The Product Regulation and Metrology Act 2025: A game-changer for online marketplace retailers

On 21 July 2025, the Product Regulation and Metrology Act 2025 received royal assent and represents the most significant overhaul of product safety regulations in the UK for decades.

For online marketplace retailers it means a radical overhaul to bring them into the regulatory framework to impose obligations on them to ensure products are safe for the final consumer, and sanctions if they fail to comply. 

It should bring online marketplaces into line with high street, physical, retailers setting a level playing field that ensures every part involved in the sale of consumer goods has a responsibility to ensure products are safe.

The devil, as always, will be in the detail. We know online marketplaces are a priority for the government and the regulators who oversee product safety, and the expectation is that this will be the first priority for the necessary secondary legislation that will bring these changes into law.

Revolutionary online marketplace provisions

Direct regulation of online platforms

One of the most significant aspects of the Act is its explicit recognition of online marketplaces as regulated entities. It introduces unprecedented obligations for platform operators. It means that online platforms will face direct regulatory obligations just like other retailers.

The range of online marketplace duty holders includes:

• those who control access to the marketplaces,
• those who control the marketplace content, and/or
• those who function as an intermediary for the person who controls access or the contents.

Seller responsibilities on marketplaces

Online marketplace sellers face comprehensive new obligations. Product requirements may be imposed on persons who market a product in the UK, and persons who import a product into the UK for it to be marketed or used in the counrtry. This creates a dual layer of responsibility between platform operators and individual sellers.

Comprehensive product safety framework

Risk-based approach

A product presents a risk if, when used for the purpose for which it is intended or under conditions which can reasonably be foreseen, it could endanger the health or safety of persons, endanger the health or safety of domestic animals, endanger property (including the operability of other products), or cause, or be susceptible to, electromagnetic disturbance.

Extensive product requirements

The Act empowers regulators to impose requirements covering virtually every aspect of product lifecycle. Product regulations may include requirements in relation to the production, component, composition or other characteristics of products, the installation of products, the use of products, the marking of products, and the provision of information (including information about risk) in relation to products.

Enforcement powers and penalties

Robust enforcement framework

The Act grants extensive enforcement powers to relevant authorities enabling regulators to monitor compliance, investigate suspected non-compliance, secure compliance and mitigate the effect of non-compliance with product regulations.

Those powers are supported by the power to enter, search and inspect premises, seize and retain products or evidence, to require the production of documentary evidence and the power to dispose of a product or require its disposal by the online marketplace.

The regulators can compel online marketplaces to warn others of risks presented by a product, require the marking of a product in respect of risks presented by it, prohibit the marketing or use of a product, and require the recall of a product or its withdrawal from the market.

Criminal and civil sanctions

The Act provides for both criminal and civil enforcement. The details that will apply to online marketplaces will be set out in secondary legislation, but if they follow a similar pattern to that adopted under the digital markets, the Competition and Consumer Act 2024 it is likely to include civil monetary penalties. There will always be the option for the regulator take criminal enforcement action that carries the risk of imprisonment and/or financial penalties imposed by the courts.

What's next?

We expect secondary legislation setting out the substantive requirements regarding online marketplaces to be introduced but the first stage with be a consultation, possibly as early as 2026. We will keep you updated with any developments in the coming editions of Retail Roundup.

There will be a need to review supply chains and ensure that contractual arrangements reflect the complexity of the regulatory regime for products and the broad range of duty holders. Once we know more about the details, we will share with you our thoughts on the pro-active steps you can take to protect your business.