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The United States, the United Kingdom, and Japan developed their product liability laws based on a common desire to protect consumers. Although these regimes are similar in many ways, due to cultural differences, it seems there will always be differences. U.S. and British strict product liability regimes date back to the nineteenth and early twentieth century. Japan's strict product liability regime, however, is still in its infancy. By examining the development of strict product liability in each of these countries, focusing on statutory and common law language, as well as the position of, structure of, and access to the judiciary, this Note concludes, due to the similarities between the United Kingdom and Japan-similarities generally not existing with respect to the United States-that Japan is more likely to develop its product liability regime in accordance with the United Kingdom, rather than the United States.


File nameDate UploadedVisibilityFile size
6 Sep 2022
2.09 MB



  • Subject
    • Comparative and Foreign Law

    • Consumer Protection Law

  • Journal title
    • Boston College International and Comparative Law Review

  • Volume
    • 23

  • Issue
    • 2

  • Pagination
    • 311

  • Date submitted

    6 September 2022