Product liability from 9 December:
substantial modifications make you the manufacturer
Video · 0:42 min · November 11, 2026
On 9 December, the new German Product Liability Act takes effect. Software and updates then count as a product, and anyone who substantially modifies equipment without the manufacturer's consent is liable like a manufacturer. For operators and service providers, what counts from now on is what they can prove about modifications and updates.
In the video
- 01The act was promulgated on 27 October. It applies to products placed on the market from 9 December.
- 02As long as the manufacturer can supply updates, it keeps control. If a safety update is missing, it is liable.
- 03Maintenance and repair make no one a manufacturer. A modification that raises the risk does.
- 04Personal injury and private property are compensated. Purely professional property and data stay out.
- 05A product can trigger claims for ten years. After a substantial modification, the period starts again.