Conformity of goods and transfer of risk in the international sales of goods: analysis under the rules of the CISG, Chinese law, and United Arab Emirates law.

This article analyzes how the conformity of goods affects the transfer of risk in international sales contracts under the Civil Code of China, the United Arab Emirates Civil Transactions Law (UCTL 1985), and the 1980 United Nations Convention on Contracts for the International Sale of Goods (CISG). It highlights that while all three legal frameworks link risk transfer to the delivery of goods, they differ in their requirements for goods' conformity before risk passes to the buyer: the CISG adopts a more flexible approach allowing risk transfer when goods meet generic descriptions, whereas Chinese and UAE laws require stricter conformity to the contract specifications. Additionally, the CISG treats the delivery of relevant documents separately from the delivery of goods for risk transfer purposes, a distinction not fully reflected in UAE law. The article recommends that China and the UAE align their laws more closely with the CISG to harmonize international commercial practices regarding risk transfer and goods conformity.