Short answer: Singapore has no general statute making manufacturers strictly liable for defective products. A customer usually claims in contract under the Sale of Goods Act 1979, in negligence, or, if a consumer, under the CPFTA lemon law. On receiving a claim, preserve the product and records, notify your insurer, admit nothing and check your supplier contracts.
A complaint that a product your company made, imported or sold has injured someone or caused a loss can arrive as an email, a social media post or a lawyer’s letter. This guide explains product liability Singapore law from the seller’s side: the legal routes, time limits, first steps, passing the claim up the supply chain, and when the regulator gets involved. If you are the buyer chasing a supplier, read our guide to rejecting defective goods under the Sale of Goods Act instead.
Key facts at a glance
- Where a seller sells goods in the course of a business, the goods must be of satisfactory quality, and safety is expressly one aspect of quality (Sale of Goods Act 1979, section 14(2) and (2B)(d)). This duty does not depend on fault.
- A business cannot use a contract term or notice to exclude liability for death or personal injury caused by negligence (Unfair Contract Terms Act 1977, section 2(1)).
- Against a consumer, the implied terms on description, quality, fitness and sample (Sale of Goods Act sections 13 to 15) cannot be excluded at all; against a business buyer, only so far as the term is reasonable (Unfair Contract Terms Act, section 6(2) and (3)).
- A consumer can ask for repair or replacement of goods that did not conform at delivery, and a defect appearing within 6 months of delivery is presumed to have existed at delivery (Consumer Protection (Fair Trading) Act 2003, sections 14 and 15).
- Personal injury claims: generally 3 years from the injury or from the date of knowledge if later (Limitation Act 1959, section 24A(2)). Contract and other tort claims: generally 6 years (section 6(1)).
- A claim for contribution against another party liable for the same damage must be brought within 2 years of the judgment or settlement (Limitation Act, section 6A).
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
What is a product liability claim, and does Singapore have a product liability law?
A product liability claim is a claim that a product was defective or unsafe and caused injury, property damage or financial loss. Singapore has no single product liability statute of the kind found in some other countries that makes producers strictly liable for defects; claims are brought under the general law of contract and negligence, supported by consumer protection statutes.
So who can sue you depends on your relationship with the claimant, and your defences depend heavily on your contracts with customers and suppliers.
| Who is complaining | Usual route against your company | Must they prove fault? |
|---|---|---|
| A business customer that bought from you | Breach of contract, including implied terms under the Sale of Goods Act 1979 | No, for breach of the implied terms |
| A consumer who bought from you | Contract, plus the lemon law remedies in Part 3 of the Consumer Protection (Fair Trading) Act 2003 (CPFTA) | No, for breach of the implied terms |
| Someone injured who did not buy from you, such as a family member or an end user of your distributor’s customer | Negligence against the manufacturer, importer or seller | Yes: duty of care, breach and causation |
Product liability Singapore: what is the legal basis for a claim?
The main sources are the Sale of Goods Act 1979, the Unfair Contract Terms Act 1977, the law of negligence and the CPFTA. Product safety regulations sit alongside them and are enforced by the regulator rather than by customers.
| Source | What it provides |
|---|---|
| Sale of Goods Act 1979, sections 13 and 15 | Goods must correspond with their description, and with the sample in a sale by sample |
| Sale of Goods Act 1979, section 14 | Goods sold in the course of a business must be of satisfactory quality (which includes safety and durability) and reasonably fit for any particular purpose the buyer made known |
| Unfair Contract Terms Act 1977, sections 2 and 6 | Limits on excluding liability for negligence and for the implied terms |
| Negligence | A manufacturer or supplier can owe a duty of care to people who use its products. Singapore courts decide whether a duty exists using the two-stage test in Spandeck Engineering (S) Pte Ltd v Defence Science & Technology Agency [2007] 4 SLR(R) 100, based on proximity and policy |
| CPFTA, Part 3 (sections 13 to 18) | Lemon law remedies for consumers: repair, replacement, price reduction or rescission for goods that did not conform to the contract at delivery |
| Consumer Protection (Safety Requirements) Regulations and Consumer Protection (Consumer Goods Safety Requirements) Regulations 2011 | Product safety rules enforced by the Consumer Product Safety Office, including registration of Controlled Goods, recalls and stop-sale directions |
| Civil Law Act 1909, section 15 | A person liable for damage can recover contribution from another person liable for the same damage |
For exclusion and limitation clauses in your own terms of sale, our guide to exclusion clauses and the Unfair Contract Terms Act explains the reasonableness test in more detail.
How does the lemon law change things for consumer sales?
Part 3 of the CPFTA applies where the buyer deals as consumer and the goods did not conform to the contract at delivery (section 14(1)). A defect appearing within 6 months of delivery is presumed to have existed at delivery unless the seller proves otherwise (section 14(3) and (4)), and the seller must prove that the buyer was not a consumer (section 13(3)). The consumer can require repair or replacement at the seller’s cost (section 15), then a price reduction or rescission if that fails or is disproportionate (section 16). These remedies deal with the goods themselves; a claim for injury or other loss still runs through contract or negligence. Our guide on what to do when a customer threatens a CPFTA claim covers the consumer complaint routes.
Who can claim, and how long do they have?
The buyer can sue the seller in contract; anyone who was injured or whose property was damaged can sue in negligence, including the manufacturer or importer they never dealt with. Time limits run from when the cause of action accrued, with extensions in negligence cases where the damage was not discovered.
| Claim | Time limit | Source |
|---|---|---|
| Breach of contract, including Sale of Goods Act implied terms | 6 years from the date the cause of action accrued | Limitation Act 1959, section 6(1)(a) |
| Negligence causing personal injury | 3 years from accrual, or 3 years from the earliest date the claimant had the required knowledge, if later | Limitation Act, section 24A(2) |
| Negligence causing other damage, such as property damage | 6 years from accrual, or 3 years from the date of knowledge, if later | Limitation Act, section 24A(3) |
| Overall cut-off for negligence claims under section 24A | 15 years from the last negligent act or omission | Limitation Act, section 24B |
| Contribution claim against another party liable for the same damage | 2 years from the judgment or award, or from the date the settlement amount is agreed | Limitation Act, section 6A |
A complaint may surface years after the sale, so keep product and batch records well beyond the usual period.
What should your company do when it receives a product liability claim?
Secure the evidence, notify your insurer and your supplier, and say nothing that admits fault. The first few days often decide whether the claim can be defended and whether insurance responds.
- Acknowledge the complaint in writing, without accepting that the product was defective or caused the harm. If someone is hurt, show concern and point them to medical help.
- Ask for the product back, or ask the customer to keep it unaltered. Never repair or dispose of a returned item; it is often the key evidence.
- Identify the batch or serial number and quarantine remaining stock from that batch.
- Notify your insurer and broker promptly. Liability policies commonly require prompt notice and forbid admissions or settlements without the insurer’s consent.
- Give written notice to your supplier or manufacturer, with the batch details, and ask for its test reports.
- Preserve emails, sales records, instructions, warnings and earlier complaints about the same item; see our guide to a litigation hold.
- Assess whether a stop-sale, customer notice or recall is needed (see below).
- Instruct a law firm before replying on the merits, especially for personal injury or a lawyer’s letter.
If the injury happened on your shop floor rather than through use of the product, see our guide for when a customer is injured on business premises, which covers the State Courts pre-action steps for personal injury claims.
Can you pass the claim back up the supply chain, and will insurance cover it?
Usually yes, at least in part. A retailer or distributor that pays a customer can claim against its own supplier for breach of the same implied terms, and can seek contribution from anyone else liable for the same damage.
- Your own contract claim. Your supplier sold to your company in the course of business, so it gave you the same section 14 terms, subject to any reasonable exclusion. Check your supply agreement for warranties, indemnities, liability caps and notice periods.
- Contribution. Under section 15 of the Civil Law Act 1909, you can recover contribution from another person liable for the same damage, within the 2-year limit in section 6A of the Limitation Act.
- Foreign suppliers. If the manufacturer is overseas, recovery may depend on the governing law and jurisdiction clause in your supply contract.
On insurance, product liability cover may be a standalone policy or an extension to a public liability policy, so check that it covers products your company supplied and note its notice conditions. If the insurer declines, our guide on an insurance claim rejected in Singapore sets out how to challenge it.
Does a safety defect mean a recall or a report to the regulator?
It can. The Consumer Product Safety Office (CPSO), which is overseen by the Competition and Consumer Commission of Singapore, enforces the Consumer Protection (Safety Requirements) Regulations (CPSR) and the Consumer Protection (Consumer Goods Safety Requirements) Regulations 2011 (CGSR). The CPSO treats manufacturers, importers, distributors and retailers all as suppliers responsible for product safety.
| Regime | What it covers | Enforcement powers and penalties (as stated by the CPSO) |
|---|---|---|
| CPSR | 33 categories of Controlled Goods, mainly household electrical, electronic and gas products, which must be tested, registered and carry the SAFETY Mark before sale | Suspension or prohibition of Controlled Goods; mandatory recall. Selling unregistered Controlled Goods: fine up to S$10,000, imprisonment up to 2 years, or both. A Registered Supplier who fails to recall: fine up to S$2,000, imprisonment up to 12 months, or both |
| CGSR | General consumer goods, which should meet relevant internationally accepted safety standards | Direction to stop sale and to inform users of the danger. Failure to comply: on first conviction, fine up to S$2,000, imprisonment up to 12 months, or both; on a subsequent conviction, fine up to S$10,000, imprisonment up to 2 years, or both |
A recall can be voluntary, started by the supplier, or mandated by the authority, and the information the CPSO needs differs between the two. The CPSO’s page on suspension and recall of goods explains the process. Some products, such as food, medicines and health products, are regulated under separate legislation, so check which regime applies to your product.
What documents will the law firm and insurer need, and what will it cost?
They need evidence of what was sold, to whom, on what terms, and how the product was made, tested and supplied. Costs depend on whether the claim settles early or needs expert testing and court proceedings.
| Document | Why it matters |
|---|---|
| The complaint, letter of claim and any photographs or medical reports supplied | Shows what is alleged and starts the response timetable |
| Invoice, order confirmation and your terms of sale | Shows whether the buyer is a consumer or a business, and any exclusion or limitation clause |
| The product itself, packaging, instructions and warning labels | Physical evidence of the alleged defect and of the warnings given |
| Batch records, test certificates and, for Controlled Goods, registration and SAFETY Mark records | Shows compliance with safety standards and helps trace other affected units |
| Supply agreement, purchase orders and supplier correspondence | Supports your claim over against the supplier |
| Insurance policy, schedule and notification email | Proves cover and timely notice |
| Cost item | What drives it |
|---|---|
| Solicitors’ fees | Value of the claim and whether it settles before proceedings |
| Expert testing | Type of product and the alleged failure |
| Damages or settlement | Severity of the injury or loss, the user’s own fault, and what you recover from the supplier |
Ask your solicitor for a written fee estimate before proceedings start. We do not quote solicitors’ fees here.
What does the company secretary prepare, and what does the solicitor file?
Your company secretary or corporate service provider (CSP) assembles the corporate records, board approvals and documents. Any court proceedings are conducted by a Singapore Advocate and Solicitor, who advises on liability and handles all correspondence on the merits and every court filing.
| Company secretary or CSP | Singapore Advocate and Solicitor |
|---|---|
| Directors’ resolution appointing the law firm and authorising a director to deal with the insurer and approve any settlement within a stated limit | Advice on liability, the exclusion clauses and the limitation position |
| ACRA business profile and an indexed bundle of contracts, invoices and supplier correspondence | Replies to the letter of claim, the defence and any third-party claim against the supplier |
| Note of any provision or contingent liability for the financial statements | Instructions to product testing experts |
A product liability claim, or its settlement, does not by itself require an ACRA lodgement. Record the board decisions in minutes and reflect the claim in the accounts as your accountant advises. Raffles Corporate Services does not give legal advice or act in court; a law firm from our panel handles the claim. If a lawyer’s letter has arrived, speak to a lawyer before replying.
What are the common mistakes?
Most avoidable losses come from what the company says, discards or forgets in the first weeks.
- Offering compensation or admitting a defect before the insurer has been notified, which can put cover at risk.
- Throwing away or repairing the returned product, so neither side can test it.
- Relying on a disclaimer in the terms of sale to exclude liability for personal injury, which section 2(1) of the Unfair Contract Terms Act does not allow.
- Notifying the supplier late, or missing the 2-year contribution limit after settling.
- Selling the same batch after a safety complaint without assessing whether a stop-sale or recall is needed.
Frequently asked questions
Can someone who did not buy the product sue our company?
Yes, in negligence. They must show that your company owed them a duty of care, breached it, and that the breach caused their injury or loss. They cannot sue you in contract unless they were a party to the contract.
Can our terms of sale exclude liability for defective goods?
Against consumers, the implied terms on description, quality, fitness and sample cannot be excluded. Against business buyers, an exclusion is valid only if it satisfies the reasonableness requirement. Liability for death or personal injury caused by negligence cannot be excluded against anyone (Unfair Contract Terms Act 1977, sections 2 and 6).
We only import and resell. Are we still exposed?
Yes. As the seller, your company gives its buyers the implied terms under the Sale of Goods Act, and the CPSO treats importers, distributors and retailers as suppliers responsible for safety. Your protection is your own claim against the overseas manufacturer and your insurance.
How long can a customer wait before suing for an injury?
Generally 3 years from the injury, or 3 years from when the person first had the knowledge needed to sue, if later, subject to a 15-year overall limit (Limitation Act 1959, sections 24A(2) and 24B).
Need help with this?
Raffles Corporate Services can handle the ACRA filings, compliance documentation and records for you, and where court proceedings or legal advice are needed, we work with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice.
Email: [email protected]
Call, SMS or WhatsApp: +65 8501 7133
Last reviewed: 5 November 2026. The Editorial Team, Raffles Corporate Services.