The New Nordic Approach to CISG Part II: Pragmatism Wins the Day?

Abstract

It is fair to say that the Nordic countries pride themselves in being international in the sense that they participate in international conventions, legislation and initiatives, and do so particularly when it comes to international legislation. Such enthusiasm often is without any hesitation despite potentially conflicting national caveats. However, now and then there is also a darker side to this coin characterised by a firm belief that Nordics do things better themselves than others can, and that the Nordic solutions are best, but such sins can also be found elsewhere. This duality can easily be seen when it comes to the CISG initiative at the beginning of the 1980’s. The Nordic countries were initially eager to integrate CISG as a part of their contract law and did not perceive the existing Nordic legislation on sales law dating from 1905 as any problem.