Jurisdiction(s):
United Kingdom

UK/EU product regulation divergence post-Brexit: comparative guide to liability, safety, corrective actions, standards and conformity marking, including Northern Ireland and forthcoming EU GPSR and PLD reforms

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Practice notes

This Practice Note presents a concise overview of the principal areas where UK and EU product regulation have diverged since the UK’s departure from the EU on 31 December 2020 (IP Completion Day). It examines differences relating to product liability, product safety, remedial measures (including product recalls), and standards and conformity marking for general consumer products.

Background

Before the Brexit transition ended, UK product regulation was largely aligned with the EU, as significant domestic rules on product liability and product safety originated from EU law, including:

the Consumer Protection Act 1987 (CPA 1987), which implemented Directive 85/374/EEC on liability for defective products (the EU Product Liability Directive or EU PLD) into UK law
the General Product Safety Regulations 2005 (GPSR 2005), SI 2005/1803, which implemented Directive 2001/95/EC on general product safety (the EU General Product Safety Directive) into UK law

Since IP Completion Day, divergence has increased as the EU has advanced new legislation, while UK law has not progressed in parallel with those EU developments. It is also worth noting that, from IP Completion Day, Northern Ireland...

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Web page updated on 22/05/2026

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