Odi et amo. Japan’s Complex Relationship with the CISG

This paper intends to present to an international audience the complex relationship which both the Japanese academic and professional worlds have with the CISG: from one side, eminent legal scholars from Japan have expressed their appreciation for the CISG as a remarkable piece of international legislation; from the other, contracts for international sales of good entered into by Japanese companies often (one would dare say "systematically") exclude the application of the CISG. There are indeed very few cases of application of the Convention reported by Japanese courts: is this because of the alleged (but unproven) reluctance to bring disputes to litigation ; or because the CISG is applied so skillfully by Japanese parties that formal adversary resolution is not needed; or because contracts for the sale of goods are governed by Japanese domestic law (by way of exclusion of the CISG) or by another foreign legislation (by choice of the parties)?