Die Umsetzung der Verbraucherrechterichtlinie in Frankreich und Deutschland

The aim of this dissertation is to examine the extent to which the first fully harmonizing directive, the Consumer Rights Directive, actually lived up to its claim of full harmonization. As part of this study, a comprehensive analysis of the legal situation in France and Germany is carried out. It takes into account the provisions that serve to transpose the Directive and those that already existed, as well as the case law that has emerged since transposition. In addition, the literature available in both countries is also included. In this way, a comprehensive comparison of the two legal systems is made possible. In the final analysis, it is determined in particular whether there could be opportunities for improvement in the future.