CISG vs. Regional Sales Law Unification : : With a Focus on the New Common European Sales Law / / ed. by Ulrich Magnus.

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. H...

Full description

Saved in:
Bibliographic Details
Superior document:Title is part of eBook package: De Gruyter DGBA Backlist Complete English Language 2000-2014 PART1
MitwirkendeR:
HerausgeberIn:
Place / Publishing House:Munich : : Otto Schmidt/De Gruyter european law pub, , [2012]
©2007
Year of Publication:2012
Language:English
Online Access:
Physical Description:1 online resource (237 p.)
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Other title:Frontmatter --
Foreword --
List of Contributors --
Table of Contents --
Introduction --
The U.S. Experience with the UCC and the CISG: Some Insights for the Proposed CESL? --
The Curious Case of Transborder Sales Law: A Comparative Analysis of CESL, CISG, and the UCC --
The CISG and the Common Law: the Australian Experience --
CISG and OHADA Sales Law. Or the Relationship between Global and Regional Sales Law --
CISG vs. CESL --
CISG, CESL, PICC and PECL --
Concluding Remarks --
Proposal for a Regulation of the European Parliament and of the Council on a Common European Sales Law
Summary: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.
Format:Mode of access: Internet via World Wide Web.
ISBN:9783866539662
9783110238570
9783110621006
9783110636208
DOI:10.1515/9783866539662
Access:restricted access
Hierarchical level:Monograph
Statement of Responsibility: ed. by Ulrich Magnus.