Will

The newest volume in Kluwer's series of comparative analyses of Member State law and the Principles of European Contract Law (PECL), this book not only provides a comparison of the PECL with German law, but also takes into account the Draft Common Frame of Reference (DCFR). The latter incorporates the PECL and adds special rules that respond to current needs, notably in the area of consumer protection. Using a straightforward comparative method, the analysis reveals a significant area of convergence but also highlights the main differences between the PECL, the DCFR and German contract law. The reasons for these differences, both legal and non-legal (historical, social, economic), are clearly set forth.