Giesela Ruhl, The Common European Sales Law: 28th Regime, 2nd Regime or 1st Regime?

Giesela RuhlThe Common European Sales Law: 28th Regime, 2nd Regime or 1st Regime? (March 19, 2012). Maastricht Faculty of Law Working Paper. Available at SSRN or DOI


The article analyses three basic models that can be applied to determine the relationship between the proposed Common European Sales Law (CESL) and the rules of private international law: the ‘28th regime-model’, the ‘2nd regimemodel’, and the ‘1st regime-model’. It argues that both the ‘28th regime-model’ and the model favoured by the European Commission, the ‘2nd regime-model’, endanger the overall objective of the CESL because Article 6 Rome IRegulation will continue to apply. The ‘1st regime-model’, in contrast, avoids application of Article 6 Rome I-Regulation because it classifies the CESL as a uniform law that takes precedence over the rules of private international law. The article, therefore, concludes that the European Commission should rethink its position and apply the ‘1st regime-model’ instead of the ‘2nd regime-model’.


Private International Law Seminar, Madrid 2011

Private International Law Seminar, Madrid 2011, Universidad Complutense de Madrid, Facultad de Derecho

On 24 and 25 March, 2011, a new edition of the Private International Law Seminar organized by Prof. Fernández Rozas and De Miguel Asensio will take place in Madrid. Supported this time by the European Commission and the Notary Association of Madrid, the Seminar is organized in coordination with the Anuario Español de Derecho Internacional Privado, where most of the contributions will be published later this year.

As in previous editions, the Seminar, which has become one of the most successful events in the field of conflict of laws in Spain, will be held at the Complutense University. It will bwe structured in five sessions: family and successions, interregional conflicts, obligations, company law, and a final panel on harmonization of international business law. The conference will bring together numerous experts, academics and lawyers from more than fifteen countries. Spanish, English and French will be spoken -though no translation is provided. The full programme can be found here

Madrid 2011

and registration (which is free) is now open.

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