Primers on the CISG from common law and civil law perspectives

An overlay

• The United Nations Convention on Contracts for the International Sale of Goods is an overlay; it sits a top the national sales code or sales law of each country that has adopted it. In most cases, this is a domestic regime that is either civil law or common law -- cultures that have at times approached sales law challenges somewhat differently. How does the CISG sit a top different civil law and common law regimes? For an introduction to that, go to: Ulrich Drobnig, General Principles of European Contract Law, in: Sarcevic & Volken ed., International Sale of Goods: Dubrovnik Lectures, Oceana (1986) 305-332. His paper also helps us understand how some of the CISG's conflict-compromises came about.

A view from South Africa

• Analysis by Sieg Eiselen of Potchefstroom University of South Africa. Analysis of: The need for unification of international sales law; Development of the CISG; Other methods to achieve legal unification or solve problems of international sales; The case for adoption; The case against adoption; Experience with the CISG thus far.

Other analyses

 

• The Vienna Sales Convention and the Lex Mercatoria: a good overview of the CISG prepared by a leading French authority.
• A brief overview of the CISG: Explanatory Note by the UNCITRAL Secretariat on the United Nations Convention on Contracts for the United Nations Convention on Contracts for the International Sale of Goods.
• A report on the CISG prepared by the Law Commission of New Zealand: an especially good general introduction to the CISG for persons from common law jurisdictions.
• Analyse de Dispositions de la C.V.I.M. du Point de Vue du Droit Civil Québécois: [French text] prepared for the Uniform Law Conference of Canada.
• Uniform Sales Law - The Experience with Uniform Sales Laws in the Federal Republic of Germany, prepared by the editor of Germany's leading text on the CISG.
• Analysis from a Provincial Common Law Perspective: also prepared by the Uniform Law Conference of Canada; in addition to comparisons of the CISG with Canadian law, includes many comparisons with the UCC and with common law sales rules in general.
• An introduction to the CISG: La Convención de las Naciones Unidas sobre los Contratos de Compraventa Internacional de Mercaderías: [Spanish text] prepared by the authors of Argentina's leading text on the CISG.

Seminal text

• For a seminal text on the CISG prepared by the individual we regard as Europe's leading authority on the subject, go to: Peter Schlechtriem, Uniform Sales Law: The UN-Convention on Contracts for the International Sale of Goods, Vienna: Manz (1986) 120 pages.

Other primers on the CISG have been prepared by law revision commissions or authorities from many countries. For citations to them, see the Bibliography on the CISG.