Most businesses in the United States are familiar with the Uniform Commercial Code (UCC). The UCC is a model law that has been adopted in some form in all fifty states. Article 2 of the UCC deals with the purchase and sale of goods within any state and between buyers and sellers located in different states. Although there are minor state-to-state differences, the UCC provides a high level of comfort and familiarity to purchasers and sellers in the US.
When buyers and sellers are located in different countries, however, they are frequently surprised to discover that there is another law that governs their transactions – the United Nations Convention on Contracts for the International Sale of Goods (CISG). The CISG is an international treaty to which almost 90 countries around the world are parties, including the US, almost all of Western Europe and Eastern Europe, China and Japan. The most significant countries that are not parties to the CISG include the United Kingdom, India, Hong Kong, Taiwan and South Africa.
This post will be the start of a series of posts about the CISG and how it affects international product sales transactions. Please check back from time to time to see the updates!