The main legal obstacles to a European legal framework on multimodal contracts of carriage identified by the Commission and the different expert groups seem to mirror the obstacles identified on an international level. It is clear that the ungoverned situation leads to unpredictability. No international legal regime is directly applicable; hence, in some jurisdictions and situations, the unimodal legal frameworks apply and in others not. Exactly when the unimodal conventions apply is not clear and different jurisdictions have different practices. The problem has been analysed several times by academic scholars 1 and the Commission. 2 However, no legal regime acceptable to all stakeholders has so far been achievable.