The recently enacted Consumer Guarantees Directive, when adopted into national law by member states, will provide Europe with reasonably uniform rules pertaining to warranties and guarantees in sales by merchants to consumers. These rules are roughly comparable to those in the United States and the Vienna Convention for the International Sale of Goods. The authors examine the differences between the European Union and major U.S. laws. They also suggest that the new directive leaves significant room for variation within Europe and is inconsistent with other European directives.
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