![](http://static.cambridge.org/content/id/urn:cambridge.org:id:book:9781780687629/resource/name/9781780687629i.jpg)
- Publisher:
- Intersentia
- Online publication date:
- January 2019
- Print publication year:
- 2018
- Online ISBN:
- 9781780687629
- Subjects:
- Law, Comparative Law
22 August 2024: Due to technical disruption, we are experiencing some delays to publication. We are working to restore services and apologise for the inconvenience. For further updates please visit our website: https://www.cambridge.org/universitypress/about-us/news-and-blogs/cambridge-university-press-publishing-update-following-technical-disruption
This book is an in-depth study of the US and EU approaches towards consumer sales remedies. It does not limit itself to a mere comparison of the hierarchy of consumer sales remedies but covers the topic comprehensively, also examining (extra)judicial application of remedies and notification duties. Whereas EU rules prescribe a very strict hierarchy of remedies that are often misunderstood by consumers, and are very favourable towards the remedy of specific performance (or performance in kind), in the US a strong preference for damages can be found. This means that consumers often do not know which remedy they are exactly entitled to or how to invoke it in a correct manner.Learning from both systems, Consumer Sales Remedies in US and EU Comparative Perspective provides a valuable and insightful contribution to the discussion of what the organisation of remedies should look like to best protect consumers. It is written at a time when the EU is considering a 'new' consumer sales Directive, and US scholars are working on the restatement of consumer contract law. It proposes to give consumers a free choice, limited by good faith and proportionality only.Dr Sanne Jansen is a judicial trainee in Antwerp, Belgium and research fellow at the Institute for the Law of Obligations at KU Leuven, Belgium. She is a member of the editorial board of the DCCR and TBH.
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