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Regarding international contracts the European Union has not only launched a private international law unification but also a substantive harmonization in certain sectors, such as consumers or commercial agency.
These substantive law rules and private international law rules must be coordinated. When they are not, there is a high risk of applying European contract law extraterritorially. To prevent this risk, this paper proposes the application of the “multilateral theory” to the interpretation of European contract law’s scope of application.
