oa Comparative and International Law Journal of Southern Africa - Progress through compromise: the 1980 United Nations Convention on Contracts for the International Sale of Goods

Volume 28, Issue 2
  • ISSN : 0010-4051



International sale contracts are generally governed by the national law of a given country, determined in accordance with applicable rules of private international law or in terms of an express choice of law clause, on application of the widely accepted principle of party autonomy. In the absence of clear choice of law, however, the selection of the governing law in accordance with conflict rules is complicated, among others, by the simple fact that most domestic sales laws are not tailored to meet the specific needs of modem international sales. To avoid the inconveniences arising from the application of domestic laws to international situations, the law of international trade has developed bases for a common understanding of the obligations arising from international sales through the establishment of uniform substantive rules. The 1980 United Nations Convention on Contracts for the International Sale of Goods (CISG) is the most notable recent example in this regard. As of February 1994, thirty-seven states, among them major trading nations such as the United States and several EU countries, had ratified or acceded to the CISG.

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