2025 was a pivotal year for class action litigation in the life sciences and health care sector, with significant developments across both the EU and the U.S. As procedural frameworks and private enforcement evolve and new legal precedents are set, companies operating in these industries must remain vigilant and proactive in managing litigation risks.

In 2025, France has consolidated and expanded the class action regime, making it more accessible and versatile. The reform broadens the scope of actionable breaches and compensable damages, and empowers a wider range of claimants, including non-approved associations and public prosecutors. This is expected to encourage more health-related class actions, particularly in cases involving product safety and regulatory compliance.

Germany, while having implemented the EU Directive on representative actions, remains cautious. The new consumer rights enforcement act (VDuG) has yet to set a mark for class actions in the life sciences sector, largely due to the individualized nature of redress claims. However, with the revised Product Liability Directive (PLD) set for implementation by December 2026, companies should prepare for potential shifts in litigation strategy and increased scrutiny.

A noteworthy ruling in Italy in 2025 has set strict criteria for homogeneity of redress claims, rendering a cross-border class action relating to many European jurisdictions inadmissible. The evolving legal environment and litigation culture in Italy may lead to more collective actions in areas such as product safety and product liability, competition, and data privacy.

The Netherlands and the UK present contrasting pictures. While the Netherlands has not observed a significant uptick in life sciences class actions under its WAMCA regime, the UK continues to see steady activity, with claimant firms targeting widely used products and emerging technologies. A noteworthy ruling dismissing a WAMCA class action in a life sciences matter at the end of 2025 may set the tone for 2026. The UK's ongoing review of its product liability regime may further facilitate collective actions, particularly as AI and digital health tools proliferate.

In the U.S., the risk of class actions has continued its steady growth, but 2025 brought notable wins for defendants on preemption grounds, as well as tightened requirements for class certification, particularly regarding numerosity and adequacy. Standing remains a key issue, with the Supreme Court engaging on the question of whether a class can proceed with uninjured class members, but ultimately not deciding the issue. As circuit courts continue to be split, all signs indicate that the Supreme Court may consider this issue again in the near future.

Looking to 2026, with new EU directives, ongoing judicial reforms in Mexico, and continued scrutiny in the U.S., the coming year promises further evolution in class action litigation. Life sciences companies should closely monitor legal developments, strengthen compliance, and prepare for a more complex and dynamic litigation environment. The trend is clear: collective redress mechanisms are becoming more robust, and the risks and opportunities are growing.