中国と日本における欠陥製品に関する回収義務を負う者の認定について
Determination of the person responsible for the recall of defective products in China and Japan 중국과 일본의 결함제품에 관한 회수의무를 짊어질 자에 대한 인정에 대하여
This paper mainly describes the legal provisions in China and the judicial precedents mainly in Japan in order to establish a concrete standard for the recognition of the person who has the obligation to recall the defective products,and analyze them from the comparative legal viewpoint. The importance and the necessity of the recognition of the responsibility subject in the constitutive requirements of non-typical omission.