ABSTRACT

Contract law and especially commercial contract law has always been at the forefront of harmonization and unification of private law. On a regional level, a number of initiatives can be discerned. Several approaches can be found in Europe which all aimed at a European Civil Code or at least a European Contract Law. The content of the Common European Sales Law (CESL) is almost identical to that of the CISG and the United Nations (UN) Limitation Convention with additional provisions on defects of consent, unfair contract terms, pre-contractual information duties, and contracts to be concluded by electronic means. The Principles of European Contract Law (PECL) have a clear European focus, but also take into account the US-American Uniform Commercial Code as well as the Restatements on Contracts and Restitution. Even long-term contracts can be accommodated by the existing CISG rules on contracts for delivery of goods by installments.