The current limits of European harmonisation in consumer contract law

摘要

This paper is concerned with the Proposed Consumer Rights Directive. In particular it considers the choices to be made concerning minimum and maximal harmonisation. In doing so it draws upon previous experiences of harmonisation and in particular reflects on the approach of the European Court of Justice. The aim is to consider which areas of the Proposed Consumer Rights Directive require maximal harmonisation and which ones can be left to minimal harmonisation.