The United Arab of Emirates is not yet a member state of the Convention on International Sale of Goods (CISG). It is widely submitted that no competition exists between the Convention and the local Law, since the sphere of application for each is different. Moreover, a national Judge is not immune from applying the Convention, even with the fact that his or her country is not a contracting state. Similarly, the Convection may apply to citizens of a non-contracting state, the place of business, rather than nationality, is what matters here. UAE Civil Transactions Act does not recognize some legal doctrines such as: fundamental breach, anticipatory breach, mitigation, besides the effect of force majeure is different under the UAE Law from that under the Convention. Despite this fact, rules concerning of formation of contract, obligations of sellers and buyers, remedies, the general principles upon which the contract is based are all similar to those under the Convention. The study recommends that the UAE ratify the Convention because it will encourage trade and contribute to the unification of the international trade law.
"Legal Reflections on the Ratification by the UAE of the Convention on International Sale of Goods (CISG) 1980: “A Study on the Interrelationship between the UAE Civil Transactions Act and the CISG”,"
UAEU Law Journal: Vol. 2017:
69, Article 2.
Available at: https://scholarworks.uaeu.ac.ae/sharia_and_law/vol2017/iss69/2