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I chose to look at four different legal systems; The Netherlands, Germany, France and England. I will look at the rules for retention of title, transfer of ownership, a bona fide purchaser and retention of title, specificatio and retention of title, accessio and retention of title and the legal systems of the Member States. The Bona fide purchaser is dealt with in another section then specificatio and accessio, because acquiring ownership in this way is a form of derivative acquisition of ownership and specificatio and accessio are two forms of original acquisition of ownership. These terms will be discussed in the sections dealing with these subjects. After this I will answer how 3 different cases would be solved according to the different legal systems. These cases will be about; a bona fide purchaser, specificatio and accessio . After answering these cases I will compare the outcomes and on the basis of the outcomes I will determine whether harmonization of retention of title in the European Union is needed. Then I will look at the legal regimes of the four Member States. After this I will determine whether harmonization of retention of title is feasible. My two main questions will be: 1. Is harmonization of retention of title in the European Union needed? 2. Is harmonization of retention of title feasible in the European Union?

Is harmonization of retention of title necessary and feasible?