The Product Regulation and Metrology Act 2025 (PRAM) gives ministers broader powers to update the UK’s product rules.
Although food is excluded from the Act’s direct scope, food and drink manufacturers should not ignore it. By reshaping how product rules are made across the wider market, PRAM can affect online sales oversight, measurement standards and the UK’s approach to aligning with the EU, as well as influencing how food businesses operate in practice.
Against that backdrop, the real question for the food and drink industry is not whether change will come, but how quickly, and how ready your business is to respond.
Why PRAM?
PRAM was introduced to modernise the UK’s product regulation framework and give the Government greater flexibility after Brexit. In particular, it allows ministers to align UK rules with EU standards where that makes sense, or to introduce different UK requirements where a separate approach is considered appropriate.
For food manufacturers trading across both markets, that flexibility has practical consequences. Alignment can simplify compliance by allowing the same specifications and packaging to be used in the UK and the EU. Divergence, by contrast, may mean operating under two regulatory systems, increasing complexity and cost. Decisions will be taken case by case, but the key point is that the UK is no longer obliged to mirror EU product rules and may take a different path over time.
Looking ahead, we expect PRAM to begin addressing gaps in the current regime, particularly in relation to online sales. The Government has previously acknowledged concerns about unsafe products sold through online marketplaces and has indicated that platforms should be more accountable, bringing them closer in line with traditional retailers. Therefore, PRAM provides the mechanism to introduce regulations in this area if needed. If those powers are used, manufacturers supplying online channels may face greater scrutiny and more detailed requests for product information or compliance evidence.
How PRAM works
At its core, PRAM gives ministers the power to amend and replace large parts of the UK’s product regulation framework through secondary legislation. In practical terms, that means detailed rules on product standards and measurement can be introduced or amended without passing a new Act of Parliament each time.
Those changes are not limited to one part of the market and may apply across the product lifecycle, potentially affecting manufacturers, importers and businesses selling products online, depending on where the Government considers risk to sit within the supply chain.
PRAM also expands ministerial powers over weights and measures, allowing new rules on how quantities are calculated and presented to consumers. For manufacturers, this could lead to changes in how net weight or volume appears on packaging, or in how measuring equipment is checked and verified. The continued use of pints for draught beer and milk in returnable containers is preserved, but the overall framework for measurement is now more flexible.
It is also important to understand how PRAM doesn’t work. PRAM does not amend the substantive law on product liability or create new causes of action; its role is to enhance regulatory oversight rather than reshape the civil liability framework. However, shifts in regulatory scrutiny can still materially influence how businesses evaluate and manage their risk exposure.
What happens next?
While no new regulations have yet been introduced under PRAM’s powers, the mechanism is now in place and, when the Government decides to act, it will be able to amend standards more readily than before. For food and drink manufacturers, that increases the importance of reviewing how regulatory change risk is managed across the business.
The first area to consider is contractual exposure, as many supply agreements assume that regulatory standards will remain stable over the life of the contract. If standards change mid-term and require reformulation, relabelling or packaging adjustments, the additional compliance costs may not be shared. Manufacturers should therefore review how change-in-law clauses operate and whether price adjustment or variation provisions offer sufficient protection.
Where production and packaging decisions are fixed well in advance, even a modest regulatory change can cause disruption. This means manufacturers should consider how quickly specifications could be updated and how existing stock would be managed if standards shift.
PRAM strengthens the wider inspection and enforcement framework, which means regulators may have clearer routes to intervene where standards are not met. In that context, clear documentation of measurement processes, labelling controls and internal checks becomes essential, not only to demonstrate compliance but to manage reputational risk if questions arise.
PRAM does not create immediate food-specific obligations, but it alters the pace and structure of regulatory change. The practical response is to treat regulatory flexibility as a standing commercial risk and to ensure that contracts, governance processes and operational planning are capable of absorbing change without significant disruption.
About the author
Andrew Walker is partner in the media, manufacturing and technology team at law firm, Morton Fraser MacRoberts.
