Although the United Nations Convention on Contracts for the International Sale of Goods (CISG) has been in force for over 35 years, there is still scholarly disagreement as to how this treaty interacts with choice-of-law clauses (see, eg, the discussion on this blog: Coyle, Brand and Flechtner, Hayward and Lal). In principle, there seems to be international consensus that the choice of the law of a Contracting State does not as such lead to an exclusion of the CISG under CISG Article 6. The CISG forms part of the legal order of the Contracting States. It is the substantive law for international sales contracts. However, some open questions remain, for instance on how to interpret a choice of the law of a territorial unit of a Contracting State, such as a US state … (more)
[Ben Köhler, Transnational Litigation Blog, 5 October 2023]
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