Product & Consumer Protection Annual Review 2025

In the six months since the publication of our 2025 Mid-Year Review, the pace of change in EU product and consumer protection law has remained high. Regulators have continued to refine how new rules are applied in practice, while several long-anticipated reforms have moved closer to implementation. For businesses placing products on the EU market, this has meant tighter expectations, more technical compliance obligations and increased scrutiny from authorities.

As we look ahead to 2026 and beyond, the regulatory environment for products is set to become even more demanding. Safety, sustainability, intellectual property and chemical compliance are all converging into a more complex framework that requires careful planning and strong internal governance.

In this edition of our Product & Consumer Protection Annual Review, we review the most important developments from the past year and look ahead to what future reform will mean in practice for manufacturers, brand owners, distributors and retailers.

What we cover in this edition

This year’s Review includes analysis and guidance on:

• The recent publication of the guidelines on the General Product Safety Regulation, and what they mean for risk assessment, recalls and market surveillance

• The overhaul of toy safety regulation in the EU, including new obligations for economic operators and supply chains

• Developments in the doctrine of exhaustion in trade mark rights, and the implications for parallel trade and resale

• An update on sustainability and product regulation, including how environmental and consumer law are increasingly intersecting

• The EU-wide ban on TPO, a substance commonly used in gel nail products, and what this means for cosmetics and beauty product suppliers

Together, these topics reflect how product regulation is moving beyond traditional safety rules into a broader framework covering sustainability, chemicals, IP and consumer protection.

Download the Annual Review

Our 2025 Annual Review is available as a PDF and is designed for easy internal sharing across legal, regulatory, technology and commercial teams.

For more information and expert advice, contact a member our of Products team.

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The content of this Annual Review is provided for information purposes only and does not constitute legal or other advice.