ABSTRACT
This chapter looks at the way different countries apply product liability laws and product safety requirements to protect their consumers. The French legal system is different from that of the UK, other Commonwealth countries and the USA in that it is based on entirely distinct tenets of civil law and it is largely codified in the French Civil Code. Draft implementing legislation for the Product Liability Direc-tive in France has been pending since 1990, consisting in part of a transcription of the main provisions of the Directive itself, which would comprise an additional Title in the Civil Code, but which could also render void certain aspects of the existing French product liability law. Germany has implemented the European Product Liability Directive but, at the time of writing, not the General Product Safety Directive. The supply of products which breach a standard or failure to comply with other requirements under the legislation is a criminal offence punishable by fines.
