Manufacturing Horizon Scanner – November 2026

Industry news

The UK now has full access to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), following Canada’s ratification on 1 September 2026. Along with other CPTPP member markets (Australia, Brunei, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore, and Vietnam), the UK can now fully operate within the c.£12.9 trillion bloc. Manufacturers are expected to experience new market opportunities, reduced administrative friction, and improved access to procurement and supply chain opportunities.

The Financial Times has reported (3 September 2026) that several global groups, including VW, Tesla, Nokia and Amazon, have revealed that businesses blacklisted by Western authorities may be present in their supply chains. The FT reports that, under US sanctions rules, companies can be held liable for indirect dealings with blacklisted entities, even if they’re unaware of the link. The announcements highlight the gap between the breadth of the rules and companies’ practical capacity to exhaustively monitor their supply chains.

The Food Standards Agency Board is progressing new regulatory proposals (the Future of Food Regulation programme) which will see major changes to an historical framework and will place ‘Big Food’ under much greater scrutiny. For further information, including commentary, concerns and advice from Walker Morris’ Chris McGarvey on how proposed changes will impact food manufacturers, see this Food Manufacture article.

The Manufacturer has reported (4 August 2026) that Take Root Bio, working with Heriot-Watt University, has successfully turned salty whey, a high-volume by-product of cheese production, into bioethanol fuel. The company is also looking at whether mobile production units could be deployed closer to where these by-products are produced, helping to reduce transport requirements and making the concept easier to scale, and whether other value or products can be recovered from other food and drink manufacturing waste. This innovation developed from biosphere engineering and a closed-loop life-support system design originally developed to address the challenge of how astronauts could grow, recycle and sustain food production during long-duration space missions.

Insecure loads can cause serious injuries and fatalities on UK roads. The brewing and drinks industry faces unique challenges, from securing unstable cylindrical kegs, casks and barrels, to managing changing load dynamics during multi-drop deliveries. Logistics UK has updated its brewing and drinks load-security best-practice guide, providing practical, industry-specific advice to help operators and drivers comply with legislation and reduce risk across the supply chain.

The European Commission has proposed measures aimed at accelerating the development of European standards, improving SME participation, increasing transparency and improving harmonisation and accessibility. As standards are often the gateway to legal compliance and market access, the proposals could reduce regulatory friction and help businesses bring new products to market more quickly. The proposals could particularly boost fast-moving sectors from clean technologies and batteries to construction products, cybersecurity and advanced manufacturing. The next step is for the European Parliament and Council of the EU to consider the proposals. One to watch.

The Law Commission is consulting, until 14 January 2027, on reforms to UK product liability law, proposing to extend the definition of a “product” to include software, AI systems and certain online platform features, and bringing online marketplaces within the liability regime. The proposals include clarifying rules on defective products, clarifying when compensation might be available for psychiatric harm claims, and easing evidential challenges for claimants in complex defective product cases. The reforms are likely to have a particular impact on businesses developing, supplying or selling digital products, AI solutions and online services. The Law Commission expects to publish its recommendations for reform in late 2027.

The Financial Times has reported (23 September 2026) that Chinese authorities are examining the use of Broadcom’s hardware in state-backed data centres as part of a drive to boost Chinese domestic producers and reduce reliance on foreign (here, American) AI infrastructure.

For many UK businesses, China has traditionally been viewed as both a significant commercial opportunity and a significant intellectual property risk. Recent developments suggest that China’s approach to intellectual property protection is evolving. With a new Trade Mark Law due to come into force on 1 January 2027, along with the Chinese courts increasingly demonstrating a willingness to enforce rights in favour of brand owners, now is a good time to reconsider how your business approaches brand protection in China. See our recent article for further information and advice.

UK nuclear technology developer Rolls-Royce SMR has been selected to deliver three small modular reactors (SMRs) for a major new nuclear power project in Sweden. It’s a significant export success for British manufacturing and engineering  expertise and should create opportunities across the UK supply chain. (For an overview of the UK nuclear investment landscape more generally, see our recent article.)

The Jackdaw gas field has been given the go-ahead. Production is expected to begin imminently and is anticipated to boost UK domestic gas output by 6% at its peak. The development is forecast to contribute £2.9 billion to the economy and support hundreds of jobs. It’s hoped the product will, in turn, benefit manufacturers who continue to face energy cost pressures.

Recent months and years have demonstrated that, rather than pursuing the lowest cost options or reacting to isolated disruptions, the most successful businesses build resilience into strategic decisions and supply chains. Legal tools and contractual risk management are key. Our recent article offers legal and practical tips to help rethink your supply chains for flexibility and resilience.

Defence/cyber/space

The government’s long-awaited Defence Investment Plan was published this summer. See this link for the full document, a four-page summary and a funding explainer. Click here to find out about our expertise in the defence sector. And click here for Make UK and Lloyds’ practical guide to working in defence.

Barclays Business Prosperity research has found that 40  percent of UK businesses surveyed, operating across multiple sectors, expect their involvement in the UK defence sector to increase over the next 12 months. This article from The Manufacturer explains and offers key messages on the need for clarity around DefCons, procurement, funding/finance, skills shortages and the need for scaling technologies.

The UK Space Strategy was updated in September 2026. It places defence, national security and economic growth at the centre of UK space policy, backed by £7.8 billion of investment to 2030 and a more interventionist approach to developing domestic space capabilities. Key identified priority areas include satellite communications, space domain awareness, in-orbit servicing and manufacturing (ISAM), and access to space. With space increasingly being treated as critical national infrastructure and satellite services already underpinning large parts of the UK economy, there are likely significant follow-on opportunities across manufacturing, communications, navigation, energy, finance, and defence generally.

In related news, the European Commissioner for Defence and Space warned, at the EU Access to Space Conference in September, that Europe faces a growing shortage of launch capacity as governments expand satellite programmes for secure communications, Earth observation, navigation and defence. The European Union alone is expected to require 62 launches by 2034.

And in Europe, as the EU’s current space funding cycle ends next year, the European Space Agency‘s director general has pitched a €10 billion action plan on autonomous access to space, and the European Commission has proposed a new European Competitiveness Fund to set aside €131 billion for defence and space.

In August 2026, the UK government announced amendments to the Cyber Security and Resilience (Network and Information Systems) Bill following a cyber attack on a UK energy facility. The amendments would allow the government to designate suppliers as ‘high-risk vendors’ and to instruct operators of critical infrastructure and essential services to: stop buying goods or services from those vendors; restrict, remove, disable, or replace existing products or services supplied by them; and impose additional security requirements where national security concerns arise. As of October 2026, the Bill is making its way through Parliament. Increased regulation of  supply chain cyber security is ‘one to watch’.

Tech

Finnish company and chrome mine, Outokumpu, has launched new proprietary technology which could help establish a fully Western supply chain for chromium and other strategic materials, decreasing reliance on Chinese critical minerals.

Businesses that provide or use certain AI systems in the EU now face new transparency obligations, in force since 2 August 2026, under Article 50 of the EU AI Act. This may require informing individuals when they are interacting with an AI system. ensuring that AI‑generated content carries machine‑readable markers, informing individuals when emotion recognition or biometric categorisation systems are being used, and labelling AI‑generated or manipulated content and text on matters of public interest. Organisations should map their AI use cases against the Article 50 requirements, review customer touchpoints and labelling processes, assess solutions for marking AI content, and consider and document their compliance.

Sustainability/ESG

The Climate Change Agreements (Amendment and Revocation) Regulations 2026 come into force on 1 January 2027. They update the Climate Change Agreement scheme, which allows eligible energy-intensive businesses to benefit from a reduced rate of Climate Change Levy in return for meeting energy efficiency or emissions targets. The Regulations clarify eligibility rules and extend the scheme to three additional activities relevant to the manufacturing sector: mechanical recycling of plastic, packaging of spirits, and production of automotive-grade battery cells.

The UK government has confirmed the final design of the British Industrial Competitiveness Scheme (BICS), which is intended to reduce electricity costs for energy-intensive manufacturers. From next year, the BICS will exempt eligible manufacturing businesses from up to 100% of Renewables Obligation, Feed-in Tariff and Capacity Market levies. Eligible businesses will also receive a one-off payment in 2027 (reflecting support they would have received had the scheme started earlier). The application window is open until 30 November 2026. Click here for the government’s eligibility checker and scheme guidance.

From 27 September 2026, Member States will be required to apply new rules on green claims as set out in the Empowering Consumers for the Green Transition Directive (EU) 2024/825 (ECGT). Manufacturing businesses operating across the EU will be aware that greenwashing is already prohibited under general consumer protection principles. However, ECGT refocuses attention on the issue and provides specific rules targeting the use of generic green claims (e.g. ‘eco’ or ‘green’), carbon neutral claims based on offsetting of GHGs, the use of self-created sustainability labels, and future performance (e.g. ‘net zero’) claims not backed up by a publicly available implementation plan and verified by an independent expert whose findings are also made public. Penalties for non-compliance will be determined at national Member State level, with the highest fines potentially exceeding 4% of annual turnover for the most egregious breaches. EU regulators have published a ‘common understanding’, which proposes a more proportionate approach to stock manufactured, ordered, distributed, or placed on retailers’ shelves before 27 September.

The EU’s new packaging regulation (the PPWR) came into effect on 12 August 2026 to further regulate packaging use in the EU. The PPWR also restricts certain packaging-related green claims and requires businesses to go further in relation to a new set of requirements covering the entire packaging life cycle, including restrictions on certain single-use plastics, such as for individual portions or sachets of condiments and sauces, a requirement for take-away businesses to offer customers the option to bring their own containers at no extra cost, and minimising substances of concern, including restrictions on PFAS in food contact packaging if they exceed certain thresholds.

The ASA has updated CAP and BCAP guidance on misleading environmental claims and social responsibility. In related news, CAP has published a new guide, ‘Greenspeaking with Confidence’, along with a checklist, to support businesses throughout the green claims creative process.

And from the enforcement perspective, the CMA has recently fined three businesses a total of £6 million for misleading sales tactics. All three were among the eight businesses investigated in the CMA’s first wave of Digital Markets, Competition and Consumers Act 2024 enforcement cases on online pricing. One of the businesses was Appliances Direct, which was fined £1.2 million, plus around £432,000 in refunds, for the fact that customers were automatically opted into paid removal and recycling of old appliances and paid installation on delivery. The business also used pop-up countdown banners for ‘limited time’ discounts, even though the same discount codes kept appearing over many days.

Lloyds Banking Group has published a report, Built to Last: Climate Resilient Infrastructure Needs Transformative Investment. It highlights £billions annual shortfall in UK climate adaption investment and says the Group aims to provide over £100 billion in sustainable and transition finance supporting adaptation and resilience from 2027 to 2030. The Group’s Chief Sustainability Officer has said the UK should “treat climate-resilient infrastructure with a national security mindset.” The flip side of investment in new, climate resilient infrastructure is, of course, asset stranding (see our earlier article for more information). Whilst the report itself focuses on energy, water and built environment infrastructure, it’s easy to anticipate consequential impacts across manufacturing, defence, logistics and more.

The government published a policy paper on strengthening the UK’s approach to tackling deforestation. The aim is to introduce legislation in 2027 requiring businesses with an annual turnover of over £1 million, that use forest risk commodities and wood products to carry out due diligence to make sure production complies with relevant laws. The government wants the measures to operate consistently alongside the EU’s Deforestation Regulation (EUDR). The intention is to move towards a deforestation-free standard.

Earlier in the year, the European Commission published a report on the simplification of the EUDR and a set of further measures for a smooth and effective implementation. Any operator or trader who places the relevant commodities covered by the EUDR on the EU market, or exports from it, must be able to prove that the products don’t originate from recently deforested land, nor have contributed to forest degradation. The EUDR will apply from 30 December 2026 for large and medium companies, as well as for micro and small enterprises from the timber sector, and from 30 June 2027 for other micro and small enterprises. The Commission has now adopted measures to support implementation and simplification of the EUDR from December 2026. Changes include removing certain derived products (such as leather, re-treaded tyres, soybeans for sowing) from scope adding other products to scope (including soluble coffee and some palm oil derivatives) and introducing targeted exemptions for certain categories of product (including waste, second-hand products and products used in the manufacture of medicines).

The EU’s ban on destroying unsold clothing, clothing accessories and footwear is now in effect. Under the EU Ecodesign for Sustainable Products Regulation, companies, including manufacturers, must publicly disclose what they discard. Click here for more information.

The Environmental Audit Committee (EAC) has published the UK government’s response to the recommendations in the EAC’s April 2026 report on PFAS. It affirms that PFAS are a significant, long-term environmental and public health challenge, and broadly accepts the need for action, but stops short of committing to many of the EAC’s proposals.  Most of its responses refer to the government’s PFAS Plan, its intention to reform UK REACH by December 2028, and to improve alignment with EU chemicals regulation.

As of 1 October 2026, the Digital Waste Tracking (England) Regulations 2026 are in force. They establish the first phase of a mandatory digital waste tracking service to replace the existing paper based system. They apply to England, with other UK nations having equivalent systems. Businesses with an environmental permit to operate waste receiving sites are now required to digitally record information about waste received.

People in manufacturing

European Commission has published Guidelines on the EU Forced Labour Regulation, which applies from 14 December 2027. The Regulation prohibits economic operators from placing or making available on the EU market, or exporting from the EU, products made with forced labour, whether inside or outside the EU. The Regulation applies to all products across all sectors and geographies. It includes agricultural products, minerals, and other raw materials. The Regulation doesn’t impose mandatory due diligence obligations but refers to the OECD six-step due diligence framework as an appropriate benchmark for businesses seeking to understand and ensure compliance. See the Commission’s Forced Labour Single Portal for compliance guidance.

In related news, the UK government is proposing significant changes to the modern slavery reporting regime. If implemented, the reforms would shift the focus from a largely voluntary disclosure exercise to extended and demonstrable governance and supply chain due diligence, backed by a meaningful enforcement regime. Early preparation will help organisations reduce compliance risk. In this article we explain what businesses need to know and set out proactive, practical advice.

The new access to workplaces regime represents a significant shift for UK industrial relations. Employers should expect trade unions to use the new rights strategically, particularly to increase membership and pursue recognition and collective bargaining rights. A recently published amended code of practice provides guidance about how the new right will work in practice and will help employers prepare for change: Make Work Pay: draft code of practice on trade union right of access – GOV.UK. Our recent article offers further information and advice.

The Home Office has published a new Code of Practice on Preventing Illegal Working, effective as from 1 October 2026. The changes will affect businesses that engage contractors, casual workers, agency workers, outsourced labour, platform workers and other non-traditional workforces, regardless of whether they consider themselves to be the individual’s employer.

For further information and advice on manufacturing horizon employment law issues, please see Preparing for change: Employment and Immigration law reforms affecting UK manufacturers.

Logistics

Colliers has published its Industrial and Logistics Market Pulse for October 2026. It shows resilient occupier demand and anticipates that that the next market phase is likely to be shaped by a shortage of modern logistics stock.

The UK government is backing British shipbuilding with multi-billion-pound investment in two major maritime projects. The Royal Navy’s submarine service will receive three new floating docks, through a UK-only competition, in light of their importance to national security and sovereign British industry. It will also receive a new marine research vessel, set to be operational in the early 2030s, which will replace the current vessel which is nearing the end of its life. The investment is anticipated to strengthen the country’s industrial base and support skilled construction, manufacturing, defence and maritime jobs.

The government has announced the creation of Great British Grid (GBG), a new publicly owned body, within Great British Energy, which is intended to accelerate investment in Britain’s electricity networks and help businesses connect to the grid more quickly. GBG will invest public capital together with private investment in electricity network infrastructure, and will work alongside existing network operators. The government has also announced plans to expand self-build connections, allowing businesses and developers, where appropriate, to build their own grid connections rather than waiting for network companies to deliver them. Competitive tendering for new transmission infrastructure will also be accelerated. The announcement is particularly relevant to the logistics sector as operators increasingly require substantial new electricity connections to support the electrification of vehicle, depots, ports and warehousing.

Warehouse and Logistics News’ latest Business Energy Tracker report has found that companies have ranked energy as their top operational risk for the fourth year running.  Energy flexibility – the ability to shift electricity use from one time period to another, in response to grid signals and market prices – could be a valuable solution. We have commercial and real estate experts with dedicated energy sector and logistics knowledge. Contact us to discuss legal and practical options.

Uber has partnered with drone delivery company Zipline to scale its drone delivery operations across the US. The first deployments will begin later in 2026, with investment planned to reach a million drone deliveries per day by the end of 2029. For the latest UK legal and commercial insights on drone use, see our recent article.

Also in relation to drones, a drone carrying explosives was this week discovered within the cargo area of Leipzig Airport, and a DHL freighter was later hit by an unknown object after taking off from the airport. The incidents caused several countries to ramp up security requirements for shipments from the UK and Europe.

A cyberattack on logistics giant CEVA in August disrupted warehouses across Europe and exposed customer data belonging to some of CEVA’s big-name clients. For help navigating the evolving legal and regulatory challenges surrounding data security, privacy and compliance, click here to access our cybersecurity tool.

The Construction Site Crime Report 2026 has found that tool theft is now the most common crime on sites. Anubis Group data suggests it’s significantly on the rise, with a 16% year on year increase. Rather than viewing storage as an afterthought, contractors are beginning to treat safe storage as part of their wider site logistics strategy, with some considering out of town warehouse options, and others considering flexible storage close to city centre projects.

Fly-tipping, protests and trespass generally are increasingly prevalent risks at manufacturing and logistics sites. For example, the BBC reported over the summer that around 400 tonnes of industrial waste had been dumped at the old Dewhirst factory site in Peterlee; the Supreme Court in McCafferty had to deal with legal issues arising from protests outside Müller UK’s dairy works at the Stonebridge Cross Industrial Estate; and ports in Dover and Portsmouth recently faced disruption from ‘small boat’ protest action.

The government has published its response to its electric vehicle excise duty (eVED) consultation from earlier this year. eVED, the government’s proposed pay per mile charge on electric cars, will be rolled out from April 2028. Participation will be voluntary, with a simpler user experience for those who opt in. eVED will apply to UK-registered EV cars, hydrogen Fuel Cell Electric Vehicles, plug-in hybrid cars and range extender vehicles.

As of September 2026, Lidl has launched a fully autonomous electric truck on public roads in Germany. How quickly autonomous lorries can be rolled out beyond pilot routes will depend on regulation. Germany and 16 other EU member states are aiming to coordinate the development of automated vehicles and develop common standards so that they no longer have to stop at national borders.

The Department for Transport (DfT) has published new research examining how the EU Entry/Exit System (EES) and the Schengen 90-days-in-180 rule could affect GB’s road transport operators. Operators expected the impact of EES to become more significant. Among goods operators, 46% reported a negative impact to date, compared with 59% expecting a negative future impact.

Road, rail, ports and freight infrastructure

A new guide, The Local Highways Climate Adaptation Guide, has been published for local highway authorities, to support resilience planning across road networks as extreme weather events grow in frequency and severity.

The Court of Appeal has dismissed a legal challenge against the Gatwick expansion project, enabling Gatwick Airport’s second runway to be bought into full use. The first flights are expected to take off from the extended Northern Runway in 2030 and could mean an extra 10,000 flights a year.

The UK government has published a summary of responses to its call for evidence on challenges and opportunities around net zero ports. The full response can be viewed here. The next steps on the role of ports in maritime decarbonisation include: removing barriers to ports securing the energy they require, which will involve highlighting ports’ energy needs in strategic energy planning and connection reforms; and working with industry to understand ports’ ability to deliver, or enable third parties to deliver, the infrastructure required for maritime decarbonisation.

In related news, the government has published its revised National Policy Statement for Ports (NPSFP). The updated NPSFP gives a stronger policy basis for a wider range of port development, including offshore and floating offshore wind, hydrogen, ammonia, and other emerging energy commodities. The express presumption in favour of consent, together with the substantial weight to be given to economic benefits, should provide important support for future Development Consent Order applications.

The government is also seeking to reduce greenhouse gas emissions at berth through a UK maritime fuel regulation, on which a consultation is expected later in 2026.

The DfT has published a briefing paper outlining the proposed structure of a Long‑Term Rail Strategy intended to guide rail investment across the UK for the next 30 years. The final Strategy is expected later in 2026.

The DfT has announced new interim 2040 targets for rail freight growth. The 2050 target is to increase freight moved by rail in net tonne kilometres by at least 75%. There’s also a new 2040 target to increase freight moved by rail in net tonne kilometres by at least 40%.  The Railways Bill, currently before Parliament, provides for the Transport Secretary to set a rail freight growth target for Great British Railways, which should embed the duty to grow rail freight into the new body’s decision-making.

Decarbonisation and climate resilience

The Tritax Big Box and Savills 2026 Future Space Report (FSR) looks at key trends shaping the Industrial and Logistics market horizon. It highlights challenges the logistics sector need to overcome on the net-zero journey.

The European Commission has published a series of guidance documents to assist non-EU operators with the implementation of the EU Carbon Border Adjustment Mechanism.

The government is seeking to support the development of ‘first-of-a-kind’ Sustainable Aviation Fuel (SAF) production technologies, to help decarbonise aviation and strengthen energy supply security. It’s delivering a Revenue Certainty Mechanism (RCM) to help producers and investors build and scale SAF production plants in the UK. The SAF Bill has received Royal Assent and provides the legislative powers needed to implement the RCM and, on 13 July, the DfT published the SAF RCM: Contract Allocation Strategy.

Construction/development and real estate

The government published its new National Planning Policy Framework (NPPF) on 17 August 2026. An explanation of the changes is set out in the Minister of State’s letter dated 17 August. Logistics UK has said that it welcomes the NPPF for its greater recognition of the sector’s role in supporting economic growth and resilient supply chains. The framework includes support for locating logistics developments near strategic transport networks, expanding EV charging infrastructure and ensuring sufficient, secure lorry parking. For more information on the new NPPF, see our ‘at a glance’ insights.

The government has published updated Compulsory Purchase Process: Guidance. Whilst underlying legal principles remain, the guidance signals a more flexible approach for progressing complex projects. It also provides for the arrival of conditional compulsory purchase orders, intended to reduce delays, avoid the need for re-determination, and support more timely delivery of projects.

We’ve reported, in earlier WM publications, on an emergent trend towards the legal recognition, and therefore enhanced protection, of rivers and other sites. Continuing that trend, the House of Lords has pushed through a proposed Nature’s Rights Bill that would recognise ecosystems and species as legal subjects. The aim is to transform how construction and engineering projects are planned and consented, placing nature at the centre of UK law by establishing a legal duty of care on public bodies and businesses to the natural environment. Although this is a Private Members Bill, it represents escalation of an issue that has been gathering pace, and that could significantly impact development. It’s one to watch.

The Supreme Court has granted permission to appeal in R (on the application of North Warwickshire Borough Council) v Secretary of State for Transport, with a full hearing scheduled for 7–8 December 2026. The case is concerned with project modifications and deemed planning permission under a projects empowering statutory authority. The Supreme Court’s decision will likely have significant implications for the delivery, design modification, and legal risk management of major infrastructure projects. One to watch.

Also on infrastructure projects, there’s an ongoing tension between the government’s attempts to facilitate various types of infrastructure developments and the objections of landowners potentially affected by that infrastructure. Barstow v Green Generation Energy Networks Cymru Ltd exemplifies that tension, and provides useful guidance as to how the courts will interpret statutory rights of entry (in this case, right of entry to carry out surveys). The High Court confirmed that statutory notices of entry must explain, as far as reasonably practicable and in plain language, what’s going to happen, where and when. It rejected any suggestion that such a notice could ‘run with the land’ and last indefinitely.

The UK Green Building Council has published a Whole Life Carbon Framework to help the built environment sector reduce and manage carbon emissions across the life cycle of buildings and support net zero aligned projects. For information and practical advice on how we can help businesses address ESG challenges in the built environment, see: ESG and UK real estate key considerations, Sustainability in the built environment and more.

The Construction Leadership Council has published its  Mental Health Joint Code of Practice – a framework to help foster better mental health in construction.

People in logistics

As AI becomes increasingly embedded across the UK logistics sector, a key issue of which employers should be aware is its potential impact on the gender gap. See here for our insights and advice on the fair roll-out of AI technologies.

The government has published its response to the consultation on the duty for employers to inform workers of their right to join a union. The duty will come into force on 1 January 2027 (rather than 30 October 2026 as previously anticipated).

See our recent articles for information and advice on the new trade union right to access workplaces: how employers can get ready and the major expansion of right to work compliance beyond direct employees from 1 October 2026.