---
title: "Product liability for manufacturers, importers and distributors"
description: "Target classes, coverage questions and submission details for manufacturers, importers, distributors and online sellers with product liability exposure."
metaTitle: "Product Liability for Manufacturers & Distributors | Nomos"
metaDescription: "A retail-agent guide to product liability: target classes, coverage questions and what to send for manufacturers, importers, distributors and online sellers."
author: tobias
publishedDate: 2026-09-16
category: Coverage deep dives
tags: [product-liability, manufacturers, importers, distributors, wholesale-insurance]
relatedCovers: [general-liability, umbrella-excess, commercial-property, inland-marine]
relatedIndustries: [manufacturing, food-beverage-manufacturing, importers-product-brands, ecommerce-brands, medical-device-companies, biotech-life-sciences, cannabis]
faq:
  - question: "Which product businesses should a retail agent send for review?"
    answer: "Start with manufacturers, importers, distributors, wholesalers and online sellers whose product, distribution method, loss history or requested limits do not fit a direct market. The product itself, not just the SIC code or industry label, determines the useful route."
  - question: "Is product liability the same as a general liability policy?"
    answer: "Not always. Products and completed-operations liability may be included within a general liability form, but some accounts need a products-only structure, a separate life-sciences or professional-liability component, or excess above the primary layer."
  - question: "Does product liability include product recall?"
    answer: "Do not assume so. Product recall is a distinct first-party and third-party exposure that needs its own coverage discussion, application and loss information."
---

Product liability for manufacturers, importers and distributors changes with the product. A household-goods distributor, a medical-device manufacturer and a supplement seller may all need products coverage, but their submission packages differ.

Nomos reviews product-driven accounts that need a specialty-market placement. This page covers target classes, coverage questions and the submission details that make a referral usable. Eligibility and terms are confirmed case by case.

## Target product classes

Start with what the business makes, imports, distributes or sells, who uses it, where it goes and what happens if it fails. We regularly review:

- Manufacturers, importers, distributors, wholesalers and online retailers.
- Appliances, electronics, tools, machinery, parts, metal goods, construction materials and industrial products.
- Apparel, household goods, furniture, sporting goods, toys and other consumer products.
- Food, beverages, ingredients, pet products and selected personal-care products.
- Cannabis/hemp, cosmetics, nutraceuticals, vitamins, supplements and other regulated or ingestion-related products.
- Medical devices, diagnostics, durable medical equipment, pharmaceuticals and other life-sciences products.

Use the list to route the account. Product composition, labeling, claims history, territory, quality control, vendor agreements and sales channel can matter more than the broad class name.

## Coverage questions

The first decision is whether the business needs general liability with products/completed operations, a products-only structure or a specialized life-sciences liability approach. It depends on the operation and the product.

| Coverage question | When it commonly comes up | What to clarify |
| --- | --- | --- |
| General liability with products/completed operations | A manufacturer, importer or distributor has premises and completed-product exposure | Operations, sales, contracts, additional-insured requirements and requested limits |
| Products-only liability | The main exposure comes from products rather than premises operations | Product catalog, distribution chain, prior coverage and retroactive-date needs where applicable |
| Life-sciences liability | Medical devices, pharmaceuticals, biologics, supplements, CBD/hemp or another regulated product is involved | Ingredients, intended use, labeling, regulatory status, clinical or professional-service role and quality controls |
| Product recall | A defect, contamination, labeling issue or government/retailer withdrawal could create first-party recall costs or third-party liability | Recall plan, quality-control procedures, prior incidents, notices, supplier controls and requested recall limit |
| Excess liability | The contract, retailer, landlord, customer or risk profile requires limits above the primary policy | Underlying form, attachment, aggregate, loss history and every scheduled underlying line |
| Property, inland marine or cargo | Stock, equipment, goods in transit, warehouses or a mobile sales/distribution operation are part of the account | Values, locations, inventory, transit method, ownership and who bears the loss in the contract |

Products coverage that responds to third-party injury does not automatically include product recall, cargo, cyber, property, commercial auto or professional-liability allegations.

## Manufacturing and industrial products

Industrial and construction-related products are good submission candidates when the account has a clear product, a controlled production process and complete loss information. Common examples include machine shops, metal fabrication, equipment and machinery parts, electrical components, appliances, construction materials, tools, protective goods and specialty manufactured products.

The submission needs to explain whether the insured designs the product, manufactures it, assembles it, imports it, repackages it or only distributes it. It should also state whether the product is installed by the insured, becomes part of another product, is used in safety-critical work or travels internationally. Those differences affect products liability, completed operations, professional liability and excess discussions.

## Importers, distributors, wholesalers and online sellers

Importers and distributors may inherit a product problem even when they do not manufacture the item. Identify the manufacturer, country of origin, contractual indemnity, vendor requirements, quality checks, storage conditions, private-label role and whether the insured sells through a marketplace, direct website or physical retail channel.

For an online seller, include product pages, the fulfillment model, sales territory and returns or complaint history. Show whether the insured controls the product, makes representations about it or can trace and withdraw it if something goes wrong.

## Food, beverage, cosmetics and supplements

Food, beverage, cosmetic and supplement accounts need more detail than a standard retail or manufacturing application provides. Send the product catalog, ingredients, labels, co-packing or manufacturing arrangements, batch controls, third-party testing, recall plan, distribution footprint and any regulatory notices or prior claims.

For supplements, nutraceuticals and cosmetics, say exactly what the product claims to do. For food and beverage, identify ingredients, storage, temperature control, allergens, alcohol content where relevant and whether the insured imports, manufactures, distributes or only sells the product. Product liability may be only one part of the discussion; product recall, property/spoilage, cargo and excess may need separate treatment.

## Medical devices, life sciences and regulated products

Medical devices, diagnostics, pharmaceuticals, biologics, durable medical equipment and regulated cannabis/hemp products usually need a dedicated life-sciences review. The submission package should identify the product's intended use, user, regulatory status, labeling, clinical or professional-service component, contractual requirements, complaint history and distribution territory. For devices, the [FDA's classification guidance](https://www.fda.gov/medical-devices/overview-device-regulation/classify-your-medical-device) helps establish the product description precisely.

Cannabis and hemp need the same level of detail. Cultivation, processing, distribution, dispensary sales, delivery, ingestible products and ancillary services create different underwriting questions. Product liability does not establish coverage for the premises, property, commercial auto, professional services or another part of the operation.

Use the dedicated guides for a product-specific checklist: [medical devices and life sciences](/resources/medical-device-insurance-submission-checklist/) and [cannabis and hemp products](/resources/cannabis-hemp-product-liability-submission-checklist/).

## Product recall

Product recall needs its own coverage discussion. General liability may respond to a third-party bodily-injury or property-damage allegation, but it does not automatically pay for removing products from the market, notifying customers, replacing stock, rehabilitating a brand or managing a regulatory withdrawal.

Raise recall early when the account makes or distributes food, beverages, consumer products, medical products, electronics, components, cannabis products, pharmaceuticals, supplements, cosmetics or any product where one defect can reach many customers. A recall submission should include five years of recall and general-liability losses, quality-control and supplier procedures, the written recall plan, current policy details, product catalog and known regulatory or consumer-product notices. For consumer products, the CPSC's [recall checklist](https://www.cpsc.gov/Business--Manufacturing/Recall-Guidance/Recall-Checklist) illustrates why traceability and a documented response plan matter.

For the coverage discussion and a recall-specific document checklist, see [product recall insurance](/resources/product-recall-insurance-submission-checklist/).

## Submission checklist

Market forms vary. Ideally, a product-liability submission package contains the applications, a clear account description and currently valued losses. Include the supporting material below for the fastest review; the product and requested coverage determine any additional forms.

Send:

- Completed ACORD application(s) and the applicable products, life-sciences, recall or cannabis supplemental form. Include the exact legal entity, effective date, operating states and locations, requested coverage, limits, deductibles and target premium where available.
- A plain-English operations narrative and product catalog, including product pages, labels and the insured's role: design, manufacture, assemble, import, repackage, distribute, private-label or retail sale.
- Annual revenue by product category, sales territory, distribution channels and the customer or end-user. Identify whether products are sold online, through retailers or to other businesses.
- Manufacturers, suppliers, co-packers and country of origin where applicable, plus contractual indemnity, additional-insured or vendor requirements.
- Quality-control, testing, traceability, complaint-handling and recall procedures. Include current regulatory, consumer-product or food-safety notices when they exist.
- Five years of currently valued general-liability loss runs, with claim narratives and explanations for material, open or recall-related losses. Include recall losses as well as general-liability losses when recall coverage is requested.
- Current or expiring declarations, prior-insurance information and, for claims-made coverage, the retroactive date. Include every scheduled underlying policy when excess is requested.
- For medical products, pharmaceuticals or supplements: the product-specific application, labels, declarations, website and five-year loss history. For cannabis or hemp: the supplemental form, menus or ingredients, website, expiring claims-made declarations and an explanation for every loss.
- For product recall: the recall application, written recall plan, quality-control and supplier procedures, product catalog, current declarations and relevant FDA, CPSC or other regulatory notices.
- Values and schedules for inventory, equipment, warehouses, transit or any requested property, inland-marine or cargo component.

Submit the account with the material you have. We review the product, distribution chain and coverage questions, then identify what else is needed before approaching the market.

[Send the file](mailto:submissions@nomos-insurance.com) · submissions@nomos-insurance.com · [Get appointed](https://nomos-insurance.com/get-appointed/)

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