Abstract：The CISG shall be applied independently for international sales of goods in judicial application or arbi-tration. The judicial interpretation of the CLC can learn from that of the CISG; however, the later, in prin-ciple，can’t learn from the former. On one hand，with reference of Article 66 of the Judicial Interpretation ofGPCL issued by the Chinese Supreme People’s Court，the Implication of Act（Article 22 CLC）embracestwo modes of acceptance：one is the Implication of Action displaying to offeror that offeree has accepted therequest；and the other is the Implication of Nonfeasance. Both of the two modes can be qualified as Declara-tion of Will and shall meet the requirement of arrival of notice. What the pattern of arrival of notice by thelatter mode is concerned，an inactive or silent implication by means of nonfeasance can be regarded as aspecial one. On the other hand，the provisions of the CISG pertinent to the modes of acceptance strictly stip-ulate that the notice of conduct shall reach offeror as the notice does not belong as the act ofperformance. Therefore，the acceptance by conduct shall be ruled under Paragraph 3 of Article 18 CISG in-stead of Paragraph 1 of this article so as to mitigate the requirement for arrival of notice.
朱岩, 潘玮璘. 承诺方式制度比较研究
——以我国《合同法》与《联合国国际货物销售合同公约》为例[J]. 法学家, 2014, 0(5): 137-149.
ZHU Yan, PAN Wei-Lin. Comparative Study on Modes of Acceptance：Focusing on Chinese Contract Law and CISG. , 2014, 0(5): 137-149.