Consumer Sales Remedies in US and EU Comparative Perspective (Paperback)

Paperback. 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. This book is an in-depth study of the US and EU approaches towards consumer sales remedies that comprehensively discusses the three important elements of the organisation of consumer sales remedies: the hierarchy of remedies, the (extra)judicial application of remedies and notification duties. Shipping may be from our Sydney, NSW warehouse or from our UK or US warehouse, depending on stock availability.