Retail Snapshot Q2 – 2025
Tuesday 1st April 2025
Welcome to our latest Retail Snapshot
A summary key legal and regulatory developments impacting affecting retail businesses in Q2 2025.
What’s happening in Q2:
- National minimum wage increase
- Consumer protection laws enforced by Digital Markets, Competition and Consumers Act 2024
- Online Safety Act 2023
- FSA best practice on allergens for loose food
- Mandatory digital waste tracking delayed
- New set of standard contractual clauses due in Q2 2025
- The Fair Dealing Obligations (Pigs) Regulations 2025
- The Environmental Protection (Single-Use Vapes) (England) Regulations 2024
- UK Privacy and data protection adequacy decision review
- Product Regulation and Metrology Bill
- Buy-now, pay-later legislation expected
National minimum wage increase
On 1 April 2025, the latest increase in minimum wages in the UK have come into force. These are:
the National Living Wage (the minimum wage for over 21-year-olds) will increase to £12.21 per hour (from £11.44);
the Minimum Wage for 18-20 year olds will rise to £10.00 per hour (from £8.60); and
apprentice* pay will increase to £7.55 per hour (from £6.40).
Consumer protection laws enforced by Digital Markets, Competition and Consumers Act 2024
The consumer protection enforcement provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCC) have now come into force on 6 April.
This legislation aims to offer greater protection to consumers by giving powers to the CMA to fine non-compliant companies. Take a look at our comprehensive series of what the Act includes.
The Illegal Harms Codes of Practice became enforceable in March 2025.
Ofcom published its Children’s Access Assessments Guidance in January. All user-to-user and search services platforms are required to undertake children’s access assessments by 16 April.
The Act also introduces a system for categorising some regulated services based on characteristics. The providers of categorised services will be required to comply with additional duties if they meet certain thresholds. The Threshold Conditions Regulations came into force on 27 February 2025. Ofcom expects to publish the register of categorised services by summer 2025.
FSA best practice on allergens for loose food
The FSA published its best practice guidance for non-prepacked foods in late February 2025. This guidance is effective immediately.
All food businesses should review this best practice guidance and consider how they can implement it. It covers how to provide allergen information for non-prepacked foods in the most effective way and manner preferred by consumers which is;
- in writing, and
- supported by a conversation.
Non-prepacked foods include all foods that are not prepacked such as meals in cafés and restaurants, loose meat and cheese at a deli counter or drinks made to order in a coffee shop. It will be reviewed in September 2026.
Mandatory digital waste tracking delayed
The Department for Environment, Food & Rural Affairs’ (DEFRA) digital waste tracking system was due to be introduced, enabling the tracking of more than 200 million tonnes of waste across the UK digitally, instead of using hard copy waste transfer notes.
This has now been delayed until 2026.
New set of standard contractual clauses due in Q2 2025
This fifth set of Standard Contractual Clauses (SCCs) regulating transfers of personal data outside of the EEA are intended to complement the existing model clauses, and cover data transfers to third country importers in restricted territories that are directly subject to the GDPR. These are EU transfer documents, but it is likely that the UK will follow suit with a UK addendum in the same way as the existing international transfers process.
The Fair Dealing Obligations (Pigs) Regulations 2025
The Government is starting to introduce specific regulations on different areas of agricultural products. The next set of regulations will be regarding the selling of pigs, soon to be followed by regulations on eggs and produce. The Regulations were laid before Parliament in March 2025 and are likely to be approved by May, coming into force in late August or early September.
The Environmental Protection (Single-Use Vapes) (England) Regulations 2024
The Government has introduced a ban on the sale and supply of single-use vapes in England, to start on 1 June 2025. The Scottish Government and Welsh Government have also confirmed they intend to introduce legislation to the same effect.
UK Privacy and data protection adequacy decision review
The European Commission proposed to extend the effect of the adequacy decision for the UK by six months to 27 December 2025. It is thought that the extension is to allow time for the Data (Use and Access) Bill to receive Royal Assent before any adequacy decision is given.
Product Regulation and Metrology Bill
The Bill is currently progressing through Parliament, and is now likely to become law in the middle of 2025.
This proposed law would give the Government the power to introduce secondary legislation concerning product safety and standards much faster and autonomously than existing laws allow; to keep up to date with emerging risks that come with new products particularly in the technology sector. These powers would allow the Government to make regulations concerning a product’s marketing, use, provision of information to consumers and the monitoring and certification of products, to name a few. A key purpose of the law will be to address the disparity on ensuring products sold via online marketplaces are captured by product safety standards.
Buy-now, pay-later legislation expected
Users of these schemes will be given stronger rights if issues arise with products they purchase, making it quicker and easier to get redress. This includes applying Section 75 of the Consumer Credit Act, which allows consumers to claim refunds from their lender, and access to the Financial Ombudsman Service to make complaints.
Legislation is expected to be laid midway through 2025.
If you would like to discuss any of these changes in more detail, please get in touch with one of our retail specialists.
