The CISG, European Contract Law and the Development of a World Contract Law

The United Nations Convention on Contracts for the International Sale of Goods (CISG), though promulgated more than a quarter of a century ago in an entirely different socio-economic and political environment, remains a landmark in the international unification process. Adopted by seventy countries, including most of the major trading nations, the CISG has not only achieved the status of a veritable world sales law but has also led a number of States to modernize their domestic sales laws. In addition, it heavily influenced the EC Consumer Sales Directive in Europe and is a source of inspiration to the current work on a possible European Civil Code. Moreover, at a universal level, the CISG has prompted UNIDROIT to prepare the UNIDROIT Principles of International Commercial Contracts, a sort of restatement of the law of international commercial contracts in general. The present article is intended to explore these developments further, focusing in particular on the potentialities of legislative instruments such as the CISG and the EC Consumer Sales Directive as opposed to non-binding or soft law instruments such as the UNIDROIT Principles.