Dis­tri­bu­tors with the sta­tus of manu­fac­tu­r­ers from the view­point of pro­duct lia­bi­li­ty law

Fede­ral Supre­me Court ruling on clas­si­fi­ca­ti­on as a manu­fac­tu­rer and dis­tri­bu­tors’ duties to safe­guard traffic

By Judgment of 21 March 2023 (Case No: VI ZR 1369/20), Ger­many’s Fede­ral Supre­me Court gran­ted an appeal by a far­mer who had brought an action see­king dama­ges against a was­te dis­po­sal com­pa­ny. The cour­t’s ruling essen­ti­al­ly dealt with the ques­ti­on of whe­ther the defen­dant qua­li­fies as a manu­fac­tu­rer and the duties of a dis­tri­bu­tor to safe­guard traf­fic within the con­text of pro­du­cer’s lia­bi­li­ty in accordance with § 823(1) of the Civil Code.

Facts of the case

The start­ing point of the case was an action filed by a far­mer against a was­te dis­po­sal com­pa­ny (the defen­dant). In the cour­se of its com­mer­cial acti­vi­ties, the defen­dant had acqui­red a phosphate- and potassium-based flu­id which was con­ta­mi­na­ted with her­bici­des from a third par­ty  as “was­te,” which it then ren­a­med “EC fer­ti­li­zer for far­ming,” pre­pa­ring asso­cia­ted pro­duct infor­ma­ti­on which iden­ti­fied the flu­id as fer­ti­li­zer. It then sold the flu­id as fer­ti­li­zer to a dis­tri­bu­tor, through which it ulti­m­ate­ly rea­ched the far­mer. Use of this con­ta­mi­na­ted flu­id, which was label­led as fer­ti­li­zer, cau­sed dama­ges to the far­mer’s rape plants. The plain­ti­ff asser­ted claims against the defen­dant see­king com­pen­sa­ti­on for assess­ment and rec­ti­fi­ca­ti­on of the damages.

Duties of distributors

The decisi­ve ques­ti­on in terms of pro­du­cer’s lia­bi­li­ty in tort law in accordance with § 823(1) of the Civil Code, which is the form of lia­bi­li­ty which comes into con­side­ra­ti­on in the pre­sent case, is whe­ther a per­son enga­ged in the manu­fac­tu­re or dis­tri­bu­ti­on of a pro­duct brea­ched its duties to safe­guard traf­fic. Whe­ther such a per­son had duties to safe­guard traf­fic, and if so which ones, depends on the capa­ci­ty in which that per­son acted. Pro­duct manu­fac­tu­r­ers are natu­ral­ly sub­ject to the most exten­si­ve duties to safe­guard traf­fic (e.g. duties rela­ting to design and fabri­ca­ti­on). Dis­tri­bu­tors, on the other hand, have only limi­t­ed duties to safe­guard traf­fic; in par­ti­cu­lar, they have no duties with respect to design and fabri­ca­ti­on. As a result, dis­tri­bu­tors are gene­ral­ly excluded from pro­du­cer’s lia­bi­li­ty for design and fabri­ca­ti­on defects.

Dis­tri­bu­tors with the sta­tus of manufacturers

But in cer­tain cases, in the cour­se of their acti­vi­ties, dis­tri­bu­tors may be con­side­red as manu­fac­tu­r­ers in terms of § 823(1) of the Civil Code, a sta­tus which comes with more exten­si­ve duties to safe­guard traf­fic. This may be the case, for exam­p­le, if the dis­tri­bu­tor makes chan­ges to the product.

In the pre­sent case, the Hig­her Regio­nal Court of Koblenz ruled that the defen­dant did not qua­li­fy as a manu­fac­tu­rer becau­se it did not make any chan­ges to the flu­id. But the Fede­ral Supre­me Court found that it did qua­li­fy as a manu­fac­tu­rer after all. As ground for this fin­ding, the Fede­ral Supre­me Court cited the fact that defen­dant its­elf acqui­red the flu­id as “was­te” and then resold it as “EC fer­ti­li­zer for far­ming,” with pro­duct infor­ma­ti­on to match. In so doing, the court found that the defen­dant had crea­ted an enti­re­ly new pro­duct, despi­te the fact that it made no chan­ges to the flu­id its­elf. As a result, the court found that the defen­dant should be clas­si­fied as the manu­fac­tu­rer, and is the­r­e­fo­re requi­red to com­ply with more exten­si­ve duties to safe­guard traffic.

Whe­ther and to what ext­ent ascer­tai­ning that the flu­id was con­ta­mi­na­ted (and con­se­quent­ly avo­i­ding its use) was part of the defen­dan­t’s more exten­si­ve duties to safe­guard traf­fic must now be deter­mi­ned by the appel­la­te court (Hig­her Regio­nal Court of Koblenz), which is now requi­red to retry the case in light of the Fede­ral Supre­me Cour­t’s judgment and issue a new ruling. It is clear, howe­ver,  that a stric­ter stan­dard must be appli­ed with regard to the defen­dan­t’s duties of due care, con­tra­ry to the pre­vious ruling by the appel­la­te court.

Con­clu­si­on

The judgment will have a prac­ti­cal impact, in that dis­tri­bu­tors should be awa­re of the fact that they may be clas­si­fied as manu­fac­tu­r­ers in terms of pro­duct lia­bi­li­ty law even if they make no actu­al chan­ges to the pro­duct, if the other cir­cum­s­tances of the case jus­ti­fy such an assump­ti­on. This may occur, as e.g. in the pre­sent case, if the pur­po­se of the pro­duct is alte­red, resul­ting in the crea­ti­on of an enti­re­ly new product.

Even if they do not qua­li­fy as manu­fac­tu­r­ers, dis­tri­bu­tors should keep in mind that they may have duties of inspec­tion with respect to the pro­ducts they dis­tri­bu­te. Exami­na­ti­on of the pro­ducts by the dis­tri­bu­tor may be requi­red if the­re is spe­ci­fic cau­se for an inspec­tion, e.g. if dama­ges from use of the pro­duct have alre­a­dy been repor­ted or if the cir­cum­s­tances of the indi­vi­du­al case sug­gest the need for review (cf. e.g. Fede­ral Supre­me Court, Judgment of 11 Decem­ber 1979 –Case No.  VI ZR 141/78, NJW 1980, 1219).

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