ABSTRACT

As this quote indicates, England’s failure to ratify the CISG came as a blow to advocates of harmonisation. Nevertheless, it was not entirely unexpected. The UK had played a leading role in negotiations leading up to the adoption of CISG and had previously been quick to adopt the two Hague Conventions on the Uniform Laws on International Sales of 1964 (ULIS).4 However, the English had rendered the latter instrument’s ratification virtually meaningless through the reservation that the ULIS would only apply where parties chose it as die law of the contract. As for English traders, there is no evidence of recourse to the ULIS in British commerce.5