A comparison of model laws as a starting point for the development of an enforceable international consumer protection regime

This article is concerned primarily with an examination and comparison of select aspects of the model international consumer protection laws proposed by the United Nations (UN), the European Union (EU), and the Organisation for Economic Co-operation and Development (OECD), using the Trade Practices Act 1974 (Australia) as a basis for examination and comparison. As a secondary consideration, it also broadly examines the content of, and differences between, the model laws. The motive for this article is that any future enforceable international consumer protection regime (possibly in the form of an international treaty or convention) would need to take into account the UN, EU and OECD guidelines. A cross-comparison of those model laws, and a comparison of them with the consumer protection provisions of a well established national consumer protection law, should provide a useful starting point for the development of such a regime. The 'select aspects' of the model laws in question are the various provisions of those laws which could relate to situations involving the wrong delivery or non-delivery of goods.