The United Kingdom is one of a dwindling number of an expanding group, European countries, that has not yet become party to the United Nations Convention on Contracts for the International Sale of Goods (CISG). Why this should be the case is not clear. The flexibility or, as some would have it, the uncertainty that CISG brings to bear in defining the rights and duties of the buyer and seller in an international sale of goods may well be anathema to the international commodity trading associations. But CISG permits contracting parties to exclude it in its entirety or, within certain limits, partially (Arts, 6, 12 and 96). Furthermore, the commodity trading associations operating out of London have inserted standard clauses in their contracts routinely excluding CISG, just as they did in the case of its twin predecessors, the 1964 Hague Conventions on Formation and International Sale of Goods. And it is not as if CISG has anything particularly useful to say about most of the issues that have surfaced in the pages of Lloyd’s Reports concerning commodity sales. Indeed, anyone reading CISG would have to do so carefully to see therein the recognition of international documentary sales.

The two books forming the subject of this review have the same publisher but they are very different in their style and approach. Honnold is the work of an outstanding American sales lawyer whose leading role in the United Nations Commission on International Trade Law during the creation of CISG makes him especially authoritative in setting out the background to and writing a commentary on CISG. This book is the first port of call and the standard text for anyone working on the Convention. The other book, Kritzer, is designed to meet the practical needs of American attorneys faced with CISG in their daily professional lives.

Honnold is organized as follows. After a useful general introduction (“Overview”), the author tackles the Convention article by article dealing with their scope and any difficulties in their implementation. The book is well documented and there is a detailed treatment of background literature, including general literature from numerous jurisdictions on the law of sale. In this respect, Honnold has expanded to a significant degree since its first edition. There are references, too, to the author’s own documentary history of the Convention for those readers seeking to follow the CISG through its various deliberative stages. The author uses numerous practical examples and variations thereon that are most helpful to the reader. He is particularly effective in making use of the provisions of CISG in their entirety in proffering solutions to problems. Altogether, the work is outstanding. Professor Honnold has given us a major work of comparative legal scholarship which is not confined to the special contract we call sale. Anyone who has worked in the area of comparative drafting will recognize the force of the following observation (p. 210): “The only vessel in which one can hope to carry a uniform rule across multi-lingual terrain is by the description of a thought or