The Draft Common Frame Of Reference (DCFR) - the Most Interesting Development in Contract Law Since the Code Civil and the BGB

The paper presents the DCFR, which is the blueprint for the future Code of Obligations of the European Union and works or works a bit like the UCC in the United States, that is, as a model of commercial code. After a brief historical justification of the project, there is a presentation of what may or may not make the DCFR today. Finally, the potential effect of the MCR project to be chosen by the parties to an international sale transaction is explained through a hypothetical situation