Das europäische Kollisionsrecht der Verbraucherverträge zwischen Römer EVÜ und EG-Richtlinien

Recent EC directives on consumer protection have led to intricate questions regarding the relationship between international private law and European law. Stefan Klauer provides a comprehensive review of the relationship between conflict of laws provisions in the directives, the Rome Convention and national implementation measures. An extensive comparison shows that the member states have often failed to ensure an appropriate protection of the »active« consumer and to respect the binding guidelines set by the Rome Convention. A reform of the Convention would limit the tendency to enforce national provisions as internationally mandatory.