Although the United Kingdom has not yet acceded to the Vienna Convention on the International Sale of Goods (1980), the Convention came into force on 1 January 1988, having secured the requisite number of states’ adherence to it. It is therefore bound to play at the very least a significant role in the future of international sales law. Whether it will be more successful in commanding the allegiance of international practitioners and merchants than its predecessor, the Uniform Law on International Sales (ULIS), remains, however, to be seen.

The 1980 Convention is ideologically represented as a compromise of the interests of the industrially developed world and of the developing world, in other words, of those states that manufacture goods and of those that consume goods. Expectations are therefore entertained that it will, unlike ULIS, be taken up by the developing world. This process can be seen to be played out in the “travaux préparatoires” of the Convention, where the national representatives of manufacturing and consuming states bring their countries’ preoccupations to bear upon particular texts. It also helps to explain why this Convention is so unconcerned with the documentary aspects of international buying and selling. The Vienna Convention appears not to have been framed for traders in the strings and circles of the various commodities markets, whose standard forms already demonstrate an intention to exclude the Convention and all its works. The principal focus of the Convention appears to be the sale of hard, manufactured goods, where the sales documents are more the wrapping in which the goods are to be found than any transactional substitute for the goods themselves.

Professors Bianca and Bonell, both of the University of Rome, have gathered together a multinational team to review a multinational text. A particular form of treatment has been prescribed and almost always adhered to—“History of the provision”, “Meaning and purpose of the provision”, “Problems concerning the provision”—but this uniformity conceals a wide variety of different personal styles and legal cultures. The quality, too, of the individual entries (there are 18 contributors) is variable, covering the range from excellent and penetrating to confusing and dull. The best contributions came from Farnsworth, in the area of contract formation, Bonell, on Arts. 7 and 9 (interpretation and usages and practices), Tallon, on impossibility of performance (Art. 79), and Nicholas, on risk. Some of the commentaries are quite uninformative and given to a mechanical paraphrase of the text as well as to a minute examination of its legislative history and antecedents, surely the least enticing aspect of the matter to an outsider. Some commentaries would have been improved by the addition of concrete examples.

There is little in the Convention to startle a common lawyer, with the exception of the actio quanti minoris (Art. 50), the consequences of which can be rather surprising where the market is volatile. Indeed, much of the Convention appears to have been influenced by common law thinking. Perhaps this is particularly striking with regard to the general availability of damages where the goods do not meet the prescribed quality standard. The especial impact of Art. 2 of the Uniform Commercial Code is evident in the provisions dealing with formation and with damages.

The impact of the common law points to one distinct drawback in the furtherance of this multinational venture. Generally speaking, the civilian commentators experienced some dis-