Die Behandlung der dépeçage im europäischen Internationalen Privatrecht

» Dépeçage « as a term of private international law means the division of the applicable law. In the European judicial area there is a great skepticism towards dépeçage, while in US American law the use of dépeçage is fairly liberal. However, also in the EU the division of the applicable law can create reasonable and - compared to the application of one law as a whole - advantageous results. The author examines the usage of dépeçage in the recent and future legislative acts of the EU which harmonize private international law in many areas (with focus on the Rome I and the Rome I Regulation). In doing so, she identifies the conditions, consequences and possible areas of use of dépeçage.