SOME MEDITATION ON THE "OPTING OUT" AND "OPTING IN": SCOPE AND APPLICATION OF THE CONVENTION ON THE INTERNATIONAL SALES OF GOODS AND THE COMMON EUROPEAN SALES LAW - PARALLELS AND DIFFERENCES.

The article presents a comparative study which analyses and compares the characteristics of the Vienna Convention on International Sales of Goods (CISG), harmonized contract law, Proposal on the Common European Sales Law (CESL) in business to business (B2B) relations and the classical private international law rules, especially Regulation Rome I. The study evaluates the contract law regime within the national laws of European Union (EU) Member States.