What law will an EU Member State forum court apply?
On 11 July 2007, the european Parliament and the Council adopted Regulation 864/2007 (Rome II). 1 This Regulation aims to:
- standardize rules on conflicts of law applicable to non-contractual obligations,
- ensure that the courts of all Member States apply the same law in cross-border civil liability disputes, and
- thus facilitate the mutual recognition of legal rulings in the european Union.
Rome II is applicable and binding, since the 11th January 2009 , across all eu member States except Denmark. 2 It is prudent therefore to describe the system in place before Rome II entered into force and the changes brought by Regulation 864/2007.