The legislation on products is paid much attention to at present in all the countries. From the view of the law of product liability and its purpose, the consumers' rights are guaranteed by regulating the duties and services of the manufacturers and sellers. But there is still a big difference in the development and perfection of the legislation in different countries. This thesis tries to compare the difference in the legislation on the duties of products and products' problem relating to it. It consists of eight parts: From part one to part six the following are analysis and studies such as the definition and scope of products both at home and abroad, the definition and norms of judgement of the product defects, the imputation principle of PL, the subject of PL, the PL cause of counterplea, the compensation for damages of PL. etc. In part seven is a brief comparison between responsibility of quote and lawsuit limitation. And a conclusion is drawn from the above seven parts which will gives us some ideas about what we should learn and what will make it perfect for our PL. |