7. Conclusions By next year, the world as such will have the possibility to criticize the attempts of the Study Group on a European Civil Code and particularly the Utrecht working team on sales law Ho f private individuals, and scholars in particular, taking it upon themselves to act as legislators. They demand an internationally acting institution at the very least. The recent developments on the European market have shown that there is also a place for an academic approach In February 2003, the Commission launched the so-called 'Action Plan on a more coherent European contract law, which is yet another important step towards the harmonization of European Private Law In fact, the research undertaken by the Working Team on Sales Law is closely interconnected with the objectives set out in th Action Plan. Accordingly, oneof the main issues is to improve the quality of the EC acquis comwmnmitaire in the area of contract law. In doing so, a common frame of reference should help to establish European concepts, principles, definitions, and terminology. This compilation, called the common frame of reference in the Commission's terminology, may latereven lead to an optional instrument at the European level. The work elaborated by the SGECC is already such an optional instrument, but at the same time the work undertaken also provides a common frame ofreference for European Sales Law, as it provides references to national legal systems and jurisdic tons next to the actual black-letterrules, Furthermore, the Principles of European Sales Lawhave defined common concepts and terminology, It is to be acquis communitaire. Ideally, such a set ofrules should constitute a compromise between the diverging interests of consumers and commercial parties, which could modemize European sales law by bringing it into line with the economic challenges of the 2lst century Let us see whether the contracting parties will use their free choice to have their contracts governed by the European Principles The Sales Team is eagerly awaiting the outcome of the discussions and the process of consultation concerning their sales draft. Practice and dogmatic critics will demonstrate whether the integrated approach ofdealing with commercial and consumersales together will be the future European choice See Viola Heutger, Ein koharenteres europaisches Vertragsrecht, Jusletter, 17 February 2003 nc/2003/om 2003006%en( Lndf. This Action Plan was the result of a process of consultation and discussion about the way in which problems resulting from divergences between nationalcontract laws in the eu should be dealt with at the European level. This initiative dates back to July 2001, when the Commission launched its Communication on European Contract lay5 7. Conclusions By next year, the world as such will have the possibility to criticize the attempts of the Study Group on a European Civil Code and particularly the Utrecht working team on sales law. However, critics have often voiced their concern about the legitimacy of private individuals, and scholars in particular, taking it upon themselves to act as legislators. They demand an internationally acting institution at the very least. The recent developments on the European market have shown that there is also a place for an academic approach. In February 2003, the Commission launched the so-called ‘Action Plan on a more coherent European contract law’, which is yet another important step towards the harmonization of European Private Law. In fact, the research undertaken by the Working Team on Sales Law is closely interconnected with the objectives set out in th is Action Plan. Accordingly, one of the main issues is to improve the quality of the EC acquis communitaire in the area of contract law. In doing so, a common frame of reference should help to establish European concepts, principles, definitions, and terminology. This compilation, called the common frame of reference in the Commission’s terminology, may later even lead to an optional instrument at the European level. The work elaborated by the SGECC is already such an optional instrument, but at the same time th e work undertaken also provides a common frame of reference for European Sales Law, as it provides references to national legal systems and jurisdictions next to the actual black-letter rules. Furthermore, the Principles of European Sales Law have defined common concepts and terminology. It is to be hoped that they will meet the expectations of the Commission and can thus contribute to the ongoing process of further developing the acquis communitaire. Ideally, such a set of rules should constitute a compromise between the diverging interests of consumers and commercial parties, which could modernize European sales law by bringing it into line with the economic challenges of the 21st century. Let us see whether the contracting parties will use their free choice to have their contracts governed by the European Principles. The Sales Team is eagerly awaiting the outcome of the discussions and the process of consultation concerning their sales draft. Practice and dogmatic critics will demonstrate whether the integrated approach of dealing with commercial and consumer sales together will be the future European choice. 11 See Viola Heutger, Ein kohärenteres europäisches Vertragsrecht, Jusletter, 17 February 2003, <http://www.jusletter.ch>. 12 http://europa.eu.int/eur-lex/en/com/cnc/2003/com2003_0068en01.pdf. This Action Plan was the result of a process of consultation and discussion about the way in which problems resulting from divergences between national contract laws in the EU should be dealt with at the European level. This initiative d ates back to July 2001, when the Commission launched its Communication on European Contract law