Die Principles of European Law on Personal Security als neutrales Recht für internationale Bürgschaftsverträge

Within the framework of plans of the European Commission to work out a Common Frame of Reference for contract law, the Study Group on a European Civil Code prepared proposals for uniform rules on personal security on the basis of comparative studies of the laws of the member states of the European Union. The Principles of European Law on Personal Security are meant to be eligible as an alternative set of rules before national and arbitral courts. Katharina Klingel discusses whether and to what extent the Principles meet the needs of participants in the European Common Market (for example enterprises and consumers) as the basis for international suretyships. The discussion is based on a comparison of the Principles with German and French law.