On 28 September 2022, the European Commission presented the proposal for a new Product Liability Directive to adapt the current Product Liability Directive 85/374/EEC, dating from 1985, to today’s industrial reality, particularly under the aspects of digitalisation and the circular economy. The current liability concept remains largely unchanged. The new directive will continue to provide for harmonised European no-fault liability for personal injury and property damage to privately used objects caused by products with safety defects.Compared to the present legal situation, which has remained unchanged for almost 40 years, the proposal nevertheless entailsnumerous problematic increases in liability for the manufacturing industry, the need for which is not readily apparent in view of digital transformation and the circular economy.This position paper of the Working Group “Legal Framework” analyses five critical modifications that are intrinsic to the European Commission's draft for a new Product Liability Directive.