Models of Consumer Protection regarding the Law Applicable to International Consumer Contracts and Suggestions for Brazilian Law
DOI:
https://doi.org/10.14393/RFADIR-v47n1a2019-48686Keywords:
Consumer Law, Private International Law, International Consumer Contracts, Applicable lawAbstract
This article addresses three models identified in determining the law applicable to international consumer contracts. Through a methodology of comparative legislation, the European (also adopted in Quebec, Argentina, Japan and the Dominican Republic), the Brazilian and the Chinese (which is similar to the Panamanian) models are presented. It is intended, after the review of these models, verify if Brazilian existing model is the best one, and, if it is not, make a suggestion to improve the protection of the vulnerable part in these situations.