“统一实体法”方法的缺点 1、主要适用于商事领域，人身性质方面的国际性实体法律规则鲜见 2、国际公约适用的前提：一国已经签署该公约 3、国际公约所包含的内容不如国内法周延 United Nations Convention on Contracts for the International Sale of Goods Article 2 This Convention does not apply to sales:(a)of goods bought for personal,family or household use,unless the seller,at any time before or at the conclusion of the contract,neither knew nor ought to have known that the goods were bought for any such use;(b)by auction;(c)on execution or otherwise by authority of law;(d)of stocks,shares, investment securities,negotiable instruments or money;(e)of ships, vessels,hovercraft or aircraft;(f)of electricity
“统一实体法”方法的缺点 1 、主要适用于商事领域，人身性质方面的国际性实体法律规则鲜见 2、国际公约适用的前提：一国已经签署该公约 3、国际公约所包含的内容不如国内法周延 United Nations Convention on Contracts for the International Sale of Goods Article 2 This Convention does not apply to sales: (a) of goods bought for personal, family or household use, unless the seller, at any time before or at the conclusion of the contract, neither knew nor ought to have known that the goods were bought for any such use; (b) by auction; (c) on execution or otherwise by authority of law; (d) of stocks, shares, investment securities, negotiable instruments or money; (e) of ships, vessels, hovercraft or aircraft; (f) of electricity
CISG Article 4 This Convention governs only the formation of the contract of sale and the rights and obligations of the seller and the buyer arising from such a contract.In particular,except as otherwise expressly provided in this Convention,it is not concerned with:(a)the validity of the contract or of any of its provisions or of any usage;(b)the effect which the contract may have on the property in the goods sold. Article 5 This Convention does not apply to the liability of the seller for death or personal injury caused by the goods to any person. Article 6 The parties may exclude the application of this Convention or,subject to article 12,derogate from or vary the effect of any of its provisions
CISG Article 4 This Convention governs only the formation of the contract of sale and the rights and obligations of the seller and the buyer arising from such a contract. In particular, except as otherwise expressly provided in this Convention, it is not concerned with: (a) the validity of the contract or of any of its provisions or of any usage; (b) the effect which the contract may have on the property in the goods sold. Article 5 This Convention does not apply to the liability of the seller for death or personal injury caused by the goods to any person. Article 6 The parties may exclude the application of this Convention or, subject to article 12, derogate from or vary the effect of any of its provisions