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Comment & Opinion

Manufacturing Horizon Scanner: October 2025

“Security – whether in relation to technology and data, or in relation to geopolitics and its effect on supply chains, sites or staff – is high on the manufacturing board agenda, alongside tech innovation and the ongoing drive for sustainability, transparency and accountability. Our cross-discipline, sector-focused specialists are helping UK and global manufacturing clients to steer a steady, successful and compliant course through an otherwise unsettled climate.”

James Crayton, Partner, Head of Commercial
James Crayton

Manufacturing & Supply chain

The House of Commons Joint Committee on Human Rights has published its report on forced labour in global supply chains. The report finds that the UK’s current legal and regulatory frameworks are inadequate for confronting the complexity of abuses in global supply chains. It makes various recommendations, and the government’s response is awaited imminently. This is ‘one to watch’.

A new report from the Global Safety Evidence Centre shows that manufacturing workers are increasingly at risk from harm posed by climate change (severe weather, high temperatures and water shortages). Rising temperatures are a key highlighted concern. The report states that outdoor workers in agriculture and construction, as well as indoor workers, especially in poorly ventilated environments, are most affected by excessive heat.

Those in manufacturing were found to be particularly at risk of harm from increased machinery and factory wear and tear due to higher temperatures and humidity, especially garment and textile workers, those operating heavy machinery or chemicals, and workers in regions most affected by rising temperatures and flooding. The report calls for more knowledge-sharing and research into the most effective ways to protect workers.

UNICEF and the International Labor Organization has published a report which finds that 138 million children around the world are involved in child labour, including 54 million children engaged in hazardous work likely to jeopardise their health, safety, or development. The sector with the largest number of child labourers is agriculture, with factory work and mining also having significant numbers.

ETQ has published its second annual global survey, the ETQ Pulse of Quality in Manufacturing. As reported in The Manufacturer, the survey reveals: persistent labour shortage; increasing investment in automation, AI and predictive analytics; increased focus on quality as a strategic driver; and continuing challenges associated with product recalls and safety incidents.

The safety of machinery and construction products

The EU regime regulating the safety of product machinery is currently contained in the Machinery Directive. From 20 January 2027, the Machinery Regulation will replace the Machinery Directive. It will introduce changes to health and safety requirements, including related to software and machines with self-evolving behaviours.

It contains expanded responsibilities for manufacturers, importers and distributors; introduces enhanced conformity assessment procedures for products presenting high levels of risk; and provides for common specifications and paperless documentation. The UK government is consulting on whether to introduce the same measures in the UK.

Manufacturers might be aware of the Construction Products Reform Green Paper on wide-ranging plans for future regulation of construction products. Proposals include bringing all construction products within the general product safety regime; enhanced regulatory, surveillance and enforcement powers; development of a new single Construction Products Regulator; and civil and criminal penalties for manufacturers that engage in misleading practices or neglect their responsibilities regarding product safety.

The government has said that the paper is the first step in what will be a proactive process of engagement and consultation across the system in the medium to longer term. The Chartered Institute of Building, in collaboration with various construction industry bodies has published the Guide to Products Critical to Safe Construction – a new resource which aims to signpost best practice, raise awareness of compliance standards, and provide advice on how to determine if a product is critical to safe construction. It’s likely to be of value across the manufacturing and build spectrum, from product and project design and manufacture, to contracting and development/employment.

construction work on new build homes ensuring a rights of light

 

The impact of Digital Product Passports

The European Union’s Digital Product Passport (DPP) initiative was introduced in 2024 with the aim of enhancing transparency and sustainability across product value chains. Originating from the European Union’s Ecodesign for Sustainable Products Regulation (ESPR), the DPP aims to create a standardised, digital record for products, capturing comprehensive details about their origin, materials, environmental impact, and end-of-life disposal.

Companies will be required to understand and gather data for each stage of their value chain, and to provide greater transparency on product lifecycles. DPP requirements are expected to apply as of 2027 or 2028.

The move to using DPPs will impact on UK manufacturers and product suppliers operating in or with EU states. Many product suppliers to the UK construction sector are headquartered in Europe are likely to want to run one DPP system across all their products in Europe and the UK. There are also currently questions as to whether the UK government will adopt or align with the DPP initiative. It’s one to watch.

We’ve reported previously on the UK government’s drive towards a circular economy. The move from a linear economy, where products are discarded following use, to a circular economy that keeps materials in use for as long as possible, is a significant challenge facing the manufacturing industry, but ‘remanufacturing’ can play a critical role. Remanufacturing involves delivering high-integrity components that meet or exceed original specifications, offering more value than simply recycling, and reusing the core materials.

A lack of product data, resulting in cost-intensive reverse engineering, is preventing many businesses from scaling a circular approach. The Manufacturer (1 September 2025) has anticipated that DPPs (see above) could become a key enabler of remanufacturing and the circular economy.

Consultation on modernising environmental permitting for industry

The Environment Agency and the Department for Environment, Food and Rural Affairs are consulting on wide-ranging reforms to the environmental permitting regime for industrial emissions in England. The proposals cover: innovation and tech; agile standard setting; proportionate, coherent regulation; and effectiveness, efficiency and transparency of regulation.

The UK government has announced the suspension of extra border checks on live animal imports from the EU and specific animal and plant products from Ireland/Northern Ireland. It comes ahead of a new sanitary and phytosanitary (SPS) deal with the EU which aims to make the trading of food cheaper and easier, and strengthen food supply chains.

A risk-based approach is being adopted to manage biosecurity. (This suspension follows the announcement in June that checks on medium risk fruit and vegetables from the EU would be suspended until end of January 2027.) The precise terms of the SPS agreement are still to be finalised.

Following several months of high inflation rates, the Food and Drink Federation (FDF) has upgraded its food and non-alcoholic drink inflation forecast, from its previous forecast of 4.8% to 5.7% by December.

The European Commission is considering delaying the application of the EU Deforestation Regulation until December 2026. The Regulation will impose mandatory supply chain due diligence requirements on companies placing relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood) and related products on the EU market. But a potential delay doesn’t mean you can ignore it. The requirements are tough, so we’re recommending businesses use this extra time to get supply chains in order and stay alert for any changes to the rules.

 

“As cybercriminals grow increasingly sophisticated, organisations must take proactive steps to safeguard their systems, data and reputation. In these articles, we outline essential measures to prepare for and respond to cyber incidents and ransomware attacks effectively.”

– Sally Mewies, Partner, Technology & Digital

The Jaguar Land Rover and Asahi cyberattacks are the latest in a line of attacks significantly affecting manufacturing businesses. We’ve created an interactive tool to help you navigate the evolving legal and regulatory challenges surrounding data security, privacy, and compliance; to help you spot gaps in your defence; and to support your business’ reaction and rebuilding if/when the worst happens. Click here to find out more and to access the tool.

“Cybersecurity and data protection are significant concerns across manufacturing and supply chain. With many businesses expressing the view that it’s no longer a question of if a breach will occur, but when, these threats now sit at the heart of the risk agenda. We can offer support and expertise from our Regulatory & Compliance, Commercial, Technology & Digital and Litigation teams, providing a holistic approach, and putting you back in control.”

Andrew Northage B&W close up

– Andrew Northage, Partner, Regulatory & Compliance

The Financial Times has reported (16 September 2025) that the US is in talks to set up a multibillion-dollar fund for overseas critical minerals mining projects, with the aim of countering Chinese dominance. The fund would invest in projects to extract minerals such as copper and rare earths, which are crucial for defence and high-tech manufacturing.

The Herald Scotland (18 September 2025) has reported that workers at Leonardo’s defence and aerospace factory in Edinburgh could be set to strike over pay. The facility has also recently been targeted by activists driving a van into a perimeter fence and blockading the factory’s entrance in protest to military action in Gaza.

In similar news, various sources have reported that four people were arrested after a break-in at Moog Aircraft Group’s Wolverhampton factory (Moog’s products are allegedly used on fighter jets striking Gaza), and the BBC has reported that British microcomputers have now been found in Russian drones used in strikes in Ukraine.

Escalating geopolitical tensions, and heightened focus on defence manufacturing and defence spending, are seemingly also escalating tensions between facilities and communities, and between employers and employees. We have extensive experience and expertise in helping employers to deal with both industrial and protest action, so give us a call to discuss any concerns.

Kathryn Vickers, Director, Commercial Dispute Resolution

Reuters (23 September 2025) has reported that South Korea, Japan and the US have expressed concern about increasing destabilising activities around Taiwan. The statement didn’t specifically mention China, but China (which claims almost the entire South China Sea and views Taiwan as its own territory) has stepped up military activities nearby, including staging war games.

Taiwan’s government rejects China’s territorial claims. The Taiwan Straight is of strategic importance for global supply chains, especially in the technology and semiconductor sectors. It’s a key maritime passage where even the threat of conflict can lead to stockpiling, supply chain reconfiguration, and increased insurance and shipping costs.

Defence Industrial Strategy 2025

The UK government has published its Defence Industrial Strategy 2025. It includes investment intended to boost innovation, industry, and employment; and includes measures to improve skills in the sector and the procurement process. The Strategy also offers a new Supply Chain Capability Programme and a Defence Investment Plan for the next 10 years.

We’ve noted previously that China is reportedly (Reuters) building and training humanoid robots at such a scale that their cost could be halved (paving the way for economic viability and wide-scale commercial use) by 2030. In related news, Amazon is using humanoids with a sense of touch in its fulfilment centres, and MITUCL and Cambridge University are reporting significant developments in humanoid robots both with and without artificial skin.

A recent newsworthy development is Google DeepMind’s Gemini 1.5. It’s a vision-language-action AI-powered robotics model that can now see, process instructions, and act accordingly. It can carry out real world tasks such as, for example, sorting piles of laundry by colour. In the Financial Times (25 September 2025), Ingmar Posner, professor of applied artificial intelligence at the University of Oxford, said the development could help robotics reach a “ChatGPT moment”. The FT has also recently reported (3 September 2025) on RoboBallet, which could revolutionise production lines.

The UK government has launched the DRIVE35 funding programme to support a range of projects which help the transition to zero-emission vehicle manufacturing. The  automotive innovation programme forms part of the Advanced Manufacturing Sector Plan, within the UK’s modern Industrial Strategy. It will commit £2 billion in funding to 2030 and an additional £500m for research and development to 2035.

Logistics

Across Logistics has published Logistics trends 2025: Technologies, AI, challenges and opportunities, analysing the main trends shaping the sector today.

Decarbonisation

The government has launched the Depot Charging Scheme, which aims to support the uptake of zero emission HGVs by part-funding the installation of charging infrastructure at fleet depots. The scheme is open to public and private sector fleets, local authorities and non-profit organisations, located in England, Scotland, Wales and/or Northern Ireland.

The application window will close on 28 November 2025 or when funding has been exhausted (whichever is sooner), and works must be completed by 31 March 2026. Support for the purchase of electric vans and HGVs is available through the Plug-in Van and Truck Grant.

Transport Scotland has published a new report which contains a mapping of existing and planned HGV charging sites in Scotland. The report also highlights where en route charging stations are needed for electric HGVs across Scotland.

The UK government has published the Net Zero Technology Outlook, which offers independent analysis of the technologies the UK must prioritise by 2050 to deliver on its net zero commitments. The report covers 18 sub-sectors within five major emitting sectors: industry; transport; heat and buildings; agriculture, land use and waste; and power.

The government has published a summary of responses to its statutory review of the renewable transport fuel obligation and provided an update on the scheme.

The UK Emissions Trading Scheme (ETS) Authority has confirmed new timelines for bringing the domestic shipping, energy-from-waste, and carbon removals sectors into the national carbon market.

Also on the UK ETS, the government has published its interim response to the consultation on including the maritime sector in the scheme.

Following publication of the Maritime Decarbonisation Strategy, the government has now announced a further £448 million over the next five years for research and development investment for the UK Shipping Office for Reducing Emissions (SHORE) programme. The aim is to accelerate the development of technologies for the decarbonisation of the sector.

Intelligent Energy, a hydrogen fuel cell developer based in the UK, has just landed £17 million funding from the Aerospace Technology Institute Programme to launch Project HEIGHTS.

It aims to fast-track development of a new zero-emission hydrogen fuel cell system that could power commercial aircraft within the decade. Hydrogen Fuel News has reported that, if all goes according to plan, the technology could save 25.6 million tonnes of CO₂ p.a. and create up to 1,600 new jobs.

Road strategy and freight infrastructure

The Department for Transport has made a statement in Parliament outlining 5 strategic road schemes and 5 key rail upgrades that it says will support 42,000 jobs and pave the way for 1.5 million new UK homes.

The Department for Transport has published the draft Road Investment Strategy 3. It outlines the government’s wishes for National Highways and the future of the Strategic Road Network. Key announcements include: £25bn investment 2026-2031, with 43% focused on maintenance and renewals rather than new capacity; permanent cancellation of the smart motorways programme permanently; and final strategy to be published by March 2026, with implementation beginning April 2026.

The Competition and Markets Authority has launched a market study to review how the civil engineering sector operates to improve the design, planning and delivery of key road and railway infrastructure.

Ernst & Young has presented a study, commissioned by Europe’s Rail Joint Undertaking, on the potential contribution of rail freight to the development of net-zero logistics chains across Europe.

The Journal of Commerce and FreightAmigo are among industry commentators noting a growing trend towards shared terminal trucking networks – logistics hubs operated by 3PL providers that serve multiple clients simultaneously, offering shared infrastructure for truck loading/unloading, cross-docking, and short-term storage. Unlike traditional dedicated terminals, these facilities are designed for flexibility, scalability, and cost-sharing.

Key drivers behind the trend include: e-commerce and omnichannel growth; cost efficiency; risk mitigation; urban and regional logistics optimisation; integration of tech such as AI-driven warehouse management systems (WMS), IoT sensors, and automated sorting and cross-docking; and sustainability/ESG ambitions.

As from 1 September 2025, the Import Control System 2 (ICS2) is fully deployed across all transport modes, including road and rail, for collecting details on all goods entering or passing through EU borders.

Supply chain and tech

The Financial Times (3 September 2025) has reported that some of the world’s biggest air cargo operators are facing a capacity crunch. Of the approximately 630 large wide-body freighters in active operation, up to 150 are nearing or have already entered their retirement window and there is very limited new wide-body capacity entering the market. The supply-demand imbalance for large wide-body freighters is expected to intensify over the next several years.

Construction and development

Developers operating in all sectors should be are of the Construction Products Reform Green Paper on wide-ranging plans for future regulation of construction products. Proposals include bringing all construction products within the general product safety regime; enhanced regulatory, surveillance and enforcement powers; development of a new single Construction Products Regulator; and civil and criminal penalties for manufacturers that engage in misleading practices or neglect their responsibilities regarding product safety.

The government has said that the paper is the first step in what will be a proactive process of engagement and consultation across the system in the medium to longer term. The Chartered Institute of Building, in collaboration with various construction industry bodies has published the Guide to Products Critical to Safe Construction – a new resource which aims to signpost best practice, raise awareness of compliance standards, and provide advice on how to determine if a product is critical to safe construction. It’s likely to be of value to clients across the build spectrum, from product and project design and manufacture, to contracting and development/employment.

Developers may be aware that Lewes District Council recently agreed to recognise the legal rights of Sussex’s River Ouse, in a charter to protect the river’s fundamental right to “exist, thrive, and evolve”. The move was intended to promote action to restore the river’s and the surrounding catchment’s ecological and chemical health. Basingstoke and Dean Borough Council, Test Valley Borough Council and Southampton City Council have now similarly formally recognised rivers within their authorities.

This is clearly a growing trend across the UK (and internationally – rivers and natural habitats in several other countries have also been granted legal rights/legal personhood). Granting rights to rivers and other natural resources could have significant implications for businesses operating near or impacting them. In particular, developers may face more rigorous environmental assessments and/or planning requirements, which could affect timelines, costs and viability.

In, Crest Nicholson Operations Ltd v Secretary of State for Housing, Communities and Local Government [2025] EWHC 2194 (Admin) the claimant argued that a water neutrality planning condition was unlawful on the grounds (1) the Inspector and Secretary of State erred by proceeding on the basis that groundwater abstraction might continue at a level that could harm the protected habitats through reliance on imperative reasons of overriding public interest; and (2) they also erred in their approach to uncertainty in the appropriate assessment, contending that what was required was certainty as to the end (being protection of the site), not the means by which this would be achieved. The High Court dismissed the claim on both grounds.

The Joint Contracts Tribunal (JCT) has released the Target Cost Contract 2024 on 25 June 2025. It is the final piece in the publication of the JCT 2024 Edition suites. This new contract family introduces a fresh approach by the JCT to cost management and collaboration. See our briefing for more information.

People in logistics

The Employment Rights Bill (ERB) introduces sweeping reforms with potentially major implications for employers in the logistics sector. Key changes include enhanced protections for agency and zero-hours workers, the regulation of umbrella companies (which may be relevant for the self-employed couriers out there), and broader consultation thresholds across multiple sites when conducting collective redundancy exercises. Trade union presence in the sector may also increase due to simplified recognition rules and expanded access rights.

With the ERB on the horizon, employers should prepare for day-one unfair dismissal rights and extended tribunal timeframes. These developments require proactive review of workforce models, industrial relations strategies, and HR policies to ensure compliance and operational resilience. See our briefings for further insight.

Laura Oxley, Director, Employment & Immigration

The All-Party Parliamentary Group for Freight and Logistics’ is considering responses to its call for evidence to inform the drafting of a new report on fostering diversity in the logistics workforce – ‘Attract, Train, Retain’. Logistics UK has requested greater flexibility in the use of the Growth and Skills Levy, urgent improvements to the Access to Work scheme, and extended National Insurance exemptions to support inclusive hiring.

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