The UK Government has now formally launched the next phase of reform under the Product Regulation and Metrology Act 2025 (the Act), publishing three parallel consultations aimed at modernising the UK’s product safety, market surveillance and enforcement framework. These consultations close on 23 June 2026.
While one consultation relates specifically to upholstered furniture fire safety, two of the three consultations are directly relevant to lithium‑ion battery safety, including e‑bikes, e‑scooters and conversion kits – an area of growing and acute concern for both property and motor insurers, particularly given the rising incidence of severe property fires originating from battery thermal runaway.
The Government’s accompanying Ministerial Statement makes clear that lithium‑ion battery fires are a key driver for reform, explicitly referencing fatalities and serious injuries linked to e‑bikes and similar products.
Keoghs will be responding to the consultations insofar as they relate to lithium‑ion battery fire risk, market controls, and enforcement capability, and we encourage insurers to consider whether they wish to feed views through us.
Lithium‑ion battery fires present a distinct and escalating property fire risk, with characteristics significantly different from traditional combustion fires:
Evidence provided during the passage of the Act, and repeated publicly since, demonstrates the scale of the risk. The London Fire Brigade (LFB) has consistently stated that it now attends a lithium‑ion battery fire involving an e‑bike or e‑scooter every other day on average in London. LFB data confirms that e‑bikes and e‑scooters are the leading cause of battery fires, accounting for over half of incidents in the year to January 2026.
1. Product Safety Framework – Consultation
This consultation proposes a wholesale restructuring of the UK product safety framework, widening scope and modernising the concept of ‘product safety’ to reflect emerging technologies and hazards.
Key proposals include:
Critically, the consultation contains a dedicated 'Spotlight' on lithium‑ion batteries, expressly referencing e‑bikes, e‑scooters and conversion kits, and the risk of thermal runaway linked to incompatible or non‑compliant chargers and batteries.
Question A8 directly invites views on further action needed to ensure lithium‑ion battery safety.
The consultation also confirms that the Office for Product Safety and Standards (OPSS) has commissioned BSI to develop a fast-track Publicly Available Specification (PAS) covering battery systems for e‑bikes, e‑scooters and conversion kits. The PAS is expected to:
The PAS is expected to be published in 2026, with the intention that it may be formally designated under product safety legislation.
2. Market Surveillance and Enforcement Framework – Consultation
This consultation addresses longstanding weaknesses in the enforcement of product safety law, including fragmented powers and over‑reliance on criminal sanctions.
Proposals include:
For insurers, this raises the prospect of more effective market controls on high-risk products, but also greater regulatory scrutiny of supply chains implicated in significant loss events.
3. Fire Safety of Domestic Upholstered Furniture – Consultation
This consultation proposes reform of the Furniture and Furnishings (Fire) (Safety) Regulations 1988, including a move away from open‑flame testing. It is not directly relevant to lithium‑ion battery‑related risk, although it reflects the Government’s broader focus on modernising fire safety regulation.
During stakeholder discussions on the Act, including conversations we previously held with Lord Foster, it had been anticipated that Government would publish a formal statement setting out how products presenting higher risk would be identified and graded, alongside the consultations.
To date, no standalone risk‑grading statement has been published.
Instead, Government appears to be relying on:
While helpful, this approach raises questions around how quickly high‑risk products will be identified, and how consistently risk gradation will be applied across sectors – issues of obvious relevance to insurers exposed to rapid‑loss fire events.
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