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The Association Henri Capitant des Amis de la Culture Juridique Française and the Société de législation comparée joined the academic network on European Contract Law in 2005 to work on the elaboration of a "common terminology" and on "guiding principles" as well as to propose a revised version of the Principles of European Contract Law (PECL). The results of this work were sent to the European Commission and have already been published in French. The English translation is now being published by sellier.elp. This work could contribute to the wider European project. The part on the guiding principles could be a component of the CFR, in the form of "black letter" model rules or recitals. The part on terminology is, in itself, useful for the elaboration of the final various linguistic versions of the CFR. It finds its place within the materials which will accompany the model rules. Last but by no means least, the revised version of the PECL should be considered by the European institutions as an alternative set of model rules on contract law.

Contracts --- Conflict of laws --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Civil law --- E-books --- Contracts - European Union countries --- Conflict of laws - Contracts - European Union countries --- Contrats (droit européen)

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Subcontracting --- Conflict of laws --- Contracts --- 347.45 --- Bijzondere overeenkomsten --(algemeen) --- 347.45 Bijzondere overeenkomsten --(algemeen) --- Sub-contracting --- Subcontracts --- Letting of contracts --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Law and legislation --- Civil law --- Subcontracting - European Union countries. --- Conflict of laws - Contracts - European Union countries.

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The Rome I Regulation on the Law Applicable to Contractual Obligations has unified the conflict of laws rules of the Member States. The influence of the European Union upon Private International Law goes beyond positive harmonisation however. There is a certain tension between European law and PIL. European law is concerned with whether the imposition of a rule constitutes a restriction to the internal market whereas PIL does not seek to neutralise the disadvantages that result from differences between national laws but instead tries to locate the geographical centre of the legal relationship. The present book attempts to identify the methodological disharmony between the two legal disciplines in the regulation of cross border contracts and proposes suggestions to enhance their mutual understanding.

Conflict of laws --- Contracts --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Civil law --- European Parliament. --- Council of the European Union. --- European Parliarment. --- Conflict of laws - Contracts - European Union countries --- Contracts - European Union countries

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This book contains a case-based assessment of the Draft Common Frame of Reference carried out by the Common Core Evaluating Group, which gathers a number of well-established and younger scholars coming from Eastern and Western countries of the European Union using the working method of the research project "The Common Core of European Private Law" (www.common-core.org). The aim of the assessment is to test how the Draft Common Frame of Reference could work when applied in different national legal systems. To this end, a number of factual situations, i.e. hypothetical cases, have been drafted by the authors and solved through the application of both national rules and rules of the DCFR. Thereby, similarities and differences in the outcome of the cases have been analysed, together with difficulties - if any - in the application of the "Principles of European Law". The Common Core assessment has been carried out as part of the "Joint Network of European Private Law" Project (CoPECL), financed by the EU Commission.

-346.02094 --- -Codification --- Civil law --- Conflict of laws --- Contracts --- 346.02094 --- Uh5.4 --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Law, Civil --- Private law --- Roman law --- International unification --- International unification. --- Contracts - European Union countries --- Conflict of laws - Contracts - European Union countries --- Civil law - Europe - International unification --- Droit civil --- Contrats (droit européen) --- Pays de l'Union européenne

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Contracts --- Conflict of laws --- -346.02094 --- -Codification --- -Conflict of laws --- -Civil law --- Uh5.4 --- Law, Civil --- Private law --- Roman law --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Agreements --- Contract law --- Contractual limitations --- Limitations, Contractual --- Commercial law --- Legal instruments --- Obligations (Law) --- Juristic acts --- Liberty of contract --- Third parties (Law) --- Codification --- -Contracts --- Law and legislation --- Contracts - European Union countries - Congresses --- Conflict of laws - Contracts - European Union countries - Congresses --- -Droit civil --- Contrats --- Droit international privé --- Pays de l'Union européenne --- Rétroactivité des lois --- Droit civil