CISG vs. Regional Sales Law Unification With a Focus on the New Common European Sales Law
:
Ulrich Magnus
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CISG vs. Regional Sales Law Unification With a Focus on the New Common European Sales Law
:
sellier.european law publishers
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9783866539662
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1
:
CHF 43.50
:
:
Internationales Recht, Ausländisches Recht
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English
:
247
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DRM
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PC/MAC/eReader/Tablet
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PDF
< >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 78 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 U.S. experience concerning the CISG and the Uniform Commercial Code? What can we learn from the African OHADA which made CISG more or less the internal law of 17 African states, what from Australia where CISG and common law exist alongside? All these questions are intensely discussed in this highly recommendable book written by renowned authors like Larry DiMatteo, Harry Flechtner, Franco Ferrari, Robert Koch, Ulrich Magnus and Bruno Zeller.
Foreword
6
List of Authors
8
Introduction
12
The U.S. Experience with the UCC and the CISG: Some Insights for the Proposed CESL?
16
The Curious Case of Transborder Sales Law: A Comparative Analysis of CESL, CISG, and the UCC
36
The CISG and the Common Law: the Australian Experience
68
CISG and OHADA Sales Law
90
CISG vs. CESL
108
CISG, CESL, PICC and PECL
136
Concluding Remarks
158
Proposal for a Regulation of the European Parliament and of the Council on a Common European Sales Law
164
