Harmonization of private law on a global level

P.J.J. Herings*, Arnald J. Kanning

*Corresponding author for this work

Research output: Contribution to journalArticleScientificpeer-review

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The Vienna Sales Convention (1980) follows in large measure the American Uniform Commercial Code: Article 2 on Sales. is this to imply that the Contracting States to the Vienna Sales Convention really prefer American sales law? This paper answers this question in the negative, and argues instead that the United States' economic leverage with other countries is the key factor influencing developments pertaining to private law on a global level.

We explain why it may be useful to harmonize rules of private law on a global level and which rules should be chosen for a uniform law. We show that the choice between two legal arrangements may lead to a coordination problem. Next we argue that the coordination problem is solved in favor of the jurisdiction whose economy is less dependent upon the economies of other jurisdictions than the other way around. We use our model to discuss the harmonization of sales law on a global level in the twentieth century. (C) 2008 Elsevier Inc. All rights reserved.

Original languageEnglish
Pages (from-to)256-262
Number of pages7
JournalInternational Review of Law and Economics
Issue number4
Publication statusPublished - Dec 2008
Externally publishedYes


  • Unification
  • Harmonization
  • Private law
  • Economic interdependencies
  • Game theory


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