Rome Convention

The Rome Convention, established in 1980, was a significant step in harmonizing choice-of-law rules within the European Union. It aimed to determine which country's law would apply to contractual obligations in cases with cross-border elements. The convention's core principle was to apply the law of the party rendering the "characteristic performance," such as the seller's law for goods contracts.12

This convention laid the groundwork for later EU legislation, like the Rome I Regulation, which further refined these rules for various contract types while retaining the underlying policy of applying the most closely connected law when specific rules didn't apply. The Rome Convention was a precursor to the broader European Economic Community (EEC), established by the Treaty of Rome in 1957, which eventually evolved into the European Union.13