Comparative Sales Law

Abstract

The story of comparative law in the field of sales contracts is inextricably linked to Ernst Rabel. Rabel not only prepared the basis for any comparative study of the modern law of sales in his epochal treatise ‘Das Recht des Warenkaufs’, but also initiated the process of world-wide harmonization of the law of international sales. This process has not only led to one of the most important international conventions in the field of private law (the 1980 UN Convention on Contracts for the International Sale of Goods—CISG) but has also become a highly influential factor in the field of comparative sales law in the twentieth century. The article first outlines the most important projects in this area and their interaction with comparative law. It then goes on to discuss selected characteristic features of the law of sales which are interesting from a comparative point of view.