European Perspectives on Producers' Liability: Direct Producers' Liability for Non-conformity and the Sellers' Right of Redress

In Europe, the Consumer Sales Directive has, to a large extent, harmonized the consumer's rights and remedies against professional sellers. As a next step, the European Commission now favors 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 recognize 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 final seller's right of redress. Additional contributions approach this topic from the perspectives of law and economics, legal history, and behavioral psychology. A comprehensive introductory chapter provides a comparative report on the different models of producers' liability, including their impact on the internal market, and sets out elements for further harmonization.