This orientation helps manufacturers, integrators and factory operators identify the records and contractual boundaries that matter. It does not replace an engineering safety assessment, accident investigation or advice on a particular claim.
Three overlapping responsibility tracks
A single incident can engage several legal and technical tracks. Product-liability questions concern whether a defect in the supplied product caused damage. The Civil Code states that a manufacturer bears tort liability when a product defect causes damage and permits an injured person to claim against the manufacturer or seller. Allocation between commercial parties may then depend on who caused the defect and on rights of recovery.
Work-safety duties remain important even when a supplied component is defective. A factory operator should therefore avoid treating a supplier warranty or indemnity as a substitute for guarding, training, inspection and safe operating procedures. Contract liability is a third track: specifications, acceptance records, change-control clauses and maintenance obligations can determine the recourse available between the purchaser, integrator and component suppliers.
Robot-specific standards to identify
The National Public Service Platform for Standards identifies GB 11291.1-2011 as the current mandatory standard for industrial robots and GB 11291.2-2013 as the current standard for robot systems and integration. Both standards are under revision, so a project file should record the edition used at design, acceptance and any later modification.
GB/T 20867.1-2024, effective from 1 March 2025, is the current application specification for industrial-robot safety requirements. The official standards record describes it as supporting the design, installation, commissioning, operation and maintenance of industrial robots. Other standards may apply to the complete cell, electrical equipment, end effectors or a particular industry. Listing a standard in a contract is useful only if the parties also define the required tests, evidence and acceptance result.
Map the actors before allocating liability
- Robot manufacturer: robot design, manufacturing conformity, supplied safety functions, instructions and identified limitations.
- System integrator: cell layout, end effector, guarding, interlocks, control logic, risk reduction and validation of the integrated application.
- Factory operator: workplace controls, training, access restrictions, maintenance, inspections and management of operating changes.
- Component or software supplier: the performance and limitations of a supplied part, sensor, controller or update.
- Maintenance contractor: work performed, bypasses or parameter changes, testing and restoration of protective measures.
These are investigation headings, not automatic conclusions. One company may perform several roles, and a later modification can move the relevant failure away from the original robot and toward the integrated cell or its operation.
Evidence to preserve after an incident
- The purchase specification, risk assessment and applicable-standards register.
- Cell drawings, safety-distance calculations, guarding and interlock design.
- Factory and site acceptance tests, safety-function validation and sign-off records.
- PLC, robot-controller and safety-controller versions, parameters, logs and backups.
- Modification, override, maintenance, alarm and remote-access records.
- Instructions, warning labels, training records and operator authorizations.
- Photographs, video and physical evidence preserved before repair or recommissioning.
Teams should preserve data promptly and control access to the equipment. Recreating settings or replacing components before the evidence is captured may make it harder to determine whether the event arose from design, integration, modification, maintenance or operation.
Contract points worth defining before commissioning
- The boundary between the robot, the complete cell and the factory's surrounding equipment.
- Who performs the application risk assessment and who validates each safety function.
- Required manuals, labels, source files, configuration backups and test records.
- Acceptance criteria, unresolved-defect procedures and authority to approve deviations.
- Rules for software updates, remote access, replacement parts and field modifications.
- Incident notification, evidence preservation, technical cooperation and recall support.
- Indemnity, limitation-of-liability and insurance provisions aligned with the actual work split.
Primary sources
Related research: China robotics hub, product-liability counsel, and employment and workplace guidance.
General information only, not legal advice or product-safety certification. Last reviewed: October 2026.
