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      Executive summary

      On 27 July 2026, the UK’s Department for Business and Trade (DBT) announced a Call for Evidence to gather stakeholder views on a new UK Digital Product Record (DPR) policy.

      The Call for Evidence follows a significant uptick in the scrutiny of the safety of products sold on online marketplaces in the UK. In the last month, consumer group Which? reported that over 150 baby products were listed for sale on online marketplaces despite having warnings and product recalls; UK holiday makers have also been warned against travelling with allegedly dangerous products purchased across a range of platforms that failed to meet UK safety requirements. The UK government has recently consulted on a new product safety regulatory framework; while the responses to the consultation are yet to be published, the proposals are due to adopt a ‘digital-by-default’ approach and are therefore likely to form part of any new regulatory framework.

      A DPR system would be designed to enable businesses to store product information in a way that is easily accessible to those who need it. The introduction of a DPR system would follow in the footsteps of the European Union, which adopted the EU Digital Product Passport (EU DPP) in July 2026.

      Businesses that interface with supply chain related data management or have views on the adoption of the EU DPP and, potentially, a UK DPR are encouraged to engage with the UK’s Call for Evidence. Businesses should also consider to what extent the EU DPP and DPR may affect their own operations before the regulatory implications do bite.

      Lisa Navarro

      Head of Regulatory Law, KPMG Law

      KPMG in the UK

      Background

      DPRs and DPPs are rooted in a broader push for a more sustainable and traceable economy: by making product information transparent and easily accessible, it is in theory more achievable to drive circular economy practices, including a reduction in waste and empowering consumers to make informed purchasing decisions, including in relation to product safety.

      DPR systems enable businesses to store product information in a structured, accessible format. A DPR system is not a new concept: in the EU, the adoption of the Ecodesign for Sustainable Products Regulation in July 2024 established the legal basis for EU DPP, which became operational on 20 July 2026. The EU DPP serves as a digital identity card for products, components and materials, storing information that is accessible to consumers, businesses and regulators through unique identifiers – typically a QR code printed on the product or its packaging. Depending on the product, this may include details on safety, origin, materials, repairability, reuse, recycling and environmental performance.

      With respect to the EU DPP, the EU DPP Registry became operational on 20 July 2026, however specific information requirements will be introduced on a sector-specific basis in the coming months. Requirements for iron and steel will be adopted in Q4 2026, and the first of the EU’s DPP requirements will become mandatory from 18 February 2027 for certain types of batteries (including electric vehicles, light means of transport and industrial batteries). Construction products, service providers and textiles, aluminium and tyres will follow in 2027. Furniture and mattresses will follow in 2028 and 2029.

      While the UK DPR policy remains in a preliminary phase, the EU DPP regime is in force and will begin to apply to certain product categories in the near term. The EU DPP applies to all businesses that place physical goods on the EU market, regardless of where the company is legally headquartered. The framework does not just target the original manufacturer, but it explicitly distributes legal responsibilities across the entire supply chain. 

      The call for evidence follows the UK Government’s consultation on the new product safety framework which ran from March to June 2026. The new framework will seek to modernise the UK’s product safety regulatory framework to reflect modern products and supply chains, aimed at addressing issues identified in relation to the sale of unsafe products and how products could be sold via online marketplaces.

      Call for Evidence in the UK

      The DBT’s Call for Evidence is seeking views on the case for introducing a DPR architecture needed to provide product information digitally. This work builds on the Government’s intention to introduce a digital option for product compliance marking. The Government is also considering product-specific DPR requirements in more targeted engagements including surveys and consultations on batteries, construction products, toys and low carbon industrial products.

      The call for evidence seeks views from a broad range of stakeholders, including those operating in the consumer goods, industrial materials, manufacturing, technology, electronics, energy and transport sectors.

      Possible implications

      If a new DPR regime was adopted in the UK, businesses could be impacted in several ways. However, the extent of the positives and negatives will largely turn on the creation of a well-functioning DPR policy, if brought into effect:

      • Implementation

        The implementation and integration of a significant compliance change such as EU DPP or UK DPR cannot be understated, for example, integrating DPR requirements into existing IT systems and processes, training, labelling and physical compliance costs, updates to websites and customer facing information, as well as legal and support costs. These processes are not cost-free and may be significant in quantum. Ensuring a UK DPR policy is clear and business-friendly is vital to ensuring businesses are helped, rather than hindered, by such a framework. 

      • Efficiency and supply chain management

        DPR policy could reduce the compliance burden on businesses from a data gathering and supplier check list perspective. UK Government would need to ensure that UK DPRs capture a sufficient range of the data to ensure businesses reap the benefits of compliance efficiency.

      • Compliance

        Regulatory auditability and smoother customs processes may facilitate increased trade. However, this would require some level of cross-border alignment with UK trade counterparts both inside and outside the EU – ensuring that businesses do not have to duplicate compliance efforts. 

      The call for evidence also examines how the EU DPP may affect UK businesses. It asks whether businesses already collect or generate information that could be relevant to a DPR, and what costs they or their sectors may face in preparing for forthcoming EU DPP requirements. It also seeks views on the potential impact on consumers and whether additional safeguards or protections may be needed.

      What businesses should do now

      Based on the call for evidence, it is plausible to expect there to be some alignment between the UK DPR and EU DPP, at least in part. To ensure businesses are setting themselves up for success with respect to any incoming obligations, businesses should consider taking the following steps now:

      • Engage in the Call for Evidence

        The UK Call for Evidence has just been announced – the voice of businesses in the formation of a new policy is key to ensuring the regime works for businesses both inside and outside of the UK. 

      • Review technical standards and infrastructure

        Consider whether product numbering systems need to be updated (e.g., aligned to GS1 standards) and whether GS1 Digital Links may be appropriate to your business. 

      • Update contractual frameworks

        Ensure the contractual framework with suppliers is fit for purposes, including service level agreements (SLAs) to make the provision of verified, structured sustainability data mandatory. 

      • Product mapping and compliance timeframe

        If your business sells into the EU, map specific product categories against the phased rollout dates at EU level; this process should assist with compliance with a similar process if/when that becomes a relevant exercise in the UK.

      • Participate in pilot programmes and sandboxes

        The EU has launched a trial technical environment for the EU Registry. Understanding what works at EU level and reporting on that as part of the UK consultation could be invaluable to ensuring issues with EU systems are not played out within a UK framework.

      • Map upstream suppliers

        Track suppliers to ensure the business can obtain key information.

      • Data audit

        Set up internal auditing systems to check the accuracy of data handed down by supply chain counterparts before it becomes disclosable at EU or UK level.

      If your business would be interested in a discussion about the UK DPR or EU DPP, do let us know and one of our KPMG Law Consumer & Product experts will happily have a chat with you.

      Please contact our Consumer Regulatory Expert, Annalie Grogan.

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