Turkey's Accession to the CISG: The Significance for Turkey and for Sales Transactions with U.S. Contracting Parties

Abstract

The United Nations Convention on Contracts for the International Sale of Goods (CISG) entered into force for Turkey on August 1, 2011. This article considers the significance of Turkey’s accession to the CISG as part of Turkey’s continuing engagement with systems of international trade, especially as relates to sales transactions with U.S. contracting parties. This article urges the Turkish bar to recognize that the CISG is a viable alternative to various potentially applicable bodies of domestic sales law, and the article offers some guidance regarding proper understanding and application of the CISG. This article also offers comparative analysis of some of the most important differences – and similarities – between the CISG and Article 2 of the Uniform Commercial Code, the primary domestic sales law in force in the United States, including analysis of the broad freedom of contract contained in each.

Keywords: CISG, Uniform Commercial Code, freedom of contract, international sales law, international trade

JEL Classification: K12, K20, K33