국제물품매매계약에서 물품의 계약적합성에 관한 비교연구

Comparative Study on Conformity of Goods in Contracts for the International Sale of Goods- Approached to CISG and UCC -

The purpose of this paper is to compare requirements for Conformity of goods between CISG and UCC. Chapter II is to use CISG as a guide to review three major provisions: contractual requirements, subsidiary definition of conformity and awareness of the buyer. Chapter III is to deal with express warranty and implied warranty of UCC which are equivalent to requirements for the conformity of goods under CISG. Chapter IV is to compare related provisions of CISG with those of UCC and especially, we consider not only the structure of liability of defect and a definition of conformity of goods but also related provisions of Korean Civil and Commercial Law. Finally we conclude this paper by suggesting proper amendment of Korean contract laws.