1. Putting EU Legislation into Context. - 1.1. EU Agreements. - 1.2. Member States’ Agreements. - 1.3. Agreements Concluded by Member States in the Interest of the Union. - 2. A Relationship of Subordination, Interplay and Confrontation. - 2.1. Subordination. - 2.1.1. Grounds for Subordination. - 2.1.1.1. EU Agreements. - 2.1.1.2. Member States’ Agreements. - 2.1.1.3. Agreements Concluded by Member States in the Interest of the Union. - 2.1.2. Variations on the Theme. - 2.1.2.1. Sheer Primacy. - 2.1.2.2. Disconnection Clauses. - 2.1.2.3. Unilaterally Mitigated Primacy. - 2.2. Interplay. - 2.2.1. Convergence. - 2.2.1.1. Convergence by Reference. - 2.2.1.2. Convergence by Imitation. - 2.2.2. Combination. - 2.2.2.1. The Two-Tier Model. - 2.2.2.2. The Assimilation Model. - 2.3. Confrontation. - 3. The Increasingly Important External Dimension of EU Private International Law. - 3.1. The Broad Construction of the External Competence of the European Union by the Court of Justice. - 3.2. The Virtual Global Reach of EU Legislation. - 3.3. External Action and the Management of Brexit. - 4. How European is EU Private International Law?
Franzina, P., The Relationship Between EU Legislation and International Instruments in the Field of Private International Law, in Von Hein, J., Kieninger, E., Rühl, G. (ed.), How European is European Private International Law?, Intersentia, Cambridge 2019: 19- 52 [http://hdl.handle.net/10807/148789]
The Relationship Between EU Legislation and International Instruments in the Field of Private International Law
Franzina, Pietro
2019
Abstract
1. Putting EU Legislation into Context. - 1.1. EU Agreements. - 1.2. Member States’ Agreements. - 1.3. Agreements Concluded by Member States in the Interest of the Union. - 2. A Relationship of Subordination, Interplay and Confrontation. - 2.1. Subordination. - 2.1.1. Grounds for Subordination. - 2.1.1.1. EU Agreements. - 2.1.1.2. Member States’ Agreements. - 2.1.1.3. Agreements Concluded by Member States in the Interest of the Union. - 2.1.2. Variations on the Theme. - 2.1.2.1. Sheer Primacy. - 2.1.2.2. Disconnection Clauses. - 2.1.2.3. Unilaterally Mitigated Primacy. - 2.2. Interplay. - 2.2.1. Convergence. - 2.2.1.1. Convergence by Reference. - 2.2.1.2. Convergence by Imitation. - 2.2.2. Combination. - 2.2.2.1. The Two-Tier Model. - 2.2.2.2. The Assimilation Model. - 2.3. Confrontation. - 3. The Increasingly Important External Dimension of EU Private International Law. - 3.1. The Broad Construction of the External Competence of the European Union by the Court of Justice. - 3.2. The Virtual Global Reach of EU Legislation. - 3.3. External Action and the Management of Brexit. - 4. How European is EU Private International Law?
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