In May S, a commodity dealer, contracts to sell a quantity of cocoa to B and to ship this by 1st September. In mid-July S ships the cocoa to B buy upon arrival the cocoa is lawfully rejected buy B as not in accordance with the contract description. S has until 1st September to ship a fresh quantity of cocoa which conforms with the contract. A agrees to build a house for B by 1 March. By 1 March some important items of work remain incomplete.
Most national laws recognise in some form a defaulting party's right to cure a non-performance.
However, except for the U.S. UCC 2.508 on the seller's right to cure, no statutes have expressed the rule in the same general terms as Article 8.104. 2. CISG and ULIS CISG art. 48 and ULIS art. 37 provide a general right for the seller to cure even after the date for delivery, as long as the buyer has not terminated the contract. However the seller cannot cure in cases where this would lead to unreasonable inconvenience or uncertainty of reimbursement for the aggrieved party.