基本説明
This book compiles national reports from 24 European countries on the sale of goods law as well as the consumer's remedies for non-conforming goods and the final seller's right of redress. A comparative report informs about the different models of producers' liability and their impact on the internal market.
Description
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The Consumer Sales Directive has to a large extent harmonised the consumer's rights and remedies against professional sellers. As a next step, the European Commission now favours 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 recognise 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 behavioural 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 harmonisation.
