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EU Product Liability Directive Art. 4(1): software, incl. AI systems, as a product

Software is a product, so the manufacturer of an AI system is strictly liable for damage caused by a defect in a product placed on the market or put into service after 2026-12-09

By Reviewed

From clause to evidenceThe chain from EU PLD Art. 4(1) to its evidence record, in 6 steps; the text alternative lists them and the facts under the figure state each in full.Clause: Product Liability Directive (EU) 2024/2853, Art. 4(1)ClauseEU PLDArt. 4Duty holder: Manufacturers and other economic operatorsDuty holderManufacturersand other…Applies from: 2026-12-09 (Applies later)Applies from2026-12-09Applies laterArtefact: Defect-liability review at design; contractual recourse; residual risk in the registerArtefactDefect-liabilityreview at…Layers: Layer 01 Govern-as-Code and Layer 05 Assurance & Continuous ComplianceLayersLayer 01Layer 05Evidence record: the common evidence record (Evidence record v1)Evidence recordEvidence recordv1Same topic elsewhere: no crosswalk topic files this clause yetAs of 2026-09-24 · illustrative, not a claim of conformity From clause to evidenceThe chain from EU PLD Art. 4(1) to its evidence record, in 6 steps; the text alternative lists them and the facts under the figure state each in full.Clause: Product Liability Directive (EU) 2024/2853, Art. 4(1)ClauseEU PLD · Art. 4Duty holder: Manufacturers and other economic operatorsDuty holderManufacturers and other economic…Applies from: 2026-12-09 (Applies later)Applies from2026-12-09 · Applies laterArtefact: Defect-liability review at design; contractual recourse; residual risk in the registerArtefactDefect-liability review at designLayers: Layer 01 Govern-as-Code and Layer 05 Assurance & Continuous ComplianceLayersLayer 01Layer 05Evidence record: the common evidence record (Evidence record v1)Evidence recordEvidence record v1Same topic elsewhere: no crosswalk topicfiles this clause yetAs of 2026-09-24illustrative, not a claim of conformity
From clause to evidence Build the artefact, then file every output it produces as a record that names AIGE-OBL-PLD-ART4. Drawn from chapter 08.
Text alternative
  • Clause: EU PLD, Art. 4.
  • Duty holder: Manufacturers and other economic….
  • Applies from: 2026-12-09, Applies later.
  • Artefact: Defect-liability review at design.
  • Layers: Layer 01, Layer 05.
  • Evidence record: Evidence record v1.
  • Record schema: Evidence record.
  • No crosswalk topic files this clause yet.
When this obligation appliesThe date of AIGE-OBL-PLD-ART4 on a time axis, against its review date 2026-09-24.2024202620282030As of 2026-09-242026-12-09 · Applies laterProducts placed on the marketor put into service after2026-12-09 (Art. 2(1));transposition by 2026-12-092026-12-09 · Applies later · Products placed on the market or put into service after 2026-12-09 (Art. 2(1)); transposition by 2026-12-09Source: Obligation register(chapter 08)
When this obligation appliesThe date of AIGE-OBL-PLD-ART4 on a time axis, against its review date 2026-09-24.2026-12-09 · Applies laterProducts placed on the market or put into service after2026-12-09 (Art. 2(1)); transposition by2026-12-092024202620282030As of 2026-09-242026-12-09 · Applies later · Products placed on the market or put into service after 2026-12-09 (Art. 2(1)); transposition by 2026-12-09Source: Obligation register (chapter 08)
When this obligation applies The first date in the row's status, then each later step: filled once its date has passed, outlined while it is still ahead of the review date.
Data table: the dates
Dates of AIGE-OBL-PLD-ART4
DateStepDetail
2026-12-09Applies laterProducts placed on the market or put into service after 2026-12-09 (Art. 2(1)); transposition by 2026-12-09
Id
AIGE-OBL-PLD-ART4
Instrument
Product Liability Directive (EU) 2024/2853 law
Clause
Art. 4(1)
In scope
Manufacturers and other economic operators
Authority
National courts
Applies from
Applies later · Products placed on the market or put into service after 2026-12-09 (Art. 2(1)); transposition by 2026-12-09

The artefact that evidences it

Defect-liability review at design; contractual recourse; residual risk in the register.

Patterns that build it

No pattern in the catalogue names this clause on its "Maps to" line yet; the artefact above is the engineering answer.

Source

Chapter 08, section Liability, copyright, consumer and sector law, checked against its sources on the review date above.

Machine-readable

Cite this obligation

García Aibar, J. (2026). EU Product Liability Directive Art. 4(1): software, incl. AI systems, as a product (AIGE-OBL-PLD-ART4). In AI Governance Engineering: The Thesis & Body of Knowledge (v0.5.0). https://doi.org/10.5281/zenodo.22956197. https://aigovernanceengineer.com/obligations/aige-obl-pld-art4. CC BY 4.0

BibTeX

@misc{aige2026obligation,
  author       = {Jorge García Aibar},
  title        = {{EU Product Liability Directive Art. 4(1): software, incl. AI systems, as a product (AIGE-OBL-PLD-ART4)}},
  howpublished = {In AI Governance Engineering: The Thesis \& Body of Knowledge},
  year         = {2026},
  version      = {0.5.0},
  doi          = {10.5281/zenodo.22956197},
  url          = {https://aigovernanceengineer.com/obligations/aige-obl-pld-art4},
  note         = {Version 0.5.0}
}