Like throwing a pebble into a lake. That is the effect that this small book seeks to achieve—it aims to cause a stir and to instigate further debate flowing from its deliberately controversial proposition. That proposition is, in the words of Zeller, “to boldly ‘push the boundaries’ of unification of international sales laws at the expense of domestic laws” (p 1). Thus, the focus of the argument is on the possibilities for achieving uniformity of law at an international level, which as a side-effect will result in a diminished application of national laws in this sphere. The controversy lies in the latter point, for, as Zeller suggests, “[t]he greatest obstacle still remains the ethnocentric approach of those who have not yet realised the significance of the CISG and its potential to be a uniform international sales law transcending all legal systems” (p 107). In order to investigate the potential for uniformity, the book contains a number of propositions on the functioning of CISG as an instrument of unification of laws, grouped around a number of central themes, with particular attention being paid to the role of Art 7 in the interpretation and application of the Convention.

Before looking into the subject-matter of the book, it may be noted that its publication comes at an appropriate time. First, having entered into force in 1988, the experience of two decades of CISG provides not only a suitable occasion to pause and reflect on the functioning of the Convention but also—in the form of case law and legal literature—a wealth of material on the basis of which its successes and failures may be assessed. This is something clearly reflected in Zeller’s monograph, which in the course of its argument makes reference to a well-chosen selection of representative cases and publications. Secondly, a point to note for United Kingdom readers may be that the ratification of CISG by the UK government, though not expected in the near future, remains on the agenda. As stated by Lord Sainsbury of Turville in the parliamentary session of 7 February 2005, “[t]he United Kingdom intends to ratify the Convention subject to the availability of parliamentary time” (see http://www.publications.parliament.uk/pa/ld200405/ldhansrd/vo050207/text/50207w03.htm ). That Parliament does not appear to have found time for the Convention may be regrettable, but at least an indication remains of the willingness of the UK (eventually) to become party to a Convention in the drafting and negotiation of which it has played a major role. A third point to note may be that Zeller’s argument on unification of international sales law has an indirect bearing on other debates on approximation of laws. The most notable example that comes to mind in the European context is the ongoing discussion on the harmonization of the private laws (and in particular the contract laws) of the EU Member States. Zeller refers to this debate in passing. His suggestion is that unification is a good thing, and that harmonization can be a first step towards achieving it. Projects aimed at harmonization of European contract law, in his view, should be regarded as a confirmation of an increasingly positive attitude towards unification by the international community (pp 15–16). Funnily, a later comment suggests that interest groups doubt the importance of harmonization of European contract law on the ground that CISG provides a satisfactory solution (p 96). This comment seems somewhat out of date in light of more recent developments in which the focus has shifted towards the improvement of European legislation, in particular in the field of consumer law (see, eg, the Green Paper on the Review of the Consumer Acquis, COM(2006) 744 final). Nevertheless, without engaging in a further analysis of the debate