Comparative Study Of The Sino-US Products Liability System

The first section introduces the U.S products liability systems Characteristics, volitions position and its influences in the international comparative products liability law. This part lays a foundation for the further description of comparative study of the Sino-US Products Liability System. The second section describes the U.S. defect and evaluation criteria of Products Liability in comparison with Chinese product liability system, then pointing out the defects in our product liability with confusion of concept and evaluation criteria..In the U.S. and other comparative product liability law, they describes the satisfaction technical standards as defenses, however, we regard the satisfaction technical standards as defective evaluation criteria in our country. In addition, the author puts forward to some advices:the defect and its evaluation criteria are short of specifics and certainty and it causes the instability of law. The third part of this paper analysis the range of products in the U.S. product liability and Chinese product liability.Under the description of this part, the author give some suggestions combining with China’s specific situation and the current law.The following part expounds the imputation of liability in the U.S product liability law and Chinese product liability law. The conclusion is as follow:consumers can choose between the fault liability and strict liability freely. That is the purpose of tort law and strict liability. The last part describes damage compensation system in U.S. product liability to compare with it in the Chinese product liability. The main questions are the subjects and spheres in damage compensation system and especially the compensation for the punishment.