[For more current case annotated texts by this author, see Bernstein & Lookofsky, Understanding the CISG in Europe, 2d ed. (2003) and Lookofsky, Understanding the CISG in the USA, 2d ed. (2004).]
330. The Scandinavian States (Denmark, Finland, Norway and Sweden) all wished to join the international community in ratifying the CISG. As regards inter-Scandinavian sales, however, these States did not wish to replace their essentially 'uniform' sales laws with the new CISG regime. Article 94 made it possible for the Scandinavian States, at the time of their CISG ratifications, to declare that the Convention is not to apply to contracts of sale or to their formation where the parties have their places of business in those States.[l]
The Article 94 declarations presuppose and indeed require that the Scandinavian States have 'essentially similar' legal rules on matters governed by the CISG Convention. And while it is still true that the Scandinavian rules are similar with regard to the rules which govern contract formation (The Contracts Acts), recent statutory amendments to the Scandinavian sales statutes (the Sales Acts) give good [page 176] reason to question whether the Scandinavian States (still) all have the kind of 'closely related' sales law rules required by Article 94.