The Product Safety and Metrology Bill, currently progressing through Parliament, represents the most significant overhaul of UK product safety law since the General Product Safety Regulations 2005. For businesses that manufacture, import, distribute or retail consumer products in the UK, understanding what is changing — and when — is essential planning.
Why the Bill is needed
UK product safety law has largely been inherited from EU directives and implemented through a patchwork of regulations covering specific product categories. Since the UK’s departure from the EU, there has been a recognised need to consolidate this framework into a single, coherent piece of domestic legislation that can be updated more flexibly as technology and markets change.
The Bill also responds to the growth of online marketplaces, which have created significant gaps in existing enforcement frameworks — particularly where products are sold directly to UK consumers by overseas sellers through platforms that have not traditionally been treated as responsible economic operators.
Key changes for businesses
Several provisions are particularly relevant for businesses with recall obligations:
• Online marketplace liability. The Bill introduces clearer obligations on online marketplaces to remove unsafe products and cooperate with recall actions. For businesses selling through third-party platforms, this changes the relationship with those platforms and may affect how recall communications need to be coordinated.
• Expanded OPSS enforcement powers. The Office for Product Safety and Standards gains stronger powers to require recall actions, impose civil monetary penalties and publish details of enforcement decisions. The reputational dimension of enforcement is becoming more significant.
• Economic operator definitions. The definition of who bears responsibility for product safety in the supply chain is being updated to reflect modern distribution models. Importers, fulfilment houses and online sellers face clearer obligations.
• Consumer redress. The Bill strengthens consumer rights in relation to unsafe products, which has implications for how businesses communicate during a recall and what remedies they offer.
What this means for recall communications
The Bill raises the bar on what constitutes adequate recall communication. The expectation — increasingly explicit in OPSS guidance — is that businesses should be able to demonstrate that their recall reached affected consumers effectively, not just that a notice was published.
This shift toward outcome-based assessment of recall communications is consistent with what insurers and ESG frameworks are already asking for. The legal direction of travel and the commercial direction of travel are aligned: businesses need to show reach, not just publication.
Timeline and preparation
The Bill is expected to receive Royal Assent in 2025, with implementing regulations following over the subsequent 12-24 months. Businesses should use this window to review their recall management processes, ensure they have documented procedures in place, and consider how recall activity will be evidenced for regulatory, insurance and ESG purposes.
ESGMessages.com helps businesses publish recall notices through a third-party platform, generating dated records and reach data that support compliance with the evolving regulatory framework. Contact us to discuss how we can help you prepare.
Published by ESGMessages.com — helping UK businesses turn recall obligations into ESG proof points.