Der Einfluß des Europäischen Gemeinschaftsrechts auf das internationale Produkthaftungsrecht

Robert Freitag examines the rules and regulations of product liability in German, French and European Community law and deals with the conflict of law rules of both states concerning cross-border liability. He gives a profound analysis of the EC regulations concerning the free movement of goods. He further asserts that international products liability law is not governed by an EC-inspired rule of origin. However, certain basic legal principles derived from the fundamental concept of the Single European Market require national conflict of laws provisions to satisfy the demands of Art. 28 EC. The author discusses these implications on the basis of the classical choice of law approach which is typical of continental European legal systems.