Consumer law | UK Regulatory Outlook June 2025

Amendments to Price Marking Order  

On 14 May 2025, the Price Marking (Amendment) Order 2025 was made.  

The 2025 Order amends the Price Marking (Amendment) Order 2024, which in turn amended the Price Marking Order 2004 (PMO). The PMO sets out the pricing information that a trader, whether online or offline, must include on price labels for the goods it is selling. The 2024 Order aimed to make it easier for consumers to identify and compare selling and unit prices and to make compliance with the PMO simpler for businesses. See this Regulatory Outlook for a detailed list of amendments. 

The 2025 Order has now been made to make minor amendments in response to business, consumer group and enforcer feedback. It results in changes to: 

• The date when amendments under the 2024 Order come into force from 1 October 2025 to 6 April 2026.
• Article 5 of the PMO to add a reference to regulations 5, 6 and 7 of the Weights and Measures (Packaged Goods) Regulations 2006 and article 9 of the EU Consumer Food Information Regulation to extend the obligation to indicate unit price to additional products required to be marked with an indication of quantity or made up in a prescribed quantity. This includes food and non-food packaged goods, such as cereal, pasta and dried fruit, detergents, cleaning products and cosmetics.
• Article 9 of the PMO to specify that a trader may only use general reductions notices when it is not reasonably practicable to alter existing labels to show the reduced selling or unit price for each item. The details of the discount must be easy to see, understand and read.
• The exemption from having to display a unit price for products sold as an assortment in Schedule 2(3) of the PMO to clarify that offers encompassing items sold at different weights or volumes, and at different prices when sold separately, are also not subject to unit pricing requirements. 

The changes under the 2025 Order come into force on 30 September 2025. 

Online marketplaces may be subject to additional obligations relating to electrical and electronic equipment 

The draft Waste Electrical and Electronic Equipment (Amendment, etc.) Regulations 2025 propose shifting the financial responsibility for dealing with electrical and electronic equipment (EEE) waste (WEEE) from overseas sellers, who supply to UK households via online marketplaces, to those online marketplace operators.  

Currently, under the 2013 WEEE regulations, businesses that place EEE on the market in the UK are considered "producers", meaning they are subject to financial obligations in the regulations, irrespective of whether they are based in the UK. They must join a Producer Compliance Scheme (PCS) or appoint an authorised representative in the UK to do so. The government is concerned that such non-UK suppliers avoid these obligations by not registering with a PCS or appointing a representative.  

The new WEEE regulations would make online marketplace operators the "producers" responsible for EEE placed on the UK market by non-UK suppliers via their platforms. These operators will need to register with a PCS, submit data on the EEE volumes placed on the market by non-UK suppliers on their platforms across all EEE categories, and assume responsibility for the financial obligations in the new regulations. The aim is to ensure a fairer distribution of costs for the "collection, treatment, recovery and environmentally sound disposal of WEEE".  

Additionally, the new WEEE regulations propose a new EEE category for devices used to consume tobacco, nicotine, vape fluid and similar substances, including e-cigarettes, vape and heated tobacco products. See also the Products section.