Contractual and non-contractual obligations
Next to the 'Brussels I' regulation on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters, the EU has introduced two other regulations. In doing so, the EU has established a set of binding rules of private international law for contractual and non-contractual obligations in civil and commercial matters.
Two regulations for contractual and non-contractual obligations
The EU has introduced two different regulations:
- 'Rome I': EU regulation on the law applicable to contractual obligations. It replaces the Rome Convention, turning it into an EU instrument and, at the same time, modernises it;
- 'Rome II': EU regulation on the law applicable to non-contractual obligations. It covers civil and commercial matters with certain exceptions, notably family relationships and the liability of the state. This regulation does not harmonise the substantive law of the EU countries. It has been applicable in all EU countries - except Denmark - since 2009.