발전소 주기기 공급계약의 구조와 준거법에 따른 주요 계약조항상의 쟁점 연구

In the context of global energy transition and carbon neutrality, the importance of gas-fired power plants is being reaffirmed. Consequently, the legal and contractual frameworksurrounding the supply of key power equipment—particularly gas turbines and steam turbines —has become crucial in international power plant projects. Despite the significance of such contracts, there has been little academic research in Korea. This article provides a legal analysis of gas power plant major equipment supply contracts as well as their typical contractual structures—including EPC turnkey schemes and split procurement structures—and the associated risks. Key contractual clauses are analyzed in detail, including liquidated damages for delay and performance shortfalls, performance guarantees, performance tests and deemed acceptance, warranty and defect liability, and termination clauses. The paper then explores how these clauses are interpreted differently depending on which law is selected as the governing law of the contract. Furthermore, the paper considers the potential applicability of the United Nations Convention on Contracts for the International Sale of Goods (CISG) to major equipment supply agreements. This study aims to assist Korean stakeholders—including contractors, developers, and legal practitioners—in understanding the legal and contractual nuances of OEM supply contracts in global power projects, and in enhancing their ability to negotiate and manage such contracts effectively under different governing laws.