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CISG vs. Regional Sales Law Unification: With a Focus on the New Common European Sales Law
In October 2011, the European Commission introduced its Proposal for a Regulation on a Common European Sales Law (CESL), which covers, inter alia, international business sales - a subject already regulated by the Convention of International Sale of Goods (CISG), which was ratified by 23 Member States. How does this new Proposal fit the existing uniform...
In October 2011, the European Commission introduced its Proposal for a Regulation on a Common European Sales Law (CESL), which covers, inter alia, international business sales - a subject already regulated by the Convention of International Sale of Goods (CISG), which was ratified by 23 Member States. How does this new Proposal fit the existing uniform sales law? How have other regions of the world managed the coexistence of global and regional sales law unification? What can Europe learn from the US experience concerning the CISG and the Uniform Commercial Code? What can we learn from the Organisation pour l'Harmonisation en Afrique du Droit des Affaires/Organization for the Harmonization of Business Law in Africa (OHADA), which made CISG more or less the internal law of 17 African States, as well as from Australia, where CISG and common law exist side by side? These questions are intensely discussed in this highly recommended book, with contributions by renowned authors, such as Larry DiMatteo, Harry Flechtner, Franco Ferrari, Robert Koch, Ulrich Magnus, Peter Mankowski, and Bruno Zeller.
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