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Comparison with Principles of European Contract Law (PECL)

Match-up of CISG Article 77 with PECL Article 9:505
CISG Article 77

A party who relies on a breach of contract must take such measures as are reasonable in the circumstances to mitigate the loss, including loss of profit, resulting from the breach. If he fails to take such measures, the party in breach may claim a reduction in the damages in the amount by which the loss should have been mitigated.

PECL Article 9:505 [Mitigation: Reduction of Loss]
(complete and revised version 1998)

(1) The non-performing party is not liable for loss suffered by the aggrieved party to the extent that the aggrieved party could have reduced the loss by taking reasonable steps.

(2) The aggrieved party is entitled to recover any expenses reasonably incurred in attempting to reduce the loss.


For the PECL definition of "reasonableness", go to PECL 1:302 and the comment and notes that accompany this provision.

Editorial remarks

Comparison between the provisions of the CISG on mitigation of losses
(Art. 77) and the counterpart provisions of PECL (Art. 9:505)

Bruno Zeller [*]
April 2005

  1. General Comments
  2. Question of Reasonableness
  3. Conclusion

I. General Comments

Mitigation is a principle which is an obligation in the common law but not clearly defined in civil law. In arbitration practices mitigation has become a general principle of international trade and Mustill refers to the principle as "[to] constitute the lex mercatoria in its present form."[1] He went further by noting that mitigation is merely treated as obvious.[2]

The CISG has incorporated the doctrine of mitigation specifically into article 77 but the rule is also reflected in articles 85 and 86 which are concerned with the preservation of the goods after a breach. The idea behind article 77 is that the plaintiff cannot recover damages or losses which he should have avoided. This principle is also accepted in the Principles of European Contract Law (PECL) in article 9:505.[3]

The first obvious difference between PECL and the CISG is that article 77 clearly states that losses include loss of profit whereas PECL is silent on this aspect. Whether loss of profit is included in the PECL can be assumed, as the official commentary to article 9:501, specifically illustration 4, explains that loss of profit is included.[4] Furthermore, article 9:502 PECL stipulates that a party has the right to recover losses and "the gain of which it has been deprived."[5] In addition, the CISG can be used as an analogical tool which would confirm that losses as explained in PECL includes loss of profits and therefore are identical to the CISG and, hence, mitigation follows the same pattern of losses in the counterpart provisions.

Another point worth noting is that PECL in its language only refers to losses whereas the CISG introduces the word "damages" in addition to losses. The question is, whether the term "damages" is to be understood to expand on losses? Stoll is correct to argue that this includes the conclusion of cover transactions - or even avoidance must be contemplated - if it will reduce damages.[6] PECL arguably covers the same ground by reference to a reduction of losses "by taking reasonable steps". Such language is broader than the one in article 77 as it will allow a court or tribunal wider discretion as to what is included in "reasonable steps". Whether avoidance or cover transactions are included in "reasonable steps" is not certain; however, it is not specifically excluded either

A real problem seems to be the choice of the words. The CISG text provides that a party who relies on a breach of contract "must" take measures to mitigate the loss. Arguably in its language this article imposes a duty on the plaintiff to mitigate the "loss." Whereas PECL only suggests that the non-performing party is not liable for damages which the aggrieved party "could" have reduced. The wording is not as strong as the one in the CISG as it appears to rely on a subjective appraisal of the situation by the non-breaching party and to that effect by the court or tribunal.

The question, which has been posed, is whether, due to the choice of wording, article 77 imposes a legal obligation[7] and hence allows the original breaching party to claim a set-off. The Secretariat Commentary to article 73 of the 1978 Draft (draft counterpart of CISG article 77)suggests that it is "a duty owed by the injured party to the party in breach"[8] whereas another view is that the injured party "is under an obligation to herself to mitigate the loss."[9] This view can be supported because the second sentence of article 77 makes it clear that should the aggrieved party not follow the advice given in the first sentence he will bear some of the costs associated with the breach. It could not have been clearer that "must" is linked to the second sentence which means that inactivity, or the failure to take reasonable steps to mitigate, are no excuse.[10]

This could be contrasted with the English view which can be formulated as follows:

"A plaintiff is under no duty to mitigate his loss, despite the habitual use by the lawyers of the phrase 'duty to mitigate'. He is completely free to act as he judges to be in his best interests."[11]

Arguably the English view is mirrored by PECL but not the CISG where the reading suggests that the non-breaching party has a legal duty to mitigate the loss.

PECL simplified the whole process by starting with the premise that the non-performing party simply is not liable for any losses which the aggrieved party could have avoided. It does require a positive step by the aggrieved party to mitigate any possible losses.

II. Question of Reasonableness

Both the CISG and PECL suggest that reasonable steps must be taken in order to mitigate the loss. In both instruments this is not a question of law but rather a question of fact. Every case will have different circumstances; hence, if a person takes steps which are in good faith - which is a principle found in both instruments - he has acted reasonably specifically if the measures adequately prevent losses. However it will be within the court's discretion to evaluate measures of mitigation. Obviously, if no measures have been taken then a party will be in breach of CISG article 77 or PECL article 9:505. It is never suggested that the efforts to mitigate must be exceptional.

The argument is, however, how far, or how much action is required to satisfy the reasonable standard test. The Supreme Court of Austria considered that:

"a possible measure to reduce damages is reasonable, if it could have been expected as bona fide conduct from a reasonable person in the position of the claimant under the same circumstances."[12]

It appears that, given the facts of the case, the court chose to look at the objective measure of a situation. As such, excessive measures, or those which entail unreasonable high expenses and risks, are not necessary.[13] This has been confirmed by the Austrian Supreme Court which noted that:

"the buyer may not undertake any unreasonable expenditures (Art. 77 CISG): if the costs to effect a cure stand in no reasonable proportion to the benefit of the cure for the buyer, then they are not recoverable."[14]

This conclusion was confirmed by a Swiss court pointing also to the to the fact that mitigation not only obliges the aggrieved party to take positive steps but these positive steps cannot be undertaken when they result in unnecessary costs. In essence the court stated:

"Seller's counterclaim may be reduced to the extent he took measures to mitigate the losses or ought to have taken such measures. Such measures entail namely the re-sale or respectively the re-utilization of the sold machine, if there was not any market place for such a kind of production machine, because it was unique. Furthermore, these measures also entail the avoidance of any unnecessary expenditures and costs."[15]

A reading of PECL counterpart provisions leads to the same result. However, article 9:505(2) turned the obligation around by allowing the aggrieved party only to recover costs which are "reasonably incurred." The interpretation of the CISG as pointed out above suggests that the non-breaching party can incur expenses until the costs to mitigate become unreasonable. In sum, though, the practical effect is the same.

Not surprisingly, courts have been relatively strict in their interpretation of CISG article 77. A Swiss Court dismissed the claim of the plaintiff that it had to pay damages to a third party as it neglected to involve the defendant in the negotiations with the third party. In such a case, the defendant could have contributed to the costs or even indemnified the plaintiff.[16]

Not all cases are controversial or difficult, as seen in a Russian arbitration proceeding. The tribunal paid attention to the fact that the buyer did not take any measures whatsoever to mitigate the loss:

"He did not cancel the contract with a third party, nor conclude substitute transactions and did not resort to article 76 when calculating the damages."[17]

The same approach was taken by the Intermediate People's Court of Shandong Province. The court apportioned the main responsibility to the buyer who "did not take reasonable measures and just let the losses grow until the value of the PTO shrimp was nearly extinguished."[18] Arguably, though, the courts would have come to the same conclusion if they had applied the PECL to the case.

Mitigation is not necessarily restricted to minimizing actual costs. Courts have viewed the circumstances of the contract in very broad terms and merely ask the question "could the situation have been changed but for the buyer's behaviour". An interesting case is where the buyer did not produce evidence asked for by the arbitral panel to determine whether he took measures to eliminate a negative impression in relation to the seller's products. The arbitral panel found it inexcusable that the buyer in effect agreed with the unsubstantiated allegations of his consumers.[19] Whether the same result would have been achieved under PECL is debatable. It would depend on the definition of "loss." Under the CISG this debate is avoided as "damages" are also included in article 77 and a negative impression will cause damages but not necessarily a loss.

III. Conclusion

In summary, the above cases illustrate that courts and tribunals simply ask whether the prudent business person has taken all reasonable steps, and has done all he can to keep costs to the breaching party to a minimum. Merely ignoring the situation is in breach of CISG article 77, so is willful adherence to contractual terms. In effect, it is of little value to try to give a definition of what is "reasonable", as each court has demonstrated that in a practical sense the word "reasonable" is well understood. One point noted by Saidov is that mitigation can bring about certain forms of costs as well. Arguably, article 77 is broad enough here to cover the situation where the mitigating party incurred costs, which could be off-set.[20] However, costs to mitigate will be subject to the same rules as the mitigation process itself. If costs are not necessary, the mitigating party cannot claim any recompense. It is argued that PECL in most circumstances would deliver the same results as those achieved by the CISG. The only question which possibly is unanswered is whether PECL article 9:505 could be as broadly interpreted as the CISG, i.e., as set-off and mitigation of abstract damages such as negative impressions or loss of reputation.

[See also commentary by the author on this subject in: John Felemegas ed., An International Approach to the Interpretation of the United Nations Convention on Contracts for the International Sale of Goods (1980) as Uniform Sales Law, Cambridge University Press (2006) 486-490.]


* Senior Lecturer in Law, Victoria University Law School, Melbourne Australia.

1. Mustill M., "The New Lex Mercatoria: The First Twenty-Five Years" 4 Arb. Int'l (1988) 86 - 119, at 113 [available on the Internet courtesy of CENTRAL Transnational Law Database (TLDB)].

2. Ibid at 100.

3. Lando, O., and Beale, H., Principles of European Contract Law, Kluwer Law (2000), 445.

4. Ibid at 435.

5. Ibid at 438.

6. Stoll H. in Schlechtriem P., Kommentar zum Einheitlichen UN-Kaufrecht, (2000), 587.

7. Saidov D., "Methods of limiting Damages under the Vienna Convention on Contracts for the International Sale of Goods", available online at <http://cisgw3.law.pace.edu/cisg/biblio/saidov.html>

8. Secretariat Commentary to Article 73 of the 1978 Draft, para 3, available online at <http://cisgw3.law.pace.edu/cisg/text/secomm/secomm-77.html>

9. Bernstein H. and Lookofsky J., Understanding the CISG in Europe, Kluwer, 2nd ed. (2003), 103.

10. Zeller B., Damages under the Convention on Contracts for the International Sale of Goods, Oceana Press (2005), 112.

11. Sir John Donaldson, in The Solholt [1983] 1 Lloyd's Rep. 605.

12. Austria 6 February 1996 Oberster Gerichtshof [Supreme Court], case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/960206a3.html>

The plaintiff, a German buyer, and the defendant, an Austrian seller, entered into an agreement for the FOB delivery of a certain quantity of propane gas. See analysis of Austrian case law by Willibald Posch & Thomas Petz, "Austrian Cases on the UN Convention on Contracts for the International Sale of Goods", 6 Vindobona Journal of International Commercial Law and Arbitration (2002) 1-24, at 23:

"When dealing with the Convention's provision on mitigation of damages (Article 77 CISG), the Court held that the loss, including lost profits, suffered from a breach of contract may only be claimed to the extent to which the loss should not have been mitigated by measures that would have been reasonable in the circumstances. Examples of such reasonable measures to mitigate the loss would be those which under the circumstances of the individual case could have been expected in good faith. In the Court's view, the answer to the question of which measures would be reasonable and ought to be taken depends on how a reasonable creditor would have acted in the same situation. [Because of the absence of any substantial argument on this point during the proceedings, this question was not answered by the Austrian Supreme Court in greater detail.]"

13. Saidov, supra note 7.

14. Austria 14 January 2002 Oberster Gerichtshof [Supreme Court], case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/020114a3.html> [a German seller and an Austrian buyer concluded a contract for the sale of a cooling system to be specifically manufactured by the seller].

15. Switzerland 3 December 2002 Handelsgericht [Commercial Court] St. Gallen, case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/021203s1.html> [the plaintiff, a buyer incorporated in Tel Aviv, Israel, ordered from the defendant, a seller, of Switzerland, a sizing machine for the production of textiles].

16. Switzerland 1 March 2002 Zivielgesetz [Civil Court] Basel, P 1997/482, para 3.7; case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/020301s1.html> [a Belgian seller and a Swiss buyer concluded a contract for the sale of soy protein products].

17. Russia 6 June 2000, Arbitration proceeding 406/1998; case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/000606r1.html> [an English buyer and a Russian seller concluded a contract for the sale of goods to be shipped to a certain port on c.i.f. terms. When the seller notified the buyer that it would not perform the contract due to an increase in tax rates which, in its view, amounted to force majeure, the buyer filed a motion for arbitral proceeding claiming damages].

18. China 17 December 1999 Rizho Intermediate People's Court, Shandong Province (Hang Tat v. Rizhao), case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/991217c1.html> [buyer, of the U.S.A., concluded a contract with sellers, of China, for the sale of a quantity of frozen shrimp].

19. Russia 24 January 2000 Arbitration proceeding 54/1999, case presentation including English translation available at <http://cisgw3.law.pace.edu/cases/000124r1.html> [a U.S. firm, the buyer, commenced proceedings against a Russian company, the seller, in connection with a contract concluded between the parties, which involved the delivery of two consignments on an FCA (free carrier) basis, in accordance with Incoterms under the contract].

20. Saidov, supra note 7.

Comment and notes on PECL 9:505

Like the commentary to the UNIDROIT Principles and the U.S. Restatements, the comments to the PECL help explain the text. The PECL notes identify civil law and common law antecedents and related domestic provisions. With the permission of the Commission on European Contract Law, these comments and notes are presented below. The source of this material is Ole Lando & Hugh Beale eds., Principles of European Contract Law: Parts I and II, Kluwer Law International (2000) 445-448.

COMMENTS AND NOTES: PECL Article 9:505: Reduction of Loss

(1) The non-performing party is not liable for loss suffered by the aggrieved party to the extent that the aggrieved party could have reduced the loss by taking reasonable steps.

(2) The aggrieved party is entitled to recover any expenses reasonably incurred in attempting to reduce the loss.


A. Failure to mitigate loss

Even where the aggrieved party has not contributed either to the non-performance or to its effects, it cannot recover for loss it would have avoided if it had taken reasonable steps to do so. The failure to mitigate loss may arise either because the aggrieved party incurs unnecessary or unreasonable expenditure or because it fails to take reasonable steps which would result in reduction of loss or in offsetting gains.

Illustration 1: B buys an old car from S for 750. S warrants that the car is in good running order. B discovers that it will cost 1,500 to put the car into good running order, and he has this work done although similar cars in good condition are available for 800. B's damages will be limited to 800; the extra amount represents an expenditure which was quite disproportionate to the value of the car as repaired (The result might be different if there were some good reason for B to have repairs done, e.g., the car was unique in that it had once belonged to General de Gaulle).

Illustration 2: C hires a camper van to take his holiday in Portugal. When he comes to collect the camper van, the car hire company tells C that it has made a mistake in bookings and no van is available from it, but it has managed to find for him another company which has a van available at a higher price. Even if C unreasonably ignores this and abandons his holiday, his damages should be limited to the loss he would have suffered if he had acted reasonably in taking the substitute van, namely the difference in cost between the vans and compensation for inconvenience in having to collect his replacement.

The aggrieved party will not necessarily be expected to take steps to mitigate its loss immediately it learns of the breach; it will depend on whether its actions are reasonable in the circumstances.

Illustration 3: O engages B, a builder, to come within 24 hours to repair the roof of O's house, which is leaking and causing damage to the decorations. B does not come within the 24 hours but assures O that it will come the next day. It is [page 445] reasonable for O to wait until the day after before calling in another builder, and O may claim damages resulting from this period of delay; but it may not be reasonable to wait any longer and if O does so it may not recover damages for the resulting additional loss.

The aggrieved party is only expected to take action which is reasonable, or to refrain from action which is unreasonable, in the circumstances. Thus it need not act in any way that will damage its commercial reputation just to reduce the non-performing party's liability.

Illustration 4: D buys goods from E in order to resell them to F. The goods supplied by E are not of proper quality. Although under the terms of its contract with F, D could require F to take the goods without a price reduction, this would be unreasonable in the light of their long-standing business relationship and D gives F a reduction of price. D may recover the amount by which it reduced the price as damages from E.

The principle applies also when one party is guilty of anticipatory non-performance within Article 9:304, e.g., by announcing that it will not perform the contract when the time comes. The aggrieved party should not incur further expenditure needlessly and should take steps to reduce its loss.

Illustration 5: K contracts to build a yacht to L's special design. L repudiates the contract. If K has done little work on the yacht and it would not be able to find a ready buyer for such a unique design of boat, it is reasonable to expect it to stop work ; it may recover the cost of the work done to date and the loss of anticipated profit. If, on the other hand, it has done most of the work and can find another buyer at a reasonable price, then even where it has terminated the contract under Article 9:304 it may be expected to complete the boat and resell it. It will be entitled to damages of the difference between the original contract price and the resale price (Article 9:506), plus the incidental costs of arranging the resale.

C. Expenses incurred in mitigating loss

Frequently the aggrieved party will have to incur some further expenditure in order to mitigate its loss. This incidental expenditure is also recoverable provided it is reasonable.

Illustration 6: X agrees to buy Y's chalet, which Y had advertised widely. Later X repudiates the contract. Y decides to make a cover transaction. In order to resell the house he has to advertise it again. He is entitled to the reasonable cost of the further advertising as well as to the difference between the prixe X had agreed to pay and the price for which the chalet was ultimately sold.

D. Reasonable attempts to mitigate which in fact increase the loss

Sometimes a party may take what at the time appears to be a reasonable step to reduce its loss but in fact increases it. The full loss suffered is recoverable. [page 446]

Illustration 10: G enters a long term supply contract to buy oil from H; deliveries are to commence in six months' time. Three months later oil prices rise rapidly because of a threatened war in the Gulf and H repudiates the contract. G quickly terminates the contract and enters a substitute contract with J at the price then being quoted for delivery three months later. By the time the date for delivery comes the threat of war has receded and G could have bought the oil for the original contract price. It acted reasonably in entering the substitute contract and is entitled to damages based on the difference between the original contract price and the price it had to pay to J.

E. Loss reduced by steps going beyond what could reasonably be expected

Sometimes a party will take a step which reduces its loss but which goes beyond what it might reasonably have been expected to do. The reduction in loss will still be taken into account, as it is entitled only to damages for actual loss: see Article 9:501.

Notes [Match-ups with Continental and Common Law domestic rules, doctrine and jurisprudence]

1. Loss caused by aggrieved party (Article 9:504)

(a) Different treatment of loss caused by aggrieved party and "mitigation"

Some legal systems treat the aggrieved party's contributory negligence and his "duty" to mitigate his loss differently. FRENCH cases, which mostly have dealt with tort liability, have admitted that in contracts also contributory negligence by the aggrieved party may reduce his claim for damages. The creditor's act will constitute a cause of exoneration even if it doe not constitute force majeure: Civ. 1, 31 January 1973, D.1973.149, note Schmelk; see Malaurie & Aynès, Obligations no. 833. French law does not know mitigation as such, but some similar results may be obtained by the application of the general rule about fault. See Cass. civ. 1, 29 April 1981, JCP 1982, 19730 where damages were reduced, as it was a "fault" of the obligee not to avoid loss due to the negligent non-performance of the obligor, and Paris, 7 Jan. 1924 DP 24.1.143 where the court would not permit the obligee to let the loss grow without notifying the obligor so that he could stop the supply of defective goods. See also on leases CC art. 1760. However, French law is reluctant to impose duties on the aggrieved party: Com. 28 June 1994, B.IV. no. 248 (warranty against vices cachées). On SPANISH law, Supreme Court 1960, 15 November 1994 (see Bercovitz, CCJC 550; Angel 13 ff.; and Diez Picazo, II, 89). On DANISH law see Gomard, Obligationsret II, 186 (duty to mitigate) and 187 (contributory negligence).

In ENGLISH law "contributory negligence" will generally either be no defence to a claim in contract or, on the theory that the loss was not caused by the breach, will lead to no compensation at all. However, a reduction of damages may be allowed in certain cases where the obligor was under a concurrent duty of care in tort and the plaintiff also failed to act carefully, see Treitel, Contract 886-891. The aggrieved party's failure to mitigate may lead to a reduction of the damages: ibid., 881-886. SCOTTISH law is to the same effect, McBryde, Contract, 454-462. The same rule is laid down in art. 77 of CISG. Furthermore, CISG art. 80 provides that a party may not rely on the failure of the other party to perform, to the extent that such failure was caused by the first party's act or omission. It has been convincingly argued that this rule may be extended by way of the interpretation by analogy rule provided in art. 7(2) so as to allow reduction of damages in case of the aggrieved party's "contribution" to the non-performance, see Bianca & Bonell (-Tallon) Art. 80 note 2.5 p. 598, but see.v. Caemmerer & Schlechtriem (-Stoll) 677.

In IRELAND there is a duty to mitigate the loss, as in England, thereby matching Article 9:505(1). Furthermore, ss. 2 and 34(1) of the Civil Liability Act 1961 allow the court to reduce the damages by reason of the defendant's contributory negligence, thereby matching Article 9:504.

(b) Contributory negligence and "duty" to mitigate loss treated alike

Several of the Civil Law systems treat the aggrieved party's contributory negligence and his "duty" to mitigate his loss on an equal footing. Contributory negligence and failure to mitigate [page 447] may lead the court to reduce or to disallow the claim for damages. This is the position in GERMANY, see BGB 254(1) dealing with contributory negligence and 254(2) with the failure to mitigate the loss. The ITALIAN CC has similar provisions in art. 1227(1) treating contributory negligence and in art. 1227(2) dealing with avoidance of loss, see Gorla, which in recent decisions has been extended to cover mitigation of loss: see e.g. Cass. 3 March 1983, no. 1594 in Giust. civ., 1984 I c. 3156. See also AUSTRIAN ABGB 1304 and GREEK CC art. 300, covering both contribution to the damage and mitigation of damage, and DUTCH BW art. 6:101; Asser-Hartkamp, Verbintenissenrecht nos. 448 ff., 453. Contributory negligence is treated in the PORTUGUESE CC art. 570 and the "duty" to mitigate may be imposed upon the aggrieved party by way of an analogy of art. 570, or under the rule of abuse of right. In BELGIAN law mitigation is treated as a sub-species of contributory negligence, Cass. 14 May 1992; Ronse no. 460 ff.; Kruithof, R.C.J.B 1989, 12 ff. It is mentioned as a separate duty only in Insurance Contracts Act of 25 June 1992, art.20. SPANISH law seems similar: there is no express provision in the CC on the topic and doctrine seems to consider mitigation as a sub-species of contributory negligence or mora creditoris, Diez-Picazo 733 ff. In FINLAND Sale of Goods Act 70 provides an express duty to mitigate the loss. This is seen as connected to the general principle of contributory negligence, Sevón, Wilhelmsson & Koskelo 87.

2. Expenses incurred (Article 9:505)

Like Article 9:505(2), the legal systems will allow the aggrieved party to recover expenses reasonably incurred in attempts to avoid or mitigate the loss. Expenses are to be reimbursed even if they increased the total loss, provided they were reasonable. This is the law in AUSTRIA, see e.g. Ehrenzweig (-Mayrhofer), 309; BELGIUM, see esp. Insurance Contracts Act of 25 June 1992, art. 52; DENMARK, see Nørager-Nielsen 410; ITALY, Cass. 28 April 1988 no. 3209, Archivio civile 1988, 1054, Cian & Trabucchi art. 1227, 964; GERMANY, BGH 22 Jan. 1959, NJW 1959, 933, 934; ENGLAND, McGregor, Damages 333-334; the NETHERLANDS, BW 6:96(2)(a); SWEDEN, see Ramberg, Köplagen 649 ff. In GREECE the rule is based upon the rule on adequate causation in CC art. 300, or on the "negotiorum gestio" rule in CC art. 736, and in PORTUGAL on the rule in CC 566(2) on full compensation, see notes to Article 9:502, above. The right to recover expenses incurred is implicit in CISG art. 77, see also art. 74.

See generally Treitel, Remedies, 145 ff. [page 448]

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