comply with new mandatory information requirements for online offers.
Additional tools to manage higher-risk products: The consultation proposes additional tools for higher-risk products, including potential verification or pre-listing assurance requirements for onward suppliers (i.e. distributors) and online marketplaces. It also proposes that there be a UK-based responsible person for the GB market, but only for certain high-risk products, e.g. where many of the noncompliant goods in question enter the GB market from abroad. This contrasts with the EU and NI position, which requires an EU responsible person for all nonharmonised products in scope of the EU GPSR and for products under many EU sector-specific rules. The UK approach recognises that requiring a responsible person for all products would not be proportionate. However, the role would be limited to UK-based manufacturers, authorised representatives or UK importers – without the option of using a fulfilment service provider (as is available in the EU).
Post-market monitoring, corrective actions and reporting: The consultation proposes requirements on product safety monitoring and corrective actions for all supply chain actors (producers, onward suppliers and online marketplaces), with the extent of the obligation depending on their respective activities within the supply chain. It also proposes requirements to retain documentation to enable product traceability. Overall, the proposals appear largely to preserve the existing recall and reporting framework, while introducing some additional obligations – notably for online marketplaces. However, the consultation does not provide detail on whether specific reforms introduced under the EU GPSR (for example, in relation to recall remedies) will be taken forward in the UK.
No mention of accident reporting: At this stage, the consultation gives no indication that OPSS intends to follow the EU GPSR approach of introducing a separate general accident reporting obligation (outside of the risk-based obligation to report dangerous products and existing obligations to report certain incidents for specific products, e.g. cosmetics).
Cooperating with authorities: The consultation proposes extending the statutory duty to cooperate with authorities to all supply chain actors. Online marketplaces may be required to enable access to their interfaces for online tools operated by regulators to identify noncompliant products. The proposals also include requiring producers and online marketplaces to have a single point of contact for authorities, with online marketplaces potentially required to register this contact point.
A new approach to product information
Move towards greater digital and physical labelling flexibilities: The consultation proposes allowing certain product information to be provided digitally instead of physically, as part of a broader push towards “digital by default”. At this stage, the proposals cover the producer’s name and contact details (capturing the UK importer) and even certain safety-relevant information. For UKCA/CE-marked products (governed by sector-specific legislation), the government has announced that separate legislation is planned for later this year to give businesses more flexibility on labelling for products placed on the GB market, including allowing digital labelling for some information – albeit for anyone placing the same products also on the EU and NI markets, digital labelling alone, for the most part, will not be compliant as things currently stand (the EU has been consulting on potential proposals as part of the upcoming European Product Act, largely focussed on moving towards Digital Product Passports).
New requirements for online offers: The consultation also proposes new mandatory information requirements for online product offers, largely based on the EU GPSR but arguably going further – including compliance markings and “any other information that could inform the purchase of a product”, such as whether a product uses AI or includes AI-driven features.
Building on the new foundations
Consolidating and simplifying the regulatory landscape: Ahead of the sector-specific reviews, the consultation also seeks feedback on provisions in sector-specific legislation that could be simplified, moved to the core framework, delivered through standards, replaced by guidance or removed entirely.
Preparing for products of the future: The consultation focuses on AI components in physical products (excluding AI in its own right). No specific reforms have been proposed at this stage. Instead, the OPSS is seeking feedback to inform future proposals and its upcoming sector-specific reviews about, for example, current or potential harms associated with AI-enabled products, regulating life cycle risks, and how to regulate AI-enabled products and digital innovations while supporting innovation.
Market surveillance and enforcement reform
New enforcement toolkit: The second consultation proposes consolidating and strengthening enforcement and market surveillance powers currently spread across more than 71 pieces of legislation into a single toolkit in one piece of legislation, applicable across all product regulation (UK GPSR and sector-specific legislation).
Expanding available penalties to ramp up enforcement: The existing reliance on criminal sanctions is seen as a blocker to enforcement (due to higher bar and the time and costs to bring criminal proceedings). The consultation proposes introducing civil sanctions, including powers for authorities to directly issue civil monetary penalties, alongside tools like enforcement undertakings (similar to the new enforcement regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA)). The OPSS is also considering obligations for companies to admit fault publicly or pay compensation.
In relation to online marketplaces, the OPSS is considering whether additional bespoke enforcement powers are needed, such as powers similar to Online Interface Orders available in the EU and under the UK DMCCA (e.g. directing removal of content, disabling access, displaying warnings or deleting domain names) or requiring certain online marketplaces to have a UK presence (e.g. where they have a high number of UK sales or demonstrated noncompliance or lack of cooperation with authorities).
Other reforms to enhance market surveillance: Proposals include new cost recovery powers for authorities and enhanced information sharing.
What’s next?
Both consultations are open until June 23, 2026. This is an important opportunity for stakeholders to comment on the proposed reforms. After considering stakeholder responses, the government plans to publish its response within 12 weeks and to introduce regulations in Parliament to implement the decisions taken. The government then plans to complete the sector-specific reviews over the next three years.
In addition to the two main consultations, the OPSS has separately published a third consultation on the fire safety of domestic upholstered furniture.
Like to know more?
Get in touch with any member of the Cooley products team to find out more about the OPSS consultations, including how to formulate a submission and how the proposals may impact your products.
