The French and the German Reforms of Contract Law

Abstract

Abstract. France and Germany not only have very prominent private law codifications, but are also those countries which have taken the EC Sales Directive 1999 (among other EU developments) as an invitation to engage in an overall reform of their old Codes at the wake of the 21st Century. This invites to a comparison, namely because the one reform occurred when transposing the directive, within two years, the other after almost 1 ½ decades of considerations and discussions.