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The United Kingdom remains one of the world's last industrialized nations not to have adopted the CISG. The UK CISG debate has endured for decades, with existing analysis largely focusing on competition, assessing the relative merits of the CISG and English law. This article's analysis is complementary; focusing instead on coherence, and the private international law implications of UK accession. This article assesses contractual interpretation, and commodity sales, within an overarching private international law framework. Recognizing the necessity of existing competitive analyses, it makes the case for UK CISG accession on the basis of its complementary coherency perspective.
Doctrinal writing and case law on the problems of giving notice abound where the CISG is concerned, whereas there are few reported problems with the PECL or UNIDROIT. It is one of the most popular areas of dispute as a proper notification is central to any remedial relief. The second opinion from the CISG Advisory Council focuses on the requirements of examination and notification and contains an overview of the relevant case law on point.
CAVEAT on terminology: Any comparison of notice requirements under the PECL, UNIDROIT, and CISG will unearth a significant difference in terminology. The CISG solely encompasses selected formalities concerning validity of contract (such as form of communication, form of contract: Art. 12), but sets most validity issues outside the sphere of application by way of Article 4(a). It thus does not concern itself with most cases in which the contract is not valid due to misrepresentation, threat, fraud, or a similar formality. It also uses the term “avoid” for termination and revocation as the only language of contract cancellation. In contrast, both the UNIDROIT Principles and the PECL refer to rescission by the term “avoid” and use “termination” for the equivalent of the CISG term “avoidance.” This chapter uses CISG terminology and indicates where it is not used in the same manner in the UNIDROIT Principles and the PECL.
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