Responsabilité du fait des produits défectueux

Responsabilité du fait des produits défectueux

  • Posted by Loïc Panhaleux
  • On 25 novembre 2011
  • 5805 Comments

accident iconLe Conseil des communautés européennes a adopté une directive le 25 juillet 1985 relative à la responsabilité du fait des produits défectueux.La transposition de cette directive a été effectuée en droit français avec retard par la loi du 19 mai 1988 qui a introduit les articles 1386-1 à 1386-18 dans le code civil (10 ans de retard, ce qui a conduit la Cour de cassation à appliquer le texte “par anticipation”  : v. civ. 1re, 9 juill. 1996, bull. civ. I n 304) qui précisent le domaine et le régime de cette responsabilité spécifique. 

A. Le domaine de la responsabilité

1. Application des dispositions relatives aux produits défectueux et autres actions de la victime

Conformément à l’article 1386-18 al .1 du code civil : “Les dispositions du présent titre ne portent pas atteinte aux droits dont la victime d’un dommage peut se prévaloir au titre du droit de la responsabilité contractuelle ou extracontractuelle ou au titre d’un régime spécial de responsabilité.”.

L’acheteur dispose donc de la possibilité de cumuler l’application des dispositions de la loi nouvelle avec les actions classiques lui permettant d’obtenir réparation du préjudice subi. Toutefois, à la lecture d’un arrêt du 25 avril 2002, on peut se demander dans quelle mesure une action fondée sur l’article 1384 al. 1 du code civil pourrait être engagée dans la mesure où seuls sont applicables les régimes de responsabilité contractuelle ou extracontractuelle reposant sur des fondements différents tels que la garantie des vices cachés ou la faute”(CJCE 25 av. 2002, aff. C52/00 : D. 2002. AJ 1670, obs. Rondey).(Autrement dit, l’acheteur pourra agir sur le fondement de l’obligation de renseignement, sur le fondement de la garantie des vices cachés).On pouvait même se demander si une personne ne pouvait pas toujours agir sur le fondement de l’obligation de délivrance du vendeur en arguant du défaut de sécurité du produit.

Mais dans ce même arrêt du 25 avril 2002, la CJCE a considéré que “L’article 13 de la directive ne pouvait être interprété comme laissant aux Etats membres la possibilité de maintenir un régime général de responsabilité du fait des produits défectueux différent de celui prévu par la directive”.En conséquence, il y a lieu de considérer que la jurisprudence précédemment applicable est devenue obsolète en ce qu’elle prévoit des solutions différentes de celles qui résultent de la directive. Hors du champ d’application de la directive, elle conserve son intérêt (v. infra à propos du dommage).

Par ailleurs, le domaine d’application de la loi nouvelle ne permet pas d’agir dans certaines hypothèses (v. article 1386-6 dern. al du code civil qui exclut l’application de la loi lorsque les articles 1792 à 1792-6 et 1646-1 du code civil sont applicables) de sorte que, dans certaines rares hypothèses, la jurisprudence ancienne pourra conserver une certaine utilité.

2. Domaine de l’obligation de sécurité du produit

i) personnes concernées

– responsables

Aux termes de l’article 1386-1 in limine du code civil “Le producteur est responsable du dommage causé par défaut de son produit..” Est producteur selon l’article 1386-6 du code civil le fabricant d’un produit fini, le producteur d’une matière première, le fabricant d’une partie composante qui agit à titre professionnel”.

On doit y assimiler toute personne agissant à titre professionnel : “qui se présente comme producteur en apposant sur le produit son nom, sa marque ou un autre signe distinctif ” ou encore ” qui importe un produit dans la CE en vue d’une vente, d’une location avec sou sans promesse de vente, ou de toute autre forme de distribution (1386-6 1 et 2)”.

De même, la loi concerne les vendeurs ou loueurs, à l’exception du crédit-bailleur ou du loueur assimilable au crédit-bailleur, ou toute autre fournissseur professionnel (1386-7 al. 1 du code civil). Mais sur ce point également, la transposition n’est pas correcte. Selon l’arrêt du 25 avril 2002, la directive n’assimile pas le distributeur ou fournisseur au producteur. Ce n’est que lorsque le producteur est inconnu que la responsabilité du distributeur ou du fournisseur peut être recherchée. Il s’agit donc d’une possibilité subsidiaire d’obtenir réparation.

Enfin, ne peut être considéré comme producteur celui dont la responsabilité peut être recherchée sur le fondement des article 1792 à 1792-6 et 1646-1 du code civil.

– victimes

Les victimes, c’est-à-dire les personnes qui ont subi un préjudice à cause d’un produit défectueux, qu’elles soient parties ou tiers à un contrat avec le producteur peuvent demander réparation de leur préjudice.Cela vise donc toutes les personnes qui subissent un préjudice du fait du produit. Cela protége aussi bien les professionnels que les consommateurs.

Il n’y a pas en principe à distinguer selon que le préjudice a été subi par une partie au contrat ou par un tiers, à distinguer responsabilité contractuelle et délictuelle. La distinction peut cependant conserver un intérêt du point de vue de la compétence des juridictions et quant aux clauses limitatives de responsabité.

ii) produits visés

Ce sont tous les biens meubles, même s’ils sont incorporés dans un immeuble. Cela vise notamment les produits du sol, de l’élevage, de la chasse et de la pêche. L’électricité est considérée comme un produit (article 1386-3 du ciode civil). L’on peut également considérer les programmes d’ordinateurs comme un meuble (rép. min.24 aout 1998). Cela vise encore les éléments du corps humain ou les produits issus de ce corps (v. art. 1386-12 du code civil).

B. Mise en œuvre de la responsabilité

1. Conditions de la responsabilité

La victime doit prouver son préjudice et le fait qui l’a généré (art. 1386-9 du code civil).

Tous les préjudices ne sont pas indemnisables à ce titre. L’article 1386-2 du code civil indique que les dispositions du présent titre s’appliquent à la réparation du dommage qui résulte d’une atteinte à la personne ou à un bien autre que le produit défectueux lui-même. Mais là encore, la transposition est insuffisante. L’article 9 de la directive fait référence à une franchise de 500 écus dans le cas des dommages aux biens. Il faut donc considérer que lorsque le préjudice est inférieur à 500 €, le demandeur ne saurait invoquer les articles 1386 et s. du code civil : il doit agir selon le droit commun (v. points 30 et s. de la décision du 25 avril 2002).

En outre, la loi ne distingue pas selon que la chose a été utilisée à titre privée ou professionnel alors que la directive distingue :

Article 9

Au sens de l’article 1er, le terme «dommage» désigne:

a) le dommage causé par la mort ou par des lésions corporelles;

b) le dommage causé à une chose ou la destruction d’une chose, autre

que le produit défectueux lui-même, sous déduction d’une franchise

de 500 Écus, à conditions que cette chose:

i) soit d’un type normalement destiné à l’usage ou à la consommationprivés

et

ii) ait été utilisée par la victime principalement pour son usage ou sa

consommation privés.

Le présent article ne porte pas préjudice aux dispositions nationales

relatives aux dommages immatériels.

La victime ne doit pas prouver la faute du producteur mais seulement le défaut du produit. Le produit est défectueux lorsqu’il n’offre pas la sécurité à laquelle on peut légitimement s’attendre (1386-4 al. 1 du code civil).On doit tenir compte de “toutes les circonstances et notamment de la présentation du produit, de l’usage qui peut en être raisonnablement attendu et du moment de sa mise en circulation” (al. 2).

En toute hypothèse,un produit ne peut être considéré comme défectueux du seul fait qu’un autre, plus perfectionné, a été mis postérieurement en circulation (art. 1386-4 al. 3 du code civil).

Cela soulève une incertitude quant à l’objet de la preuve de la victime. Le danger peut provenir d’une mauvaise utilisation du produit (incompatibilité ou défaut de renseignement). Le défaut ne doit pas être confondu avec le vice caché. En vérité, ce sont les conséquences du défaut qui permettent de tracer la limite entre les vices cachés et l’obligation de sécurité. La seconde ne concerne que les dommages aux personnes ou aux biens autre que le produit défectueux lui-même (art. 1386-2 du code civil).

2. Mise en oeuvre de la responsabilité

a) Délais pour agir

La victime doit agir dans un délai de 3 ans à compter de ” la date à laquelle le demandeur a eu ou aurait dû avoir connaissance du dommage, du défaut et de l’identité du producteur” (1386-17 du code civil).

En outre, l’action en responsabilité ne peut plus être intentée dix ans après la mise en circulation du produit (1386-16), cad à compter du jour où le producteur s’en est dessaisi volontairement (1386-5 du code civil). Cette seconde limite ne vaut cependant qu’en l’absence de faute du producteur. Mais en quoi consiste la faute ? Peut-on considérer qu’un défaut d’information constitue une faute ? En outre, une difficulté surgit en cas d’intégration d’un composant d’une partie dans un nouveau produit.

b) Possibilités d’exonération

Conformément à l’article 1386-15 cciv.al. 1 , “les clauses visant à écarter oou limiter la responsabilité du fait des produits défectueux sont interdites et réputées non écrites”. Toutefois, le second alinéa comprend une exception dans le cas des “dommages causés aux biens qui ne sont pas utilisés par la victime principalement pour son usage ou sa consommation privée, les clauses stipulées entre professionnels sont valables”.

Aucun plafond d’indemnisation n’a été admis par la loi française bien que la directive de 1985 ait envisagé cette possibilité (art 16 de la directive.)

Mais le professionnel peut s’exonérer de sa responsabilité dans certains cas. Ces hypothèses sont prévues notamment par l’article 1386-11 du code civil). Il en va ainsi s’il prouve qu’il n’avait pas mis le produit en circulation, s’il prouve que le défaut est survenu après la mise en circulation du produit, que le produit n’était pas destiné à la vente ou à toute autre forme de distribution, ou que le défaut ne lui était pas imputable conformément à l’art. 1386-11 dern. al. du code civil).

Il peut s’exonérer s’il prouve que l’état des connaissances scientifiques et techniques, au moment où il a mis le produit en circulation, n’a pas permis de déceler l’existence du défaut (1386-11 4° du code civil). La cour de justice a eu l’occasion de préciser cette cause d’exonération. Son appréciation apparaît assez restrictive dans la mesure où elle a posé des exigences importantes quant aux connaissances scientifiques du producteur (niveau le plus avancé des connaissances et état objectif des connaissances dont il devait ou pouvait être informé (CJCE 29 mai 1997, J.C.P. 1997.1.4070, obs. G. Viney).

Il peut encore s’exonérer si le défaut est dû à la conformité du produit avec des règles impératives d’ordre législatif ou réglementaire (1386-11 5 du code civil). Toutefois, l’article 1386-10 précise que le producteur peut être reponsable du défaut alors même que le produit a été fabriqué dans le respect des règles de l’art ou de normes existantes ou qu’il a fait l’objet d’une autorisation administrative.

Mais selon l’article 1386-12 al. 2, les possibilités d’exonération prévues aux 4° et 5° de l’article 1386-11 du code civil ne peuvent être avancées lorsqu’en présence d’un défaut qui s’est révélé dans un délai de 10 ans après la mise en circulation du produit, le producteur n’a pas pris les dispositions propres à en prévenir les conséquences dommageables. Toutefois, cette réserve a été remise en cause dans l’arrêt du 25 avril 2002 (points 47 et s.)

Le producteur pourra aussi s’exonérer en cas de fait de la victime dans les conditions posées aux articles 1386-13. Mais le fait du tiers n’est pas exonératoire (art. 1386-14 cciv. du code civil.

Enfin, le producteur peut encore s’exéonérer lorsque l’état des connaissance scientifiques ou techniques, au moment où le produit a été mis en circulation, n’a pas permis de déceler l’existence du défaut (1386-11 4du code civil).

Le producteur ne peut invoquer la cause d’exonération prévue à l’article 1386-11 4° lorsque le dommage a été causé par un élément du corps humain ou par les produits de celui-ci (1386-12 du code civil).

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Caroline
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Ruben
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Terence
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