For certain obligations some CIVIL LAW systems will grant remedies for non-performance only if the non-performance was "imputable" to the debtor (manufacturer in your context), and this frequently requires that he has committed a fault. Thus in BELGIAN, DUTCH, FRENCH, AND LUXEMBOURG law there is non-performance of an "inspanningsverbinteris" or "obligation de moyens" only if there has been fault. The creditor must prove that the debtor did not act with the care which he had undertaken to exercise. However, in case of an "resultaatsverbinteris" or "obligation de résultat", the creditor must only prove that the result which the debtor undertook to provide has not been achieved. In either case the debtor is excused by force majeure which extinguishes the obligation. SPANISH law has developed on similar lines, see Diez Picazo II 575; Lacruz-Sancho, Delgado, Rivero II, 1, 25, 194. See also Note 2 to Article 6:102.

HTH
Poornima