- Applicable law — Rome Convention — Rome I Regulation and choice of law
This chapter expounds on the domestic sales laws across the world. It cites the differences and peculiarities of the Uniform Commercial Code in the US, Code Civil in France, codifications of the Germanic legal systems and Ibero-American legal systems, and the jurisdictions of the African legal systems. Additionally, the chapter explores the main influences of Middle Eastern, Arab, and Asian laws. It highlights how no comparative work on sales and contract law would not include its respective historical development. The chapter notes that the foundation of Continental European systems is Roman law after it was preserved in Western Europe.
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