Unified Law in a Fragmented World: CISG and Conformity in Global Production

The UN Vienna Convention on Contracts for the International Sale of Goods (CISG or Convention) is among the most successful uniform instruments in international trade. Scholars often praise the CISG for creating a common language in international sales law—lingua franca—as the foundation of a more “secure, safer, and less expensive world.”¹ However, the socio-economic and political structures changed since its adoption: the number and diversity of member states steadily increased over time,² while the text of the Convention remained the same, with almost no possibility of amendments or changes.³ The global economy evolved to a disintegrated and interconnected model: “The goods we buy are the end result of an elaborately choreographed transnational odyssey. These objects are part of an economy whose tendrils reach over further outward, linking, integrating, and transforming both far-flung and nearby places.”⁴