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Private International Law


Introductions to the Convention on Contracts for the International Sale of Goods (CISG)

The United Nations Convention on Contracts for the International Sale of Goods (CISG) is a multilateral treaty that provides substantive contract law on international contracts for the sale of goods.

The following books provide good introductions for those working with the CISG for the first time:

Key Tools for Researching the CISG

Many researchers and organizations have created valuable tools for researching the CISG. However, there are three organizations that pop up repeatedly and are particularly important to know:

Text and Status of the CISG

Almost every website and book about the CISG provides generally reliable and accurate text of the CISG. However, the official depository for the CISG is the United Nations. As the depository, the UN is responsible for publishing the official text of the CISG in its United Nations Treaty Series (U.N.T.S.).

Under Bluebook rule 21.4.5, the CISG is cited to both U.NT.S. and a U.S. treaty source in the format United Nations Convention on Contracts for the International Sale of Goods, Apr. 11, 1980, S. Treaty Doc. No. 98-9, 1489 U.N.T.S. 3. (1983)

Outside of U.S. publications and law reviews, the best citation is to U.N.T.S.

The following sources provide the most authoritative text of the treaty:

As the CISG's depository, the United Nations is also responsible for officially tracking the status of the treaty, including which countries have signed the treaty, consented to be bound by the treaty, and made any reservations or declarations limiting their compliance with the treaty.

The United Nations provides two interfaces for accessing status information:

Annotated Text of the CISG

Pace Law School's CISG Database includes an annotated version of the CISG, in which each CISG section is followed by links and citations to relevant decisions, travaux préparatoires, and secondary sources discussing how the section is interpreted and applied in practice.

The annotated text is an excellent starting point for researching any CISG section:

Treatises on the CISG

UNCITRAL provides a free and detailed commentary on the CISG:

Similar commentaries are provided by the preeminent treatises on the CISG, Schletriem & Schwenzer and Honnold:

In addition to the two preeminent treatises, the library owns other treatises on the CISG:

For a full list of books on the CISG available from the UCLA library system, check the library catalog for books listed under the subject of United Nations Convention on Contracts for the International Sale of Goods (1980 April 11):

Locating Additional Secondary Sources on the CISG

Pace Law School's CISG Database provides two tools for locating secondary sources on the CISG:

UNIDROIT's UNILEX database also includes a bibliography of sources on the CISG:

To locate additional law review articles, try the following sources:

Decisions on the CISG

Several reputable free websites provide online searching of arbitral and court decisions interpreting the CISG.

When searching these databases, keep in mind the following:

  • The databases do not reliably search full-text. Although many of the databases link to full-text, they typically only search abstracts (summaries) of the decisions and subjects and keywords associated with the decision. This means that the type of complex keyword searching that you might perform on Lexis or Westlaw is inappropriate and it's better to search for decisions by CISG article or broad subject or keywords that are likely to appear in abstracts. 
  • Do not expect to find full text copies of arbitration decisions. One primary appeal of arbitration for parties is that the parties may almost always keep the arbitration completely confidential if they so choose. Although a few arbitration decisions are posted as full text, many are available only as abstracts and most never see the light of day at all.
  • Do not expect to find full text English copies of foreign court decisions. Foreign court decisions are not routinely translated into English, just as U.S. court decisions are not routinely translated into Spanish or Chinese. Typically, an English language abstract is the most you should expect to find. 
  • Do not expect to find decisions precisely on point with your facts. Instead, retrieve the decisions on a specific article of the CISG or a specific topic and then review them to see how they can be applied to or distinguished from your facts. 
  • Although there is significant overlap between the databases, each database includes slightly different decisions and assigns them slightly different subjects and keywords. A search on one database may turn up a decision that you missed on another database. It is always helpful to check multiple databases.

Try the following databases for decisions on the CISG:

Travaux Préparatoires for the CISG

Travaux préparatoires (preparatory works) are the "legislative history" for a treaty and, like legislative history, may be used to interpret the text of the treaty.

The UNCITRAL website posts various travaux:

Pace Law School also posts travaux for the CISG:

Travaux are also available in print:

UNIDROIT Principles of Commercial Contracts

The CISG does not cover every possibility and it is common for researchers to turn to non-binding but more detailed texts to serve as gap fillers, when the CISG is silent. The most popular gap filler is the UNIDROIT Principles of Commercial Contracts, available from UNIDROIT's website:

UNIDROIT's UNILEX database includes tools for locating sources on not only the CISG but also UNIDROIT's own principles:

The library also owns print commentaries on the UNIDROIT principles, similar to the print commentaries on the CISG:

Lex Mercatoria and Other Gap Fillers

To supplement the CISG and UNIDROIT Principles, some researchers also turn to lex mercatoria- general principles of commercial law that have not been formally codified in a treaty, model law, or officially endorsed set of principles. A team of researchers at the University of Cologne has sought to write down these unwritten rules in their TransLex database:

When reviewing Pace Law School's Annotated Text of the CISG, you may also see references to:

  • The Principles of European Contract Law: model contract rules drafted by European academics;
  • The Proposed Common European Sales Law: a stalled EU proposal; and
  • The CISG Advisory Council: a private group of legal scholars who promote uniform interpretation of the CISG.

The CISG Advisory Council posts its opinions on its website: