I Introduction

Abstract

This introductory chapter provides a general comparison of the substantive law of the United Nations Convention on Contracts for the International Sale of Goods (Convention) with the UNIDROIT Principles on International Commercial Contracts (Principles), and the Sales provisions of Article Two of the Uniform Commercial Code (Code). The Convention, the Principles, and the Code are similar in two important aspects: all three are attempts to seek uniformity in the law of sales, and all three are attempts to reflect modern commercial practices. Unlike the Code, the Convention and the Principles are not based on any particular set of underlying established domestic legal principles. Instead, the Convention and the Principles were drafted to be independent of rather than work in conjunction with any particular domestic law or legal tradition. Another significant difference among the Convention, the Principles, and the Code is that the sales provisions of the Code are an integral part of the larger Uniform Commercial Code. Neither the Convention, the Code, nor the Principles cover all aspects of commercial contracts. Unlike the Principles, the Convention and the Code are limited to contracts for the sale of goods.