How does the PRAM Act 2025 impact the Food and Beverages sector?

Mine’s a Pint: How does the Product Regulation and Metrology Act 2025 impact the Food and Beverages sector?

Having received Royal Assent on 21 July 2025, the Product Regulation and Metrology Act 2025 (“PRAM”) provides wider powers for the Government to introduce further product regulations. The primary aims of PRAM are to protect consumers through the promotion of product safety, the enhancement of regulatory oversight of products in the UK and (according to the Office for Product Safety and Standards) seeking to ensure “ a level playing field between the high street and online marketplaces”.

Immediate changes

So what immediate changes has PRAM introduced to the Food and Beverages sector? The answer is: so far, not that much. But ultimately this is because PRAM is not intended to be a substantive piece of legislation that in itself introduces far-reaching changes, but rather it is an enabling legislation which provides the Government with a broad remit to introduce future regulations in relation to specific types of product issues, such as product labelling, and digital traceability as part of product safety.

In particular, PRAM has been enacted to provide the Government with the ability to introduce regulations which, with respect to the marketing or use of products within the UK, seek to:

• reduce or mitigate risks presented by products;
• ensure that products operate efficiently or effectively;
• ensure that products designed for weighing or measuring operate accurately.

While the majority of PRAM is focused on providing the Government with powers to introduce future product regulations, there are some immediate changes introduced which providers of Food and Beverages products should note, particularly regarding measurements.

Moreover, the reference to “Metrology” within PRAM is notable. For the uninitiated, metrology is the science of measurements, with the Office for Product Safety and Standards focusing largely on the application of legal requirements to such product measurements. A collective sigh of relief will have reverberated around the country at the inclusion of Section 5(4) of PRAM, as this effectively protects the “pint” measurement. The provision prevents the Government from placing any restrictions in future product regulations on the use of the “pint” measurement in the marketing of draught beer or cider, or milk in returnable containers. For those that need reminding, there is also the resounding answer to the age-old question heard in pubs as to what a true measurement of a pint is – PRAM confirms this is equal to 0.56826125 cubic decimetres.

Future implications

So what are the future implications of PRAM for the Food and Beverages sector? The answer is: potentially quite far reaching. Given the Government has scope to introduce regulations across fairly broad purposes i.e. product efficiency, weight and measurement accuracy, product marketing and product risk mitigation, suppliers of Food and Beverage products (with ‘products’ defined as a tangible item that results from a method of production) will need to ensure that they are actively monitoring any new regulations.

This is particularly important given PRAM also bestows the Government the ability to enforce product regulations through additional regulations, such as conferring certain investigatory powers on a relevant authority. Further, the Government is also able to introduce product regulations which make provision for certain sanctions for non-compliance with those product regulations, or potentially even the creation of criminal offences in relation to such non-compliance.

In addition, operators of online marketplaces which allow sellers of Food and Beverages products to make their products available through the marketplace to consumers, are likely to face new obligations under future secondary legislation through PRAM. The once ‘neutral’ provider of a digital marketplace may now have obligations as duty holders to: monitor and remove unsafe Food and Beverages products; ensure consumers are warned of risks; potentially be involved in Food and Beverages product recall; and co-operate with regulatory investigations into such products. Providers of online marketplace platforms and the sellers of Food and Beverages products which use the platforms as distribution channels will need to reconsider their relationships to ensure optimum operational practices given the changes PRAM has brought and will continue to bring.

Suppliers, distributors, providers of online marketplaces and marketeers of Food and Beverages products should therefore ensure they are actively monitoring the regulatory product landscape given the extensive powers the Government now has to enact relevant product regulation.

Simmons & Simmons has extensive experience in working with Food and Beverages organisations in identifying and responding to legal and regulatory risk. To discuss any product or regulatory concerns or learn more about the related services we offer within the Food and Beverages sector please contact Calum Murray, Joel Smith, Elinor Cavil, James Marsden or Fergus Nolan.