Stefan WRBKA, Kyushu University
Harmonisation of national private law via European Union (hereinafter EU) directives and regulations undeniably leads to increased legal defragmentation at the pan-EU (or: inter-Member State) level, i.e., to a greater amount of alignment of (content-wise) similar legal rules used by different European Member States (hereinafter Member States). Depending on the harmonisation level applied by the respective EU instrument, legal defragmentation can take a stronger (maximum / full harmonisation; hereinafter full harmonisation) or weaker (minimum harmonisation) form.