The recently enacted Consumer Guarantees Directive, when adopted into natio
nal law by member states, will provide Europe with reasonably uniform rules
pertaining to warranties and guarantees in sales by merchants to consumers
. These rules are roughly comparable to those in the United States and the
Vienna Convention for the International Sale of Goods. The authors examine
the differences between the European Union and major U.S. laws. They also s
uggest that the new directive leaves significant room for variation within
Europe and is inconsistent with other European directives.