Emmert, Frank2014-02-142014-02-142012Emmert, Frank. "The Draft Common Frame Of Reference (DCFR) - the Most Interesting Development in Contract Law Since the Code Civil and the BGB." Cuadernos de la Maestría en Derecho 2 (2012): 1-25.2027-9469https://hdl.handle.net/1805/3994The paper presents the DCFR, which is the blueprint for the future Code of Obligations of the European Union and works or works a bit like the UCC in the United States, that is, as a model of commercial code. After a brief historical justification of the project, there is a presentation of what may or may not make the DCFR today. Finally, the potential effect of the MCR project to be chosen by the parties to an international sale transaction is explained through a hypothetical situation.esInternational Sale of Goods, choice of law, Contracts for the International Sale of Goods (CISG), Unidroit Principles, Draft Common Frame of Reference, European private law, European contract law.Export sales contracts -- Europe Union countriesContracts -- Europe Union countriesConflict of laws -- Contracts -- Europe Union countriesCivil law -- EuropeArticle