19/05/2026
The new EU Product Liability Directive (PLD) is here. ⚖️ And it expands the scope on how manufacturers of machines, consumer electronics and other products placed on the EU market or put into service in the EU can be held liable.
Important changes that will apply from 9 December 2026, what you need to know
* Software (including AI systems and software updates) is now explicitly covered by the PLD. So are digital manufacturing files and raw materials.
* Fault-independent liability: manufacturers are liable for damage caused by defective products, regardless of fault.
* In addition to traditional physical damages, claims can now arise from data loss or psychological harm.
* Cyber security vulnerabilities enter the game. If a product lacks security updates while it remains under the manufacturer’s control, it can be considered “defective”.
* The liability risks for manufacturers increase as the new PLD shifts the burden of proof toward them.
The good news is: Properly applying existing regulations and standards, applicable to your product, can substantially reduce many of the new liability risks.
Latest regulations and new editions of standards also provide a scope extension, similar to the PLD 💡
* EU Machinery Regulation & harmonized standards (e.g., EN ISO 12100, EN ISO 13849, Draft EN 50742, ...)
* EU Low Voltage Directive & harmonized standards (e.g., EN 60204-1, EN 60335, EN 60730, …)
* UNECE Regulations (e.g., R79, R13, R13-H, R155 and related safety & cyber security standards (e.g., ISO 21434, …)
* Cyber Resilience Act (CRA) & to-be-harmonized standards: already require security patches over a product’s lifetime.
Are you ready for the new PLD? If you’re unsure how this affects your products, contact Jens Köhler and let’s talk! 👋 💬
Please keep in mind that we cannot provide legal advice.
