Since 2003, the Organization of American States ("OAS") has concentrated most of its efforts and focused on the harmonization of international consumer law. It has become the current focal point of the legal harmonization process undertaken by the Inter-American Specialized Conference on Private International Law ("CIDIP"). As its name indicates, the CIDIP is concerned with conflict issues and therefore with private international law rules understood in a broad sense (i.e. choice of law, jurisdiction, judicial cooperation and international arbitration). However, the CIDIP VI, in 2002, has changed this "paradigm" of codification, enlarging the scope of the inter-American unification even more. Thus, the Inter-American Model Law on Secured Transactions deals with both domestic and international relationships, and by consequence most of its provisions are substantive rules. The current state of affairs of the treatment of the subject matter of consumer protection offers a mix of proposals made by Brazil, Canada and the United States ("U.S."), reaffirming the change operated in 2002.
Diego P. Fernandez Arroyo, Current Approaches Towards Harmonization of Consumer Private International Law in the Americas, 27 Penn St. Int'l L. Rev. 693 (2009).