欧美国家缺陷汽车召回制度在缺陷产品召回制度的基础上发展完善起来。而我国目前立法位阶比较低,出现缺陷汽车需要召回的情况,消费者的权益得不到有效维护。本文通过研究国外有有关立法和理论实践做法,阐释我国的有关法律规定,从比较法的角度发现我国在这方面存在的问题,进而改善我国缺陷汽车召回制度。 Defective vehicle recall system in Europe and the United States developed and perfected on the basis of defective product recall system. At present, the level of legislation in our country is relatively low, there is a situation that defective vehicles need to be recalled, and the rights and interests of consumers can not be effectively maintained. This article through the study of foreign legislation and practice of practice, interpretation of the relevant laws and regulations of our country, from the perspective of comparative law found that China’s problems in this area, thus improving China’s defective car recall system.