Even within these considerably different systems, there is considerable variation as to the meaning of the phrase in their differing jurisdictions. As examples, discussed in greater depth later, although both the UK and the USA have addressed the concept and accept the notion in a general sense, both countries have dealt with it quite distinctly. While the USA has included it in its Uniform Commercial Code, the UK has found it to be a sufficiently onerous obligation so as to make acceptance of the CISG unpalatable.