In business, global markets developed in many areas. Germans order goods and services from abroad and vice versa. Contractual obligations with international reference are therefore of key importance for today’s trade.
Such contracts are by no means automatically governed by the well-known rules of German law, such as the Civil Code or the Commercial Code. For international sales contracts, for example, the UN Convention on the International Sale of Goods (CISG) is to be observed as an international convention that automatically applies between businesses from more than 80 States, unless the parties have explicitly agreed that the CISG is excluded. Where the CISG does not apply or where a service, sales or franchise contract was entered into, European regulations (Rome I Regulation) govern the applicable law. This also applies to creditor/debtor relationships that are not based on a contract, such as product liability (Rome II Regulation).
The experienced lawyers of Heuking Kühn Lüer Wojtek support you in planning and carrying out your cross-border activities in all areas of business law. We also advise you on an ongoing basis regarding new national and international rules and regulations. In addition, we can also seek legal advice on foreign jurisdictions at any time through one of our international cooperation partners from the World Services Group.