The control of standard contract terms has become one of the most important yet controversial areas of contract law. By comparing the Directive 93/13/EEC on unfair terms in consumer contracts with the recently adopted US Restatement of Consumer Contracts, this Article sheds light on the relative strengths and weaknesses of the EU and US regulatory approaches to the use of standard terms in consumer contracts. Particular emphasis is placed on the review of dispute resolution clauses. The central thesis of this Article is that the personal scope of the European and US consumer contract control regimes should be broadened to protect small and medium sized enterprises and that their interplay with private international law needs to be clarified.
