在《消费品买卖指令》转化为各成员国国内法后,欧洲买卖法在一些核心概念上尚差异明显,如瑕疵、销售者的追索权以及瑕疵担保责任与普通履行障碍法的关系,这表明为欧洲消费者保障一个统一的买卖瑕疵担保最低标准的目标远未完全实现。此外,欧洲买卖法在教义学上也没有取得一致认同的成果。这些表明通过广泛的自主融合来实现欧洲买卖法统一的希望自始就是不现实的。 After the “Consumer Goods Sale and Purchase Directive” has been transformed into the domestic laws of member states, there are some core concepts of the European Sale and Purchase Law which are quite different, such as flaws, sellers’ recourse and the relationship between the flawed guarantee liability and the ordinary performance obstacle law The goal of guaranteeing a uniform minimum standard of guarantee for sale to European consumers is far from fully realized. In addition, there is no consensus on the doctrine of European sale and purchase law. These indicate that the promise of unifying the European sale and purchase laws through a broad range of autonomous mergers has been unrealistic from the beginning.