The Primacy of the European Union Law and the Collision of the Rome I Regulation with the Vienna Convention on International Sale of Goods

The article deals with some issues of relation between the national and European Union law with the focus on the primacy principle. After the general introduction the specific relation between the Rome I regulation (which is directly applicable in Member States as a source of EU law and which contains choice of law norms) and Vienna convention on international sales of goods (which is self-executing and therefore applicable in the Czech Republic as a source of international law and contains uniform rules) is examined. The problem of the relation of these two legal acts cannot be easily solved by simple reference to precedence of uniform rules over choice of law norms as this could be a question just within one system of law. The solution is different. We have to take into account competences of the EU in the area of international private law as this competence is shared with Member States and is limited solely to the area of choice of law norms.