The Community authorities follow the attribution of jurisdiction in Article 81 of the TFEU (formerly Article 65 TA):

Rome I, Rome II and Rome III Regulations

Rome II Regulation

Rome I Regulation

Rome III Regulation

Unification of rules of conflict

The same legal system will apply regardless of the Court of the Member State before which the claim is filed = predictability

1/4

Rome I, Rome II and Rome III Regulations

General solutions

2/4

Rome IRome I

A)

Freedom of choice

Solutions for types of contracts

Legal system of the state where party required to effect the characteristic performance has its habitual residence Escape clause

Special solutionsB)

Carriage

Consumers

Employment

Insurance

Rome I, Rome II and Rome III Regulations

General solutions

3/4

Rome IIRome II

A)

Freedom of choice (with exceptions)

Law of common habitual residence

Closer connections

Locus danmi

Special solutionsB)

Product liability

Unfair competition / Acts restricting free competition

Environmental harm

Intellectual property

Collective action

* Exclusion of damage to privacy, honour, etc. from the material scope of liability

Rome I, Rome II and Rome III Regulations

Solutions

4/4

Rome IIIRome III

A)

Freedom of choice

In the absence of a choice, the legal systems referred to in Article 8 will be applied.

Negotiation by enhanced cooperation

Exclusion of annulment from the material scope