Abstract
Since the European Union was granted legislative competence to deal with private international law issues, several EU Regulations have been adopted that govern the scope of applicable law on several matters (contracts, maintenance, divorce...). The universal nature of these instruments can lead to the application of foreign laws. However, this matter has not been harmonised yet. This article argues that the current divergence in the way domestic systems apply foreign laws seriously undermines the efficacy of applicable law Regulations, such that there is an urgent need of harmonisation in this respect.
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