Article by Gonzalo Parra-Aranguren
The work undertaken by the International Institute for the Unification of Private Law (UNIDROIT) demonstrates the possibility of establishing the same substantive rules in various countries through uniform conventions; while keeping in mind that the identical result may also be obtained when a uniform law, annexed to a convention, is prepared. In fact, conventions on unification may differ formally. Some of them are self-executing treaties, incorporating the uniform rules in the text of the convention itself and becoming effective as soon as the required number of ratifications is obtained, as happened with the Vienna Sales Convention of 1980.1 In other cases, the provisions are gathered in a uniform law annexed to the convention, but when ratifying it, the contracting states assume the obligation to incorporate the uniform rules within their internal legislation. This latter method was followed by the Hague Sales Convention of 1964. Nevertheless, as remarked, the difference of procedure should not bring about any substantial consequences.
About the Author
Gonzalo Parra-Aranguren. Professor of Private International Law, Universidad Central de Venezuela and Universidad Catolica “Andres Bello.”
Citation
69 Tul. L. Rev. 1239 (1995)