ICPHSO 2025: Key takeaways on product safety & regulation

The Autumn 2025 ICPHSO conference brought together regulators, industry leaders, legal experts, and consumer advocates to discuss the rapidly evolving landscape of product safety. With a central theme of "adapting to change", the sessions explored the impact of technology, regulatory developments, and global collaboration on consumer protection. Set out below are my main takeaways from certain talks. Find the event website here for more details.

1. Adapting to change: The regulatory perspective

Sarah Smith (OPSS) opened the conference by emphasising the need for regulatory frameworks to keep pace with technological and market changes. The OPSS, now well-established within the Department for Business and Trade, is focused on enabling growth while ensuring consumer safety. Key challenges include the rise of online marketplaces, the integration of AI, and the need to simplify compliance for businesses without compromising protection.

Key message: Regulators must balance innovation and consumer protection, ensuring that online and offline shopping are equally safe.

2. Compliance culture: beyond the paper programme

A fireside chat with Eric Holder Jr (former US Attorney General) and Sarah Wilson (Covington & Burling) highlighted the importance for compliance to be embedded in corporate culture. Holder emphasised that "compliance combined with innovation is how to maximise the bottom line with the least amount of risk", highlighting that robust compliance should be seen as a driver of sustainable business, not a barrier.

The discussion also stressed the value of proactive engagement with regulators, advocating for open dialogue and the cultivation of "good relationships with regulators before a crisis happens". Such collaboration, in non-adversarial settings, can help organisations better understand expectations and respond effectively when issues arise.

In the face of rapid technological change, Holder noted that regulators and businesses alike must "deal with new tech but have to work out how to apply old values to that." The key is to remain conversant with technological change, while ensuring that the core principles of safety and responsibility continue to underpin decision-making.

Key message: Compliance and innovation are not mutually exclusive; robust compliance can enhance profitability and reduce risk.

3. AI and product safety: opportunities and challenges

A dedicated panel highlighted how AI is now routinely used across sectors to improve product safety and compliance, from screening listings to analysing customer feedback and detecting hazards. The technology has moved beyond simple keyword matching to intelligent, context-aware analysis-enabling deeper understanding of risks, such as identifying ingestion hazards from consumer reports.

Notably, the European Commission's eSurveillance Webcrawler automates the monitoring of online product listings with high accuracy, while AI is also used to proactively detect early warning signs from consumer feedback. This marks a shift from basic controls to anticipatory protection, with ongoing integration and international cooperation seen as vital for keeping pace with market complexity.

Key message: AI is transforming product safety, enabling smarter, faster, and more collaborative risk management, while augmenting human judgment, streamlining compliance, and enabling proactive risk strategies - but responsible use, human oversight, and international cooperation remain essential.

4. Global perspectives: Latin America and regulatory fragmentation

A session on Latin America revealed significant challenges due to fragmented regulatory systems, informal markets, and varying standards. Coordination and collaboration efforts, rather than the more ambitious full harmonisation, was seen as a pragmatic first step. Informal and digital markets pose particular risks for lower-income consumers, who may be exposed to unsafe products.

Key message: Building trust, improving transparency, and enhancing coordination are critical for raising safety standards in diverse markets.

5. Sustainability and the circular economy

The shift towards sustainability and circularity in product design and packaging introduces new safety challenges, such as contaminants in recycled materials and the risk of counterfeiting. Consumers expect recycled products to be as safe as new ones, so clear communication and robust testing are essential-though the financial burden of compliance can be significant. Digital product passports and supply chain transparency will help address these risks, while the right to repair must be balanced with safety and technician competence. Ultimately, effective alignment on standards and adequate enforcement are crucial for progress.

Key message: Achieving a balance between sustainability and safety will require alignment on standards, simplification of requirements, sufficient funding for enforcement, investment in testing and supply chain transparency.

6. Risk Assessment: A dynamic and ongoing obligation

The General Product Safety Regulation (GPSR) introduces a more dynamic approach to risk assessment, requiring manufacturers to assess risks not only before market entry but throughout a product's lifecycle. Companies must now systematically review consumer complaints and real-world product use, updating risk assessments as new information emerges. The GPSR also mandates keeping and investigating a register of complaints, with an emphasis on using digital tools and AI to analyse feedback from diverse sources. Robust documentation of risk assessment processes is essential, particularly as the revised Product Liability Directive will make this evidence increasingly important in liability cases. This shift underscores the need for continuous, data-driven risk management in the EU regulatory environment.

Key message: EU regulation now requires ongoing, proactive risk assessment throughout a product's lifecycle, making continuous monitoring and documentation essential for compliance and liability protection.

7. Digital safety and cybersecurity

With the proliferation of connected products, cybersecurity is now a core aspect of product safety. The UK's PSTI Act is a leading example, but high rates of non-compliance highlight the need for ongoing education and enforcement. As Manny Dekermenjian, Product safety manager at Google described it, "traditionally you interact with a product, turn it on and off. Sometimes a hazard may develop, like a short circuit. But in a connected world, maybe someone else interacts with the product. How does that interaction, and ability to hack in, present hazards?" This shift means that risks now include not only traditional hazards, but also those arising from remote access and malicious interference. Companies must therefore adopt a culture of continuous compliance, integrating cybersecurity risk management into their product safety strategies to protect both consumers and their own liability in an evolving regulatory landscape.

Key message: As products become increasingly connected, cybersecurity must be integrated into product safety risk assessments, with clear responsibilities across the supply chain.

8. Packaging regulation and extended producer responsibility (EPR)

The new EU Packaging and Packaging Waste Regulation (PPWR), which came into force on 11 February 2025 and is effective from 12 August 2026, introduces ambitious targets for recyclability, labelling, and minimising substances of concern. From 2030, all packaging must be recyclable, with strict criteria on material separation, labelling, and the minimisation of hazardous substances such as PFAS. Recyclability will become a condition for market access, and packaging that does not meet minimum performance grades will be prohibited; "if you cannot show you meet requirements, you're not allowed to place on the market".

The regulation also introduces harmonised labelling to help consumers sort waste correctly, and mandates clear identification of substances of concern. From 2030, extended producer responsibility (EPR) fees will be controlled based on recyclability and recycled content, incentivising sustainable design and material choices.

Key message: The PPWR will make recyclability and transparency non-negotiable for packaging, requiring companies to redesign, relabel, and document packaging to meet strict new EU standards by 2030. Compliance will become a condition for market access, meaning businesses must prepare now for significantly stricter requirements.

9. Online marketplaces: proactive safety management

Online marketplaces (OMs) are under increasing scrutiny to prevent the sale of unsafe products. The UK's PRAM Act introduces a general duty on OMs, with calls for more rigorous checks and better communication with consumers. Collaboration between regulators, marketplaces, and consumer groups is essential, and growing, and the PRAM Act's clear legal definitions support stronger enforcement.

OMs are increasingly using AI to detect unsafe or non-compliant products and provide further safety information on products they purchase. As Ryan Radford from Amazon noted, "we're working at scale to parse hundreds of millions of product listings, with billions of changes every day."

Key message: Online marketplaces will increasingly face proactive safety duties and stricter enforcement, meaning compliance and proactive, collaborative approaches are essential to address the scale and complexity of online product safety

10. Product liability and the new EU PLD

The forthcoming EU Product Liability Directive (PLD), coming into force in December 2026, will significantly alter the liability landscape for producers, distributors, and online marketplaces. Key changes include a presumption of causation in technically complex cases, expanded disclosure obligations, increased litigation risk and more class actions. Companies must prepare for overlapping requirements with the GPSR, manage sensitive data carefully, and ensure robust internal processes to navigate these heightened compliance and liability challenges.

Key message: The new PLD will make it easier for claimants to bring product liability cases and increase disclosure and litigation risks, making proactive compliance, documentation, and data management essential for all businesses in the supply chain.

Conclusion

The ICPHSO conference underscored the need for agility, collaboration, and innovation in product safety. As technology, markets, and regulations evolve, all stakeholders, regulators, businesses, and consumers, must work together to ensure that safety keeps pace with change. Simplification of regulations, transparency, and proactive risk management are recurring themes, with AI and digital tools offering both opportunities and challenges for the future.