Products | UK Regulatory Outlook April 2025

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UK

Update on the Product Regulation and Metrology Bill

On 1 April 2025, the Product Regulation and Metrology Bill had its second reading in the House of Commons and has now moved to Committee stage. During its second reading, discussions were had around modernising regulations, concerns around the reliance on delegate powers, and potentially allowing for dynamic alignment with EU regulations without sufficient parliamentary oversight. The start of the Committee stage is to be announced.

In the meantime, the Public Bill Committee has launched a call for evidence on the bill. The Committee will report its findings by 5pm on Tuesday 20 May 2025, but may conclude earlier. Submissions are to be sent to scrutiny@parliament.uk.

EU

European Parliament and Council reach provisional agreement on new EU Toy Safety Regulation

The European Parliament and Council have reached a provisional agreement on the proposal for a Regulation on Toy Safety. Measures being introduced by the regulation are as follows:

Ban on harmful chemicals

• Expanded the ban on harmful chemicals to now include endocrine disruptors, PFAS (with exemptions for toy components necessary for electronic or electric functions of the toy where the substance or mixture is fully inaccessible to children), and the most dangerous types of bisphenols.
• Prohibition of skin sensitisers and fragrance allergens in toys for children under 36 months and in toys meant to be placed in the mouth.
• The regulation grants the Commission the authority to remove toys from the market if new risks emerge.

Digital product passport

• All toys sold in the EU will have to have a clearly visible digital product passport in the format of a data carrier, such as a QR code.
• Manufacturers must conduct safety assessments on toys before placing them on the market covering chemical, physical, mechanical, and electrical hazards, as well as flammability, hygiene, and radioactivity. Where appropriate, assessments must consider children's specific vulnerabilities, including potential risks to mental health from digital toys.

Safety assessment

• Manufacturers must conduct safety assessments on toys before placing them on the market covering chemical, physical, mechanical, and electrical hazards, as well as flammability, hygiene, and radioactivity. Where appropriate, assessments must consider children's specific vulnerabilities, including potential risks to mental health from digital toys.

Economic operators and online marketplaces

• The new rules clarify obligations for manufacturers, importers, distributors, and fulfilment service providers, aligning with other EU legislation like the General Product Safety Regulation and Ecodesign for Sustainable Products Regulation.  
• Clarifies requirement for online marketplaces, including that they must now ensure the display of the CE mark, safety warnings, and a link to the digital product passport before purchase.

The agreement now needs to be formally agreed by both bodies. Once in force, the regulation provides for a 4.5 year transition period in order to give industry time to implement the new requirements.

Commission launches consultation on the Digital Product Passport

The European Commission has launched a public consultation on the future digital product passport. The aim of this is to gather stakeholder opinions on data storage and management by service providers and the necessity of a certification scheme for these providers. Feedback is to be made by 1 July 2025.

Sustainable products

UK

New simpler recycling rules for workplaces in England come into effect

On 31 March, new regulations for workplace recycling and waste management came into effect across England. These changes aim to simplify the process, boost recycling rates, and reduce waste sent to landfills or incineration.

Key points with regard to these measures:

• Applies to workplaces with 10+ employees.
• Requires separation of dry recyclables (plastic, metal, glass, paper/card), food waste, and residual waste.
• Offers flexibility in container size and collection frequency based on waste volume.

The Environment Agency has said it is committed to assisting businesses to ensure compliance with the regulations.

Future measures include by 2026, local authorities will standardise recyclable waste collection, including weekly food waste collections. Kerbside plastic film collections from workplaces and households will be introduced by 31 March 2027. Guidance on the new requirements can be found here.

HSE provides update on work into PFAS

The Health and Safety Executive (HSE) has published its UK REACH Work Programme 2024/25 which contains updates on its work into per-and poly fluoroalkyl substances (PFAS), aka "forever" chemicals. In summary, it outlines that work is to continue this year into PFAS used in firefighting foam and the HSE will continue to gather evidence and conduct stakeholder engagement of wider use and manufacturing of PFAS. The plan provides some timelines on projected date for earliest initiation of a restriction, with the restriction on PFAS in consumer products earliest date being 2026/27.

However, given the slow progress in this area and the fact that the HSE has not yet initiated any consultation on PFAS restrictions in consumer products, we consider it unlikely that the restriction will be implemented as early as 2026.

Government launches inquiry into the risk of PFAS

The UK government is taking steps to look at the impact of PFAS, having launched an inquiry into their use.

The inquiry will assess whether current measures are sufficient to mitigate PFAS risks, and evaluate the capabilities of research institutions and the Environment Agency in detecting and monitoring the impact of PFAS. Additionally, it will compare UK regulatory mechanisms with other jurisdictions, including the EU and USA. Evidence can be submitted until 26 May 2025.

With the EU already moving towards restricting the use of PFAS, the UK government is also now addressing this issue. The steps taken following the conclusion of this inquiry will be crucial in shaping the country's approach to managing PFAS risks.

England's circular economy

Last month, the Department for Environment, Food and Rural Affairs announced it would publish a new circular economy strategy in autumn 2025, building on the work of the Circular Economy Taskforce established in 2024. Defra has identified textiles, transport, construction, agri-food, and chemicals and plastics as the sectors with most potential for major economic gains from driving out waste.

EU

European Commission adopts working plan under Ecodesign for Sustainable Products Regulation

The European Commission has adopted its 2025-30 working plan for the Ecodesign for Sustainable Products Regulation and Energy Labelling Regulation. This set outs a list of products that should be prioritised to introduce ecodesign requirements and energy labelling over the next five years.

The first working plan focuses on four final products (textiles, furniture, tyres and mattresses), two intermediate products (iron and steel, and aluminium) and two legal acts setting out horizontal requirements (repairability and recycled content and recyclability of electrical and electronic equipment), in addition to a list of work carried over from the last ecodesign and energy labelling working plan.

Below are the products in which ecodesign requirements will be introduced over the next five years along with the timeline for their adoption. Once adopted and following the delegated act entering into force, the ESPR requires an 18-month transition period before it applies, except in duly justified cases.

The ecodesign requirements will set out both performance (such as spare parts, replacement, energy efficiency) and information (such as technical documentation, user manual) requirements that businesses will need to incorporate into their products.

Final products 

Final products are those directly used by consumers or businesses.

• Textiles/Apparel
  Indicative timeline: 2027
• Furniture
  Indicative timeline: 2028
• Tyres
  Indicative timeline: 2027
• Mattresses
  Indicative timeline: 2029

Intermediate products 

Intermediate products are used as components or raw materials in manufacturing final products.

• Iron and steel
  Indicative timeline: 2026
• Aluminium
  Indicative timeline: 2027

Horizontal requirements 

Horizontal requirements apply across multiple product categories to improve specific aspects like repairability or recyclability.

• Repairability (including scoring)
  Indicative timeline: 2027
• Recycled content and recyclability of electrical and electronic equipment
  Indicative timeline: 2029

Energy-related products 

These products are carried forward from the previous working plan and include:

• Low-temperature emitters - Adoption: 2026
• Displays - Adoption: 2027
• EV chargers - Adoption: 2028
• Household dishwashers - Adoption: 2026
• Household washing machines and household washer-dryers - Adoption: 2026
• Professional laundry appliances - Adoption: 2026
• Professional dishwashers - Adoption: 2026
• Electric motors and variable speed drives - Adoption: 2028
• Refrigerating appliances (including household fridges and freezers) - Adoption: 2028
• Refrigerating appliances with a sales function - Adoption: 2028
• Light sources and separate control gears - Adoption: 2029
• Welding equipment - Adoption: end 2030
• Mobile phones and tablets - Adoption: end 2030
• Local space heaters - Energy label: adoption in 2026; Ecodesign requirements: adoption mid-2030
• Tumble dryers - Adoption: end 2030
• Standby and off mode consumption - Adoption: end 2030

Digital product passport 

A key aspect of the ESPR is the digital product passport (DPP). Every product for which ecodesign measures will be adopted will have a digital product passport. The DPP will provide essential information about products, ensuring traceability and promoting sustainable trade. It will include details on material composition, substances of concern, and instructions for safe use, recycling and disposal.

Destruction of unsold goods 

The ESPR allows for future bans on the destruction of unsold products. Currently, this ban includes apparel, clothing accessories, and footwear and comes into effect on 19 July 2025. For the first working plan, the Commission does not intend to bring any more products within scope of this provision.

New rules to reduce plastic pellets losses

The European Parliament and Council have reached a provisional agreement on new measures aimed at preventing plastic pellets losses throughout the supply chain. The agreement includes:

• Entities handling over five tonnes of plastic pellets in the EU, as well as EU and non-EU transport carriers and maritime operators, must take specific measures to avoid losses.
• Economic operators must establish risk management plans for installations handling plastic pellets, including procedures to prevent, contain, and clean up spills. Compliance certification is required for installations handling more than 1500 tonnes of pellets annually.
• Labels, packaging, or safety data sheets accompanying plastic pellets should include a specific pictogram and warning statement.

The regulation will apply two years after its entry into force. The provisional agreement now has to be endorsed by both the Council and the Parliament.

Life sciences and healthcare

UK clinical trials regulatory reform

On 11 April 2025, the new clinical trials regulations were signed into law, marking the start of the 12 month implementation period. From 10 April 2026, the new regulations will come into effect aiming to strengthen patient safety, accelerate approvals, and boost innovation.

Key reforms include:

• Putting patient safety at the forefront.
• Cutting duplication and unnecessary delays.
• Creating a flexible regulatory environment including reducing bureaucracy for lower-risk trials.
• Aiming to reduce the time from application to first participant from 250 to 150 days.

Read more on the regulations in our January Regulatory Outlook.

MHRA issue statement on products containing CBD

The Medicines and Healthcare products Regulatory Agency (MHRA) has, on 14 April, issued a statement on products containing cannabidiol (CBD). The statement does not contain any new information but provides businesses with a useful reminder of the regulatory framework for products containing CBD. Two key messages are highlighted within the statement:

1. If marketing a CBD containing product that makes a medicinal claim, it will be considered a medical product and therefore companies must hold a marketing authorisation to sell, supply or advertise the product.
2. Companies need to be mindful that, if the product is not a medical product, it may need to comply with other regulatory frameworks, such as the novel food process.

For an overview of CBD legislation across Europe, see our report.