Michiel Poesen, az Aberdeen Egyetem oktatójának angol nyelvű vendégelőadása.

Az előadás összefoglalója angolul alább olvasható:

In 2024, the European Union adopted a revised Product Liability Directive. One of the Directive’s main objectives is to “AI-proof” the EU product liability framework, notably by facilitating access to justice for victims harmed by artificial intelligence (AI). While the Directive establishes a harmonised regime for product liability within the EU, non-EU jurisdictions may adopt substantially different – and, potentially, less victim-friendly – approaches to product liability for defective AI.ú

This lecture examines the enforcement of the EU Directive in cross-border product liability cases relating to defective AI. It addresses several questions: Do victims based in the EU have access to the courts of EU Member States even when the manufacturer of an AI product is established outside the EU? Will the courts of the Member States apply the product liability rules of a non-EU country, even where those rules provide a lower level of protection for victims of AI-related harm? And can EU courts obtain access to relevant evidence in product liability claims concerning defective AI when such evidence is located outside the EU?

The lecture argues that, despite the Directive’s ambitions, several legal and practical gaps remain that may undermine the effective enforcement of EU product liability rules in cross-border AI-related product liability cases.