9 DEC 2026 · NEW EU PRODUCT LIABILITY RULES

What changes
EU PRODUCT CHECKDOCUMENT REVIEW
EU PRODUCT CHECKDOCUMENT REVIEW
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NEW EU PRODUCT LIABILITY RULES

What changes on 9 December 2026

New EU rules widen who can be made to pay for a defective product, and let a court order the product documents handed over.

At a glance

63
DAYS UNTIL IT APPLIES

  • WHAT

    The new EU Product Liability Directive.

  • WHICH PRODUCTS

    Products placed on the EU market after 9 December 2026.

  • WHO CAN BE MADE TO PAY

    Besides the manufacturer, in certain cases: importers, fulfilment service providers, distributors and some marketplaces.

  • DOCUMENTS

    A court can order the product documents handed over.

Who can be held liable

  1. The importer

    Can be held liable when the manufacturer is outside the EU.

  2. The fulfilment service provider

    Can be held liable when the manufacturer is outside the EU and there is no importer or appointed representative in the EU.

  3. The distributor

    Can be held liable when it cannot name its supplier.

  4. The marketplace

    Can be held liable in some cases.

How a claim runs

  1. A defective product causes harm.

  2. The person harmed claims from a business in the chain.

    Any one of them can be made to pay the full amount. Liability is joint and several.

  3. A court can order the product documents handed over.

    If they are not produced, the product is presumed defective. The same applies if it does not meet a mandatory safety requirement.

  4. So each business has reason to ask its supplier for the documents.

Could you hand over your documents today?

Request the free Listing Scan

How much can be claimed

  1. No lower limit.

    The old €500 minimum is gone. Small claims count.

  2. No upper limit.

    There is no maximum amount.

  3. No limit by contract.

    Liability cannot be limited by contract. A clause in a supply agreement does not change that.

AUGUST 2026 TO DECEMBER 2027

When the rules change

  1. 12 Aug 2026Packaging
  2. 18 Aug 2026Batteries
  3. 11 Sep 2026Connected products
  4. 10 Oct 2026Chemicals
  5. 9 Dec 2026Product liability
  6. 18 Feb 2027Batteries
  7. 11 Dec 2027Connected products

Which of these rules applies to a given product and company is a question for that company's own lawyer.

Common questions

What can we do before the date?

Start with the free Listing Scan: a few questions about one product. It shows whether a full read of your documents is worth it, before you send any.

Is this legal advice?

No. We provide no legal services, give no legal opinions and don't tell you what to do. We describe what the published rules say and what is in your file. Whether your product may lawfully be placed on the market is a legal question that only your own examination or a qualified lawyer can answer.

If our product gets stopped anyway, is that on you?

A Gap Report describes your documents as they were when you gave them to us. It cannot predict what a marketplace, buyer, customs office or authority will decide, because those decisions can turn on things outside the file. You remain the responsible economic operator. The limits of our responsibility are set out in the agreement before you decide.

Port crane over a container ship at dusk

BEFORE 9 DECEMBER

Tell us about one product.

Say which documents you hold and, if you have one, send a listing link. We aim to reply within 24 hours with what looks missing and a price for the next step.

Request the free Listing Scan