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CISG: Table of Contracting States

Click on the country of interest to identify the date the CISG entered into effect for it and texts and explanations of declarations or reservations, if any, applicable to the adoption of the CISG by that country. These are summaries prepared for the cisgw3 database. For official summaries prepared by the UN Treaty Section, click on United Nations, New York-Treaty Section. Also Treaty status information can be obtained by fax: (212) 963-3693. An alternative source of CISG status information is the UNCITRAL website. As of 13 June 2014, UNCITRAL reports that 81 States have adopted the CISG.

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Albania Argentina Armenia Australia Austria Bahrain Belarus Belgium Benin
Bosnia-
Herzegovina
Brazil Bulgaria Burundi Canada Chile China (PRC) Colombia Croatia
Cuba Cyprus Czech Rep. Denmark Dominican
Republic
Ecuador Egypt El Salvador Estonia
Finland France Gabon Georgia Germany Greece Guinea Honduras Hungary
Iceland Iraq Israel Italy Japan South
Korea
Kyrgystan Latvia Lebanon
Lesotho Liberia Lithuania Luxembourg  Macedonia  Mauritania Mexico Moldova Mongolia
Montenegro Netherlands New
Zealand
Norway Paraguay Peru Poland Republic
of Congo
Romania
Russian
Federation  
Saint Vincent
& Grenadines 
San Marino    Serbia    Singapore    Slovakia Slovenia Spain Sweden
Switzerland  Syria Turkey Uganda Ukraine United
States
Uruguay Uzbekistan  Zambia

See presentation on Russian Federation for comments on current status of Azerbaijan, Kazakhstan, Tjikistan and Turkmenistan; see also the Commentary by Rolf Knieper at 25 Journal of Law and Commerce (2005-2006) 477-481. See Annotated Text of CISG Article 91 for comments on effects of dissolution of former Yugoslavia on application of the CISG.

For the United Kingdom, not now a CISG signatory, see Nathalie Hofmann, Interpretation Rules and Good Faith as Obstacles to the UK's Ratification of the CISG and to the Harmonization of Contract Law in Europe, 22 Pace International Law Review (Winter 2010) 141-181; see also Sally Moss, "Why the United Kingdpom Has Not Ratified the CISG", 25 Journal of Law and Commerce (2005- 2006) 483-485; Angele Forte, "The United Nations Convention on Contracts for the International Sale of Goods: Reason or Unreason in the United Kingdom", 26 Baltimore Law Review (1997) 51-66; and A.F.M. Maniruzzaman's comparative study of selected provisions of English Law and the CISG and other contract law provisions. He states:

"Although the English common law of contract, like any other branch of English law, was considered to be influential in many parts of the world, especially the commonwealth and common law jurisdictions, such complacency should no longer exist in light of the recent move towards the globalisation and liberalization of international trade. The United Kingdom has not yet ratified the CISG, perhaps because of pride in its longstanding common law legal imperialism or in its long-treasured feeling of the superiority of English law to anything else that could even challenge it. This despite the fact that the major and influential trading nations, such as the north American states, including the United States and most European states are parties to the CISG.

"With the anticipated acceleration of globalisation and liberalization movements in the near future, there will be a greater demand for the global harmonization of commercial law. In such a situation, the insular attitude of the United Kingdom to the harmonization phenomenon is, in fact, regrettable. The time has come to wake up and face reality, and deal with it effectively.

"The world has so far been deprived of the reputable talent of British judges and lawyers in the matter of interpretation of the CISG which could have influenced the harmonization process in judicial decisions in the same way as the common law has in many countries. The truth of the matter is, as one has to acknowledge, that the influence of the traditional common law of contract seems to be falling increasingly into decay with the recent trend of many common law countries to adopt international instruments such as the CISG replacing their age-old habit of following the UK legislation as a model. In the view of the rest of the common law world, what matters most in this modern day and age is global expectation in the context of international sales contracts which is reflected in the CISG." See the December 2001 issue of the IBA's International Business Lawyer at page 489. For another commentary on The British Refusal to Ratify the CISG: The Conventional Reasons and The Reasons through the Lens of Public Choice, see Section II.B.2 of John Linarelli, "The Economics of Uniform Laws and Uniform Law Making", 48 Wayne Law Review 1387 (2003).

Dr. Maniruzzaman [from a commonwealth country] comments on the talent of British judges. In a ruling on another international convention, Lord Denning states:

"We are told that there have been no decisions so far in other countries on this Article of the convention So where we lead, others may follow. " James Buchanan & Co Ltd v. Babco Forwarding and Shipping (U.K) Ltd [1977] 1 All ER 518 (CA) at 522, 524, [1977] 2 WLR 107 (CA) at 113, 113-114.

The cisgw3 database reports:

In the United States, we have over the course of our history cited English jurists where their opinions are relevant -- as have courts of other countries.

We would like to share British jurisprudence -- with the jurisprudence of other countries -- to help the world community benefit from the reasoning of English jurists on the evolution of international commercial law as participants in the global jurisconsultorium on the CISG.

Declarations, State interpretations, and variations in implementations

Certain countries have adopted the CISG subject to authorized declarations. There are also several instances of States accompanying their acceptances with interpretive comments (a procedure not authorized by the CISG).

Examples of authorized declarations

Article 92 and 94 declarations. The Scandinavian States (Denmark, Finland, Norway and Sweden), pursuant to Article 92 declared that they would not be bound by Part II of the Convention (Formation of the Contract); and that pursuant to Article 94 the entire Convention would not apply to inter-Scandinavian trade between parties from these countries [the Scandinavian countries have their own uniform Sale of Goods Acts].

Article 93 declarations. Pursuant to Article 93, several States have made territorial declarations: Australia has declared that the Convention shall not apply to the territories of Christmas Island, the Cocos (Keeling) Islands and the Ashmore and Cartier Islands; Denmark has declared that the Convention shall not apply to the Faroe Islands and Greenland; New Zealand has declared that the Convention shall not apply to the Cook Islands, Niue and Tokelau.

Article 95 declarations. Pursuant to Article 95, China (PRC), Singapore, St.Vincent & Grenadines, and the United States declared that they would not be bound by Article 1(1)(b). The Czechoslovak Socialist Republic had made a similar declaration (see Czech Republic and Slovakia for comments on the current status of this declaration). This declaration restricts the role of private international law in determining the applicability of the CISG when both contracting parties do not have their relevant places of business in Contracting States. See the Cross-reference editorial analysis of Article 1 for further discussion of this subject.

Article 96 declarations. Pursuant to Article 96, Argentina, Armenia, Belarus, Chile, Estonia, Hungary, Latvia, Lithuania, Paraguay, Russian Federation and Ukraine have declared that any provision of Article 11, Article 29 or Part II of the Convention that allows a contract of sale or its modification or termination by agreement or any offer, acceptance, or other indication of intention be made in any form other than in writing does not apply where any party has his place in the country that has filed this declaration. China (PRC) has filed a similar declaration, but it is not couched in the precise phraseology called for by Article 96.

Examples of interpretive comments that accompanied adoptions of the CISG.

The interpretive comments recited below will presumably be followed by the courts of the State (or in the case of Canada, the province) that made them, but whether they will be followed by other courts is a matter of conjecture as they are not expressly authorized by the Convention. Article 98 of the CISG states: "No reservations are permitted unless expressly authorized in this Convention."

Canada. A summary and assessment of interpretive comments contained in implementing acts of provinces of Canada:

"The Alberta, New Brunswick and Ontario Acts . . . require the contract to state 'that the local domestic law of [the enacting jurisdiction] or another jurisdiction applies to it or that the Convention does not apply to it.' The Manitoba Act . . . indicates that the parties may exclude the Convention 'by expressly providing in the contract' that the Convention does not apply to it. Bill C-81 [of Canada's Parliament], on the other hand . . . provides that the parties may exclude the application of the Convention 'in accordance with the terms of the Convention and, in particular, by providing in the contract that other law applies in respect of the contract'. Newfoundland's approach differs yet again. Section 7(1) [of the Newfoundland Act] allows the parties to exclude the Convention 'by expressly providing in the contract that the law of the province or another jurisdiction applies to it or that the Convention does not apply to it.' Section 7(2) then goes on to make it clear that the section of the law of the province or of another jurisdiction as the proper law of the Contract shall not be interpreted so as to make the Convention apply to it." Jacob Ziegel, "Canada Prepares to Adopt the International Sales Convention", 18 Canadian Bus. L.J. (1991) 3. Zeigel's assessment is: "All this is . . . bound to lead to much confusion." Id.. With respect to the Ontario Act, for example, he states: "[The interpretation recited there] may prevail before an Ontario Court but it would cut little ice outside Canada. This is because a foreign tribunal or arbitrator would probably hold that Ontario cannot unilaterally change the meaning of Article 6 of the Convention." Id. at 11.

Germany and Armenia. Upon ratifying the Convention, Germany declared that it would not apply Article 1(1)(b) in respect of any State that had made a declaration that the State would not be bound by Article 1(1)(b). Armenia has made a similar delcaration. These appear to be interpretations, not declarations authorized by the Convention.

Hungary. Upon ratifying the Convention, Hungary declared that it considered the General Conditions of Delivery of Goods between Organisations of the Member Countries of the Council on Mutual Economic Assistance (CMEA) to be subject to the provisions of Article 90 of the Convention. With the demise of the CMEA, this declaration is no longer relevant.

Examples of variations in implementation

Norway. Sevón reports: "In Norway it was considered more rational to enact one Act containing both [domestic and international] provisions. The provisions of the Norwegian Act will, as a rule, be applicable to all sales." Lief Sevón, "The New Scandinavian Codification on the Sale of Goods and the 1980 United Nations Convention on Contracts for the International Sale of Goods", in Einheitliches Kaufrecht und nationales Obligationenrecht, Peter Schlechtriem ed., Baden-Baden: 1987, 349. For further data on issues associated with Norway's implementation of the CISG, see Kai Krüger, International sales under present Norwegian law; see also Joseph Lookofsky, Understanding the CISG in Scandinavia (2d ed. 2002) p. 2 and 1-2, 2-2, 2-4, 4-4, 6-4, 6-5 and 6-19.

Israel. The CISG was incorporated into internal Israeli law by the Sales Law (International Sale of Goods) 5760-1999, which came into effect on 5 February 2000. For international sales contracts concluded prior to that date, the previous laws, i.e., the 1964 Hague Sales and Formation Conventions, would continue to apply. Pursuant to CISG article 99(2), Israel became a CISG Contracting State on 1 February 2003 -- the first of the month following the expiration of twelve months after 22 January 2002, the date of the deposit with the UN of its instrument of acceptance.

Albert H. Kritzer


Pace Law School Institute of International Commercial Law - Last updated June 24, 2014
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