"Reasonable time" by period

This page sorts case law interpreting and applying the "reasonable time" standard of Art. 39(1) CISG by the time period that the respective Court found to be reasonable or unreasonable.

2.5 months:

Four Directions Ltd. v. [...]
Rechtbank Amsterdam (District Court Amsterdam)
Netherlands, 31 January 2018 – C/13/613066 / HA ZA 16-774, CISG-online 3731

Delivery of (unspecified) goods at the beginning of August 2013, first notice of non-conformity given at end of November 2013 - unreasonable

12 days:

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)

5.5 months:

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

Delivery of production line on 15 January 2001, notice given (at the latest) on 6 July 2001 - 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

2 weeks:

PVC foil case
Oberlandesgericht Naumburg (Oberlandesgericht des Landes Sachsen-Anhalt) (Court of Appeal Naumburg)
Germany, 24 April 2019 – 12 U 152/18, CISG-online 4506

as a "rule of thumb", a notice period of 2 weeks can be considered reasonable in case of non-perishable goods that are not affected by strong price fluctuations

4 months:

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

1 year:

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

Notice given one year after the defects of window frames and doors made of PVC became known to the buyer was clearly not made within reasonable time

1 month:

Grinding set for hygienic tissues producing machine case
Bundesgerichtshof (German Supreme Court)
Germany, 03 November 1999 – VIII ZR 287/98, CISG-online 475

[Leitentscheidung zum "noble month" - noch ausführen]

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

Generally, a period of one month is reasonable (sale of window frames and doors made of PVC)

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)