The Law Applicable to Contracts in the European Union - A Competition Between Rome I Regulation, Other Sources of EU Law and Directive Law as Implemented

California International Law Journal, Vol. 20, No. 1 & 2, Spring/Summer 2012, 21-53

32 Pages Posted: 24 Oct 2012 Last revised: 6 Feb 2013

See all articles by Tamas Dezso Ziegler

Tamas Dezso Ziegler

Eötvös Loránd University

Izolda Takacs

University of Pécs

Date Written: 2012

Abstract

EU private international law ("PIL") was significantly different before the recent private international law boom. Before 1998, there had been only fragmented and miscellaneous conflict-of-laws provisions in the acquis communautaire, focusing on specific areas. Most provisions were to be found in directives dealing with substantive law, i.e. the conflict-of-laws rules were merely extensions to the regulations in certain areas. Adopting such rules was common in the fields of consumer protection (i.e. consumer contract law) and insurance law. The article tries to summarize these rules and analyse their connection with the latest law, i.e. with the provisions of the Rome regulation on the law applicable to contracts.

Keywords: Rome I regulation, consumer law, labour law, conflict-of-laws, private international law, sales law

JEL Classification: K12, K2, K20

Suggested Citation

Ziegler, Tamas Dezso and Takacs, Izolda, The Law Applicable to Contracts in the European Union - A Competition Between Rome I Regulation, Other Sources of EU Law and Directive Law as Implemented (2012). California International Law Journal, Vol. 20, No. 1 & 2, Spring/Summer 2012, 21-53, Available at SSRN: https://ssrn.com/abstract=2166016

Tamas Dezso Ziegler (Contact Author)

Eötvös Loránd University ( email )

Pazmany Peter setany 1A
Budapest, -- H1117
Hungary

Izolda Takacs

University of Pécs ( email )

Budapest
Hungary

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