Germany’s revised Product Liability Act will apply to products placed on the market on or after December 9, 2026. The reform expands the potential chain of liability to include manufacturers, importers, fulfillment service providers, suppliers, and online platforms under certain conditions.
For cross-border sellers sourcing products from China, the US, and other non-EU markets, the changes could increase legal and financial risks. If no responsible party established in the EU can be identified and the seller cannot identify the relevant supplier or responsible party within one month, the seller may be treated as the manufacturer and held liable for personal injury or property damage, even without personal fault.
Sellers importing goods directly from outside the EU, making substantial product modifications, or selling products under their own brands should review supplier records, product traceability, and liability arrangements before the new rules take effect.
