European Perspectives on Producers’ Liability : Direct Producers’ Liability for Non-Conformity and the Sellers’ Right of Redress – Comparative Report

The Consumer Sales Directive has to a large extent harmonised the consumer's rights and remedies against professional sellers. As a next step, the European Commission now favours the introduction of an EU wide direct producers' liability. Currently, the situation in Europe is divided: Whereas in most jurisdictions consumers can only bring claims against their sellers, a growing number of countries recognise a direct claim of the consumer or final buyer against the producer.This book compiles national reports from more than 20 European countries on the consumer's remedies for non-conforming goods and the fi nal seller's right of redress. Additional contributions approach this topic from the perspectives of law and economics, legal history, and behavioural psychology. A comprehensive introductory chapter provides a comparative report on thedifferent models of producers' liability, including their impact on the internal market, and sets out elements for further harmonisation