Abstract
Norway is not a EU member state, but is associated to the EU through the European Economic Area (EEA) Agreement. The EEA Agreement extends the single market to Norway, but does not cover the area of judicial cooperation. EU law nevertheless has a considerable significance for Norwegian private international law. On the one hand, Norway has ratified and implemented Lugano Convention, Norwegian courts give consideration to EU private international law, and there is a project of codification which is based on the Rome I and Rome II Regulations. On the other hand, substantive EU law on the single market may have an impact on the applicable law, and thus indirectly on the effectiveness of private international law. In particular, the principles of freedom of movement and of establishment, as well as the principle of legal clarity, proved to have significance for the formulation of choice of law rules for company and labour law.
Highlights
Known as conflict rules or choice of law rules,[1] is that branch of the law that deals with choice of the law applicable to an international legal relationship, choice of forum for international disputes, and the recognition and enforcement of foreign decisions
For EU member states, large parts of private international law are regulated by EU law
Since 1994, Norway has been connected to the EU by the European Economic Area Agreement
Summary
Known as conflict rules or choice of law rules,[1] is that branch of the law that deals with choice of the law applicable to an international legal relationship, choice of forum for international disputes, and the recognition and enforcement of foreign decisions. The EEA Agreement extends to Norway (as well as to Iceland and Liechtenstein) the application of EU law provisions relevant to the implementation of the single market. This means that Norway is committed to apply principles correspond-. Parts of EU private international law have become applicable through the Lugano Convention,[2] as well as through isolated choice of law rules contained in instruments that are EEA relevant. To the extent that the EEA Agreement forbids hindrances to the freedom of movement or of establishment, the application of the applicable substantive law will be restricted This has an impact on the effectiveness of the conflict rule that designated that law as applicable.
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