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National Practice Guide · L3

Industrial Robot Safety and Product Liability in China: Orientation

Integrators and OEMs ask: Who is liable when a robot cell injures a worker—the manufacturer, the integrator, or the factory? Allocation depends on design defects, modifications, warnings, and employment safety duties. This orientation supports contracting and risk design.

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Updated2 Aug 2026
AudienceForeign businesses & individuals
Author China Legal Portal Editorial · Last reviewed · 1 min read · Editorial policy · AI content policy · Disclaimer · Not legal advice — confirm current rules with counsel and authorities
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Hub: Robotics hub · Product lawyers: Product liability · Employment: Employment guide · NNN: Manufacturing NNN.

Actors and typical duties

  • Manufacturer — design/manufacture defects, instructions, software updates
  • Integrator / system builder — cell design, guarding, PLC logic, modifications
  • End-user factory — safe workplace, training, lockout/tagout, maintenance
  • Component supplier — defective parts cascading into system liability

Contract levers

  • Scope of supply and accepted modifications
  • Acceptance tests and safety validation records
  • Warning labels and Chinese manuals as deliverables
  • Indemnities and insurance minimums
  • Software update and remote access responsibilities
  • IP/NNN for cell designs shared with China plants

Checklist

  • [ ] Risk assessment documented for each cell design
  • [ ] Chinese safety instructions delivered and acknowledged
  • [ ] Change-control process for field modifications
  • [ ] Incident investigation and evidence preservation SOP
  • [ ] Insurance covers product + professional liability as needed
  • [ ] AI vision/voice features reviewed under privacy/AI rules if present

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General information only—not product safety certification advice. Last reviewed: August 2026 · China Legal Portal Editorial

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