"Reasonable time" by category of goods

This page sorts case law interpreting and applying the "reasonable time" standard of Art. 39(1) CISG by the category of goods delivered.

1: Meat and meat preparations

Theo Bauwens N.V. v. N. Vriesekoop B.V.
Rechtbank van Koophandel Dendermonde (Commercial Court Dendermonde)
Belgium, 26 May 2011 – A/10/03341, CISG-online 4605

Notice given more than a month after delivery of frozen chicken fillets that were close to their expiration date and after the buyer has already processed the goods not reasonable, because notification in case of perishable products has to be immediate (irrespective of whether they had been frozen or not)

5: Vegetables and fruit

Groente-En Friuthandel Heemskerk B.V. v. Frutas Caminito Sociedad Cooperativa Valenciana
Gerechtshof Arnhem (Court of Appeal Arnhem)
Netherlands, 19 January 2009 – 87379 / HA ZA 07-716, CISG-online 2072

Notice given 12 days after delivery of citrus fruits (lemons and tangerines) not reasonable, because goods were perishable (irrespective whether they had been cooled or not)

72: Machinery specialized for particular industries

Shuttle Packaging Systems, L.L.C. v. Jacob Tsonakis, INA S.A. et al.
U.S. District Court for the Western District of Michigan
USA, 17 December 2001 – 1:01-CV-691, CISG-online 773

Notice given (at the latest) 5.5 months after delivery of production line still within reasonable time, because the machinery was complicated, unique, delivered in instalments and subject to training and on-going repairs; buyer's employees furthermore lacked the expertise to inspect the goods and needed to rely on seller’s engineers even to use the equipment

74: General industrial machinery and equipment, not elsewhere specified, and machine parts, not elsewhere specified

Ecogen Holding B.V. v. Isolcell Italia S.p.A.
Tribunale di Bolzano (District Court Bolzano)
Italy, 27 January 2009, CISG-online 2344

Notice of non-conformity given 4 months after delivery was still made within reasonable time, because the goods concerned (industrial machine) were non-perishable

89: Miscellaneous manufactured articles, not elsewhere specified

Window frames and doors case
Tribunal des Districts de Martigny et St-Maurice (Court of First Instance Martigny et St-Maurice)
Switzerland, 14 July 2015 – C1 13 276, CISG-online 2760

Sale of window frames and doors made of PVC - notice given one year after buyer became aware of defects was in any case made too late