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 [2]. His paper also helps us understand how some of the CISG's conflict-compromises came about.

2019 Commentary

• Brunner & Gottlieb: Commentary on the UN Sales Law (CISG) [3]
• Schwenzer, Fountoulakis & Mariel, International Sales Law: A Guide to the CISG [4] 
• CISG: Then and Now — What Is Next?: Contracts for the International Sale of Goods: A Multidisciplinary Perspective [5]

CISG and Tech Related Matters

• What does the CISG have to say about smart contracts?: a legal analysis [6]
• The Vienna Convention on International Sales of Goods and the Bitcoin [7]

UCC and CISG

• Uniform Commercial Code- Digest [8] consists of case law on various U.S. commercial law topics. It also touches upon CISG, where deemed relevant. It is available online through Lexis/ Nexis and is updated periodically.

Recent CIETAC Analysis (2019)

• A Study on Application of CISG in the Commercial Arbitration of China-Focus on CIETAC Arbitration Cases [9]

A view from South Africa

• Analysis by Sieg Eiselen of South Africa [10]. 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.

A view on Turkey- U.S. Contracts

• Turkey's Accession to the CISG: The Significance for Turkey and for Sales Transactions with U.S. Contracting Parties [11] (2011)

Other analyses

• The Vienna Sales Convention and the Lex Mercatoria: [12] a good overview of the CISG prepared by a leading French authority. For another civil law perspective, see Silvia Ferreri, 25 Journal of Law and Commerce (2005-2006) 223-239 [13]
• What is the Convention about and how does it impact upon English lawyers? For a superb introduction to this subject, see Barry Nicholas, The Vienna Convention on International Sales Law. 103 Law Quarterly Review (1989) 201-243 [14]
• 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 [15]
• A report on the CISG prepared by the Law Commission of New Zealand [16]: 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 [17]: [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 [18], [19] prepared by the editor of Germany's leading text on the CISG.
• Checklist on the CISG [20]: adapted excerpt from 1994 Guide to Practical Applications of the Untited Nations Convention on Contracts for the International Sale of Goods
• The Uniform International Sales Law, in: Dalhuisen on International Commercial, Financial and Trade Law, Hart Publishing (2007) 400-330 [21]
• Analysis from a Provincial Common Law Perspective: [22]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 [23]: [Spanish text] prepared by the authors of Argentina's leading text on the CISG.
• Luke Nottage, Who's Afraid of the Vienna Sales Convention (CISG)? A New Zealander's View from Australia and Japan, Victoria University of Wellington Law Review (2005/4) 815-845 [24]

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. [25]

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 [26].