•  
  •  
 

Emory International Law Review

Authors

Justus Meyer

Abstract

The U.N. Convention on Contracts for the International Sale of Goods (CISG) stipulates that the seller can cure a lack of conformity by supplying a replacement. On the other hand, the buyer can only demand a replacement delivery if the lack of conformity constitutes a fundamental breach of contract. In contrast, according to the European Sales Law Directive, the consumer may, at his choice, require the seller to repair the goods or to replace them “in the first place”. This article traces the developments that have led to these different regulatory approaches.

Share

COinS