Product liability rules worldwide Japan, US and Turkiye

Absztrakt

The present article is to examine the similarities and differences in the methods for regulating product liability issues within very differing countries, owing different legal culture and located in distant geographical areas, namely USA, Japan and Türkiye. These countries have a decisive economic influence on the world market that is growing with the effect of mass production worldwide. The USA was the cradle of product liability law, and now, it has spread to all countries. As a result of the global development and the national reception or adoption of existing legal solutions, a rich body of sources is available for a comparative analysis, which was the main research method used for preparing this work. This study analyses these above-mentioned adaptation processes. In addition, the analysis of these national regulations or legislative approaches may also provide insights into the future developments. The aim is to examine whether the additions made by the countries concerned to the law of another country can preserve the originality of their national law. Contrasting these product liability national regimes, this study scrutinizes how the chosen countries can maintain the originality of their national law during the adaptation of foreign legal solutions and phenomena.