Substantive Provisions

Scope

Rome II will apply, in civil and commercial matters, to most non-contractual obligations where there is a conflict of laws. As a result of a late amendment sought by the European Parliament, the recitals of Rome II now make it clear that non-contractual obligations for these purposes include those arising out of strict liability. For product manufacturers and suppliers therefore, Rome II will apply not just to consumer claims brought in tort but also to those brought under the Product Liability Directive.