中外产品责任抗辩事由比较研究

Contrastive study of product liability defense in China and foreign countries

欧美及世界上发达国家的产品责任法对产品责任抗辩事由都作了较为详尽的规定。我国产品质量法关于产品责任抗辩事由的规定从总体上说与世界发达国家的立法保持一致,但也存在抗辩事由规定过于单一,内容不够全面、具体等缺陷,亟待完善。

The product liability laws in advanced countries including the US and European countries have detailed stipulations regarding product liability defense.The product quality law in China remains in general agreement with the legislation in advanced countries with regard to product liability defense;yet,it needs to be perfected as it is not comprehensive in content and the defense stipulated is too narrow.