IZBIRA MATERIALNEGA PRAVA

Arbitration and UNCITRAL’s Sales Conventions

Cyril Emery, Julia Salasky

In contracts or disputes concerning international sales of goods, the United Nations Commission on International Trade Law has produced two legal texts which present themselves as particularly apt options in the matter of selecting the applicable substantive governing law: the United Nations Convention on Contracts for the International Sale of Goods ("CISG") and the Convention on the Limitation Period in the International Sale of Goods ("Limitation Convention"). This article provides (a) a brief introduction to the content and status of these conventions, (b) an overview of the frequency with which they are used in arbitration, (c) a presentation of the advantages that they may present as the governing substantive law of a dispute involving parties from different States, (d) information on the manner by which these texts are selected as the governing law in an arbitration, and, finally, (e) a preview of developments in international organizations that may further increase the use of these texts in arbitration.