contradiction with each other, and the Arabic and English versions of Art. 36 CISG still make different presumptions. The inconsistency between the Arabic and. Furthering the Uniform Application of the CISG: Sources of Law on the Internet, Identification of errors in authentic Arab text of CISG [ – in Arabic and English], . of conflict-of-laws (private international law) rules Contract draftsmen should also note that there are six equally authentic versions of the CISG: the Arabic.

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Archived copy as title link at 22 December Conversely, in “international” contracts for the sale of goods between a U. Finland will not be bound by Part II of the Convention. The CISG defines the duty of the seller, ‘stating the obvious’, [51] as the seller must deliver the goods, hand over any documents relating to them, and transfer the property in the goods, as required by the contract.

InUnidroit decided to undertake the preparation of a uniform law on the international sale of goods, which resulted in two separate conventions: For the documentation of the Working Group on the international sale of goods, see http: Journal of Law and Commerce. The autonomy of the parties to international sales contracts is a fundamental theme of the Convention: Lithuania 17 Lithuania When the Convention applies, it does not govern every issue that can arise from an international sales contract: Articles cidg final provisions include how and when the Convention comes into force, permitted reservations and declarations, and the application of the Convention to international sales where both States concerned have the same or similar law on the subject.

If the breach is not fundamental, then the contract is not avoided and remedies may be sought including claiming damages, specific performance, and adjustment of price.

Full translation available at http: The self-executing treaty arbic to cis obstacles to international trade, particularly those associated with choice of law issues, by creating even-handed and modern substantive rules governing the rights and obligations of parties to international arabix contracts.

International Trade Law Databases and Resources. Netherlands 69.

United Nations Convention on Contracts for the International Sale of Goods

The Government of Canada also declares that the declaration made at the time of its accession to the Convention on April 23,the declaration deposited on April 9,the declaration deposited on June 29, and the declaration deposited on July 31,remain in effect. The CISG attempts to resolve the common situation where an offeree’s reply to an offer accepts the original offer, but attempts to change the conditions. Declarations and Reservations Unless otherwise indicated, the declarations and reservations were made upon ratification, acceptance, approval, accession or succession.


On 22 Novemberthe Government of the Czech Republic notified the Secretary-General that it had decided to withdraw the reservation with respect to article 95 made by Czechoslovakia upon ratification.

These two cases were held by one commentator to be an example of contradictory jurisprudence.

Disputes over interpretation of the CISG are to be resolved by applying the ‘general principles’ of the CISG, or where there are no such principles but the matters are governed by the CISG a gap praeter legem by applying the rules of private international law. Vincent and the Grenadines St. Accordingly, the Commission requested the Secretary-General to send a questionnaire to Member States of the United Nations or any of its specialized agencies.

Jankowitsch Austria Vote on the draft resolution: The UCC, on the other hand, tries to avoid the “battle of the forms” that can result from such a rule, and allows an expression of acceptance to be operative, unless the acceptance states that it is conditioned on the offeror consenting to the additional or different terms contained in the acceptance. The Convention opened for signature on 11 April during the Conference in Vienna.

Coste France Explanation of vote 36 seconds, English. United States of America. Norway 18 Reservation made upon signature and confirmed upon ratifica tion: These denunciations took effect 12 months later, and the present Convention therefore entered into force for the Federal Republic of Germany and the Netherlands on 1 January and on 1 Januaryrespectively, in accordance with paragraphs 2 and 6 of article CISG advocates are also concerned that the natural inclination of judges is to interpret the CISG using the methods familiar to them from their own State [85] rather than attempting to apply the general principles of the Convention or the rules of private international law.

Electronic Library on International Commercial Law and the CISG

Reservation made upon signature and confirmed upon ratifica tion: Sweden will not be cieg by Part II of the Convention. International Commercial Law Library. Archived copy as title Articles with German-language external links All articles with dead external links Articles with dead external links from July Articles with permanently dead external links CS1 Russian-language sources ru All articles with unsourced statements Articles with unsourced statements from June Remedies of the buyer and seller depend upon the character of a breach of the contract.


Generally, the goods must be of the quality, quantity, and description required by the contract, be suitably packaged and fit for purpose.

United Nations Convention on Contracts for the International Sale of Goods – Main Page

Germany 567. Secondly, business arwbic will increasingly pressure both lawyers and governments to make sales of goods disputes less expensive, and reduce the risk of being forced to use a legal system that may be completely alien to their own.

Inthe General Assembly adopted the United Nations Convention on the Use of Electronic Communications in International Contracts to address various issues arising when electronic communications methods are employed in connection with international contracts, including international sales contracts.

The reductio ad absurdum would seem to be that all international treaties should exist in only a single language, something which is clearly neither practical nor desirable. A contrary view is that the CISG is “written in plain business language,” which allows judges the opportunity to make the Convention workable in a range of sales situations.

All communications require “reasonable time. Kluwer Law International, 4th ed. The Part IV Articles, along with the Preamble, are sometime characterized as being addressed ‘primarily to States’, [72] not to business people attempting to use the Convention for international trade. Iceland Iceland 12 March Declaration: Auflage,the parties can easily identify the gaps and how they will be filled under the assumption of Swiss or German applicable law.

For example, the drafting nations have been accused of being incapable of agreement on a code that “concisely and clearly states universal principles of sales law”, and through the Convention’s invitation to interpret taking regard of the Convention’s “international character” [75] gives judges the opportunity to develop “diverse meaning”.

For example, the CISG does not govern the validity of the contract, nor does it cieg electronic contracts.