Assignment Requirements
In this module students consider the EU single market, which is the central objective (shared by all 27 EU members) of the Treaty on European Union (TEU) and the TFEU and its predecessors. In particular, the course has focussed on three of the four freedoms that are central to the treaty: freedom of movement for goods and workers, freedom of establishment and freedom to provide services. (The fourth freedom—movement of capital—is considered in other modules.)
In 1997 an interesting paper was published entitled, ‘The Dilemma of the European Union: Balancing the Power of the Supernational EU Entity Against the Sovereignty of Its Independent Member Nations’ 1
(Reference: BC George and PL Frantz and J Birmele, ‘The Dilemma of the European Union: Balancing the Power of the Supernational EU Entity Against the Sovereignty of Its Independent Member Nations’ (1997) 9 Pace International Law Review 3.).
More than a decade later, it is still possible to view the provisions of the current version of the treaty as this kind of a balancing act:
• On the one hand, aiming at almost total freedom of movement for goods, people, services and capital within the supranational EU entity, and
• On the other hand limiting those freedoms, and thereby strengthening the sovereignty of its independent Member States, through legislated derogations to each of the freedoms and through ECJ jurisprudence (such as the ‘mandatory requirements’) which has had a similar effect.
In your Final Project for this module, you will be submitting a detailed report on ways in which the freedom of movement for goods, people and services (either through temporary provision of services or by long-term establishment as a service provider) is created by the provisions of the TFEU and on restrictions on these freedoms which the provisions of the TFEU still permit Member States to impose.
You should devise and structure your own Final Project Report in order to achieve the aim stated above. However, your Final Project Report must include the following:
• An overview of the rationale behind the establishment of the single market, its evolution and the legislative instruments (including subsidiary legislation) that have been used to promote its aims;
• An analysis of each of the three freedoms studied in terms of the nature and scope of each freedom and the nature and scope of permissible derogations and exceptions;
• A critical overview of the three freedoms, highlighting differences between the scope and nature of each of the freedoms;
• A critical overview of the ‘residual sovereign rights’ of Member States in relation to each of these freedoms (i.e., permitted restrictions on the freedoms), highlighting differences between both the scope and nature of the permissible derogations and exceptions; and
• A final commentary on the current state of the ‘balancing act’ between total freedom of movement for goods, people, services within the supranational EU entity and sovereignty of its independent Member States in relation to permitted derogations and exceptions to these freedoms in order to achieve national aims.
You should study carefully the relevant legislation and case law and read relevant and rigorous secondary sources you need to help you understand and describe relevant points.
This Project requires a detailed research report on your findings in relation to the topic, including an analysis of relevant primary and secondary sources.
For your Individual Project this week, write a proposal explaining the scope of your report, discussing the organisational structure you are proposing for your Project and describing the materials you intend to use as the basis for your research.
Review the relevant legislation, Craig and de Búrca textbook and your Weekly Notes, and look at other materials that have been suggested by those resources.
You should then search for other articles which assist you to meet the goals of this project.
REQUIRED RESOURCES
Textbook
P Craig and G de Búrca, EU Law: Text, Cases, and Materials (5th edn, OUP 2011)
Chapter 19, ‘Free Movement of Goods: Quantitative Restrictions’, discusses the following topics on pages 668-690:
o Defences to discriminatory measures: Article 36
o Defences to indistinctly applicable rules: the mandatory requirements
o Free movement of goods and Cassis: the broader perspective
Online treaties
Consolidated Versions of the Treaty on European Union and the Treaty on the Functioning of the European Union [2010] OJ C83/01
The treaty you will study for this course is the Treaty on the Functioning of the European Union. The Tables of Equivalences can also be found on the Official Journal C83 of 30 March 2010.
Review Articles 34-37 TFEU.
SUPPLEMENTAL RESOURCES
Online article (to be found in the University of Liverpool Online Library)
LW Gormley, ‘Free Movement of Goods and Their Use—What Is the Use of It?’ (2011) 33 Fordham International Law Journal 1589
Useful online resources
Commission, ‘Free Movement of Goods—Guide to the Application of Treaty Provisions Governing Free Movement of Goods (Articles 34-36 TFEU)’ (2009) SEC 673 final
EU Law Blog
EU cases are accessible at http://eur-lex.europa.eu//RECH_celex.do using the relevant CELEX number.
Important:
– Reference Style: OSCOLA Style.
– References should be a peer reviewed academic articles.
– No Books accept the Text Book.
WEEKLY NOTES
Non-fiscal barriers to the free movement of goods: derogations and mandatory requirements
This week introduces you to the justifications available in respect of national measures creating prima facie barriers to the free movement of goods, examining the express derogations and mandatory requirements.
Central ideas
Last week you focused on Articles 34 TFEU (28 TEC) on imports and 35 TFEU (29 TEC) on exports.
You learned that Article 36 TFEU (ex Article 30 TEC) provides an exhaustive list of exceptions to the prohibitions in Articles 34 (28 TEC) and 35 (29 TEC) such that a State is allowed to place restrictions on the movement of goods through its borders (i.e,. by way of imports, exports, or goods in transit) so long as the measure is not a means of arbitrary discrimination or a disguised restriction on trade between Member States.
You also learned that these are not the same thing as the ‘mandatory requirements’ which must be satisfied to justify a State trade rule which is found to be ‘non-discriminatory’ but ‘indirectly applicable’ and therefore otherwise incompatible with Article 34 TFEU (ex 28 TEC).
This week you will examine the public interest grounds, express derogations (Article 36) and the mandatory requirements (Cassis) in greater detail.
Express derogations [Article 36 TFEU (ex 30 TEC)]
Article 36 (ex Article 30 TEC)
The provisions of Articles 34 and 35 shall not preclude prohibitions or restrictions on imports, exports or goods in transit justified on grounds of public morality, public policy or public security; the protection of health and life of humans, animals or plants; the protection of national treasures possessing artistic, historic or archaeological value; or the protection of industrial and commercial property. Such prohibitions or restrictions shall not, however, constitute a means of arbitrary discrimination or a disguised restriction on trade between Member States. [Bold added.]
If State rules related to products are found to be discriminatory under Article 34 TFEU (28 TEC) on imports or Article 35 TFEU (29 TEC) on exports, the rule can be saved through invoking Article 36 TFEU (30 TEC).
The ECJ has construed Article 36 TFEU (30 TEC) strictly. Rules found to be discriminatory will be scrutinised to ensure that:
– The defence pleaded is warranted on the facts of the case, and
– The rule passes a test of proportionality (the rule of reason): the discriminatory measure must be the least restrictive possible to attain the end in view.
The burden of proof under Article 36 TFEU (30 TEC) rests on the Member State, but when a Member State provides convincing justifications, it is then for the Commission to show that the measures taken are not appropriate in that particular case.
The Commission points out (at section 6.1)1 that:
Article 30 EC cannot be relied on to justify deviations from harmonised EU legislation [165].2 On the other hand, where there is no Community harmonisation, it is up to Member States to define their own levels of protection. In the case of partial harmonisation, the harmonising legislation itself quite often explicitly authorises Member States to maintain or adopt stricter measures provided they are compatible with the Treaty. In such cases the Court will have to evaluate the provisions in question under Article 30 EC.
In a case related to a ban on the import of pornography,3 the Court stated that the function of the second sentence of Article 36 [30 TEC] ‘is to prevent restrictions on trade based on the grounds mentioned in the first sentence from being diverted from their proper purpose and used in such a way as to create discrimination in respect of goods originating in other Member States or indirectly to protect certain national products’,i.e., to adopt protectionist measures.
The categories of defence permissible under this Article all relate to noneconomic interests4 and are exhaustive, although the way the categories have been defined has tended to evolve. Shuibhne5 discusses the implications of the closed list approach, noting that:
Maintaining a closed list of grounds for justification is, essentially, to maintain a value-judgment; in the cultural context, for example, the inclusion of national treasures but not other cultural possibilities, renders the protection of a painting or sculpture more valuable than protection of a language or traditional method of food production—not to mention, more important than consumer protection, the environment, and so on. In this vein, and given that a closed-list provision cannot reflect changing priorities (be they moral, political or social), should there be instead a generic ‘objective justification’ test, irrespective of the type of breach of Article 28 [TEC] involved and rendering Article 30 [TEC] effectively redundant? [p. 423]
Public interest defences: public morality
Member States may decide to ban a product on morality grounds. While each Member State may set standards by which goods comply with national provisions concerning morality, that discretion must be exercised in conformity with the obligations arising under Community law. (For example, any prohibition on imports of products where their marketing is restricted, but not prohibited, will be discriminatory and in breach of the ‘free movement of goods’ provisions.) Cases where the court has directly admitted the public morality justification have mostly concerned obscene, indecent articles, while in other cases where public morality was also invoked, other interlinked justifications were found (public interest in gambling cases6 and protection of minors regarding age-limit labelling of videos and DVDs7).
As Craig and de Búrca point out:
– In Henn and Darby the ECJ was willing to accept that a UK ban on the import of pornography could be justified under what is now Article 36 [30 TEC], notwithstanding the fact that domestic law did not ban absolutely the possession of such material. The ECJ concluded that the overall purpose of UK law was to restrain the manufacture and marketing of pornography and that there was no lawful trade in such goods within the UK.
– In Conegate, in relation to the importation to the UK of blow-up ‘love dolls’, the ECJ was not willing to accept that a UK ban on their import was justified under the same Article.
The distinction between Conegate and Henn and Darby lies in the ECJ’s evaluation of whether the banned imported goods were defences to discriminatory measures being treated more harshly than similar domestic goods. In Henn and Darby the ECJ was willing to find that UK law restrained the manufacture and marketing of pornography sufficiently to enable it to conclude that there was no lawful trade in such goods within the UK. In Conegate the ECJ reached the opposite conclusion.
Public interest defences: public policy
Public policy is interpreted very strictly by the Court of Justice and has rarely succeeded as grounds for a derogation under Article 36 [30 TEC]. Where an alternative Article 36 [30 TEC] derogation would apply, the ECJ tends to use the alternative or public policy justification in conjunction with other possible justifications.8 The public policy justification alone was accepted in one exceptional case, in which a Member State was restricting the import and export of gold-collectors’ coins. The court held that it was justified on grounds of public policy because it stemmed from the need to protect the right to mint coinage, which is traditionally regarded as involving the fundamental interests of the state.9
Craig and de Búrca point out that
The ECJ has reasoned that since Article 36 [30 TEC] derogates from a fundamental rule of the Treaty enshrined in Article 34 [28 TEC], it must be interpreted strictly, and cannot be extended to objectives not expressly mentioned therein. A public policy justification must, therefore, be made in its own terms, and cannot be used as a means to advance what amounts to a separate ground for defence.
Public interest defences: public security
Public security justification has been advanced in relation to the EU energy market, but the decision should be limited to the precise facts and is not of wide applicability. In Campus Oil10 (see Craig and de Búrca) Ireland ordered petrol importers to purchase up to 35% of their petrol requirements from a national petrol company at prices fixed by the government. The ECJ held that the measure was clearly protectionist and constituted a breach of Article 34 [28 TEC]. However, it was held to be justified on the grounds of public security, i.e., for maintaining a viable oil refinery to meet supply in times of crisis.
[I]n the light of the seriousness of the consequences that an interruption in supplies of petroleum products may have for a country’s existence, the aim of ensuring a minimum supply of petroleum products at all times is to be regarded as transcending purely economic considerations and thus as capable of constituting an objective covered by the concept of public security. [Para 35, bold added.]
Justification has also been accepted on the grounds of public security in cases involving trade in strategically sensitive goods (memory circuits)11 and dual-use goods (i.e., goods capable of being used for both civil and military purposes),12 as ‘…the risk of serious disturbance in foreign relations or to peaceful coexistence of nations may affect the security of a Member State (Liefer).’ In these cases the court stated that the scope of Article 36 [30 TEC] covers both internal security (e.g., crime detection and prevention and regulation of traffic) and external security.
The protection of health and life of humans, animals or plants
States have often attempted to defend measures which breach Article 34 [28TEC] on this ground—the protection of health and life of humans, animals and plants is the most popular justification under which Member States attempt to justify obstacles to the free movement of goods. The ECJ will focus on:
– Whether the protection of public health is the real purpose behind the Member States’ action, or whether it was designed to protect domestic producers;
– Whether the measures at issue are proportionate; i.e., restricted to what is necessary to attain the legitimate aim of protecting public health;
– Whether measures at issue are well-founded, providing relevant evidence, data (technical, scientific, statistical, nutritional) and all other relevant information.
–
Craig and de Búrca discuss these issues and the issue of different sets of checks in different Member States and cases involving subsequent dual sets of controls related to this ground.
Shuibhne notes (at p 421) that full-out environmental protection is not included in the Article 36 [30 TEC] closed list of justifications, but that
… something of a contemporary reading to ‘protection of the health and life of humans, animals and plants’ was given in Bluhme13, including within its scope the ‘maintenance of biodiversity’. The measure at issue in Bluhme was directly discriminatory, but an imaginative reading of Article 30 was preferred here over the bolder approach in Walloon Waste and Decker.
The protection of national treasures possessing artistic, historic or archaeological value
A Member State’s duty to protect its national treasures and patrimony may justify measures which create obstacles to imports or exports. What is a ‘national treasure’ is open to interpretation, and each Member State must determine which items fall within this category. However, it is clear that such items must possess real ‘artistic, historic or archaeological value’.
Directive 93/7/EEC14, which regulates the return of cultural objects unlawfully removed from the territory of a Member State, may be an interpretative aid where doubt exists. The Directive mentions that national treasures could include the following:
– Items listed in the inventories of museums or libraries’ conservation collections;
– Pictures, paintings, sculptures;
– Books;
– Means of transport; and
– Archives.
Member States impose different restrictions on the export of antiques and other cultural artefacts, and those restrictions—as well as related administrative procedures, such as the completion of declaration forms and the provision of supporting documents—are generally considered to be justified under Article 36 [30 TEC]. Attempts by Member States to discourage the export of art treasures by the imposition of a tax, however, have not been deemed justifiable since such action constitutes a measure equivalent to a customs tax (Article 30 [25 TEC] in regard to which Article 36 [30 TEC] cannot be invoked as a justification).15
As well as discussing (p 420) the limited view of ‘national treasures’ that has been taken by the courts (‘the Court has, for example, stated expressly that the protection of ‘creativity and cultural diversity’ in the realm of publishing is not protected by [Article 36 (30 TEC)]’), Shuibhne has also directly criticised the value judgements inherent in this Article such that some cultural artefacts (e.g., paintings) are seen as national treasures while others are ignored (e.g., indigenous languages). See the discussion above.
The protection of industrial and commercial property
Key types of industrial and commercial property are patents, trademarks and copyright. Two principles can be deduced from the case law on the compatibility with Articles 34-36 TFEU (28-30 TEC) of the exercise of industrial property rights:
– The treaty does not affect the existence of industrial property rights granted pursuant to the legislation of the Member States. Accordingly, national legislation on the acquisition, transfer and extinction of such rights is lawful. This principle does not apply, however, where there is an element of discrimination in the national rules.16
– According to the principle of exhaustion of rights: an industrial property right is exhausted when a product has been lawfully distributed in the market of a Member State by the owner of the right or with his consent. Thereafter the owner of the right may not oppose the importation of the product into any Member State where it was first marketed. This principle does not preclude the holders of performing or lending rights from recovering royalties for each performance or rental.
Both of these aspects are now mainly covered by harmonised legislation, such as Directive 89/104/EC on trademarks. It should be noted that, apart from patents, trademarks, copyright and design rights, geographical denominations also constitute industrial and commercial property for the purposes of Article 36 [30 TEC].
Other grounds for validating discriminatory measures?
The list of defences for discriminatory rules caught by Article 34 [28 TEC] is contained in Article 36 [30 TEC].
Where a national rule is not discriminatory, the ECJ has extended defences to Article 34 [28 TEC] to ‘indistinctly applicable rules’ and created defences (the mandatory requirements) that overlap with, but are not identical to, those found in Article 36 [30 TEC]. Craig and de Búrca explore these, particularly as they relate to the approach to Wallonia17—the Belgian Waste Case discussed earlier. You should read this section of the textbook in conjunction with Shuibhne’s analysis of the same issues.
Mandatory requirements [Cassis]
In Cassis de Dijon the ECJ laid down the concept of mandatory requirements as a non-exhaustive list of protected interests in the framework of Article 34 [28 TEC].
Mandatory requirements, as developed by the ECJ in the Cassis case, could be invoked only to justify the ‘indistinctly applicable’ rules. Therefore discriminatory measures could (at least theoretically) not be saved by reference to the mandatory requirements, but would need to be justified by one of the express derogations in Article 36 [30 TEC]. The ECJ has found ways to overcome this separation without renouncing its earlier practice:
In Wallonia18, the Belgian Waste Case, the ECJ decided that the measure which could be seen as discriminatory was not discriminatory because of the special nature of the subject matter of the case and then allowed the environmental justification.
In Commission v Austria19 the ECJ chose to regard a measure as indistinctly applicable instead of indirectly discriminatory.
It has been argued that such separation is artificial (e.g., see Shuibhne) and it would appear that the ECJ is moving towards simplification and treating mandatory requirements in the same way as Article 36 [30 TEC] justifications.
The list of mandatory requirements specified in Cassis (unlike the list in Article 36 [30 TEC]) is not exhaustive, and newer categories have been added since Cassis by ECJ jurisprudence. Newer categories include the following:
– Environmental protection
– Pluralism of the press
– Fostering of certain forms of art
– Protection of fundamental rights
– Cultural aims
– Financial balance of the social security system
– Road safety
– Fight against crime
– Protection of animal welfare
Some of these are discussed in Craig and de Búrca, while discussion on others can be found in the Commission Staff Working Document20 on this topic.
The mandatory requirements: consumer protection
Certain obstacles to trade between Member States resulting from disparities between provisions of national law have been justified as being necessary in order to satisfy overriding requirements relating to consumer protection or fair trading, and the ECJ has found them acceptable in so far as such provisions are applicable to domestic and imported products without distinction (i.e., they are non-discriminatory but indistinctly applicable rules).
To be permissible, such provisions must be proportionate to the objective pursued and that objective must not be capable of being achieved by measures which are less restrictive of intra-Community trade (as stated in Cassis itself). The ECJ guiding line has been that, where imported products are similar to domestic ones, adequate labelling, which may be required under national legislation, will be sufficient to provide the consumer with the necessary information on the nature of the product. No justification on the grounds of consumer protection is admissible for unnecessarily restrictive measures.
The mandatory requirements: public health
Public health finds itself both on the list of express derogations (i.e., available as justification under Article 36 [30 TEC]) and the list of mandatory requirements (via Cassis) which make justifications for ‘indistinctly applicable rules’ available under Article 34 [28 TEC]. Where a public health justification is pleaded and where it is unclear whether the impugned rule is discriminatory or indistinctly applicable, the ECJ has not always found it necessary to clearly state under which category it has permitted the justification. Craig and de Búrca discuss the German Beer case21 in this light.
The mandatory requirements: environmental protection
Although protection of the environment is not one of the express derogations mentioned in Article 36 [30 TEC], nor was it mentioned in Cassis, it has been recognised by the Court as constituting an overriding mandatory requirement. In a case22 relating to a requirement for reuseable containers for beer and soft drinks, the ECJ noted that the protection of the environment is ‘one of the Community’s essential objectives’, which may as such justify certain limitations of the principle of the free movement of goods. That view is moreover confirmed by the Single European Act.
On grounds of protection of the environment, the Court has justified a variety of national measures, including the following:
– Prohibiting the importation of waste from other Member States;23
– A deposit-and-return system for containers;24
– An outright ban on certain chemical substances but which also provides for exceptions when no safer replacement is available;25
– Obliging electricity suppliers to buy all electricity produced from renewable energy sources from within a limited supply area.26
New reading of the free movement of goods
Gormley27 opines that ‘The issue of whether or not to assimilate the case-law-based justifications is one on which the overwhelming majority of authors are agreed: this is not something which should happen. There has been no pressure to add to the list of justifications contained in article 36 TFEU (article 30 EC). The initial confusion caused by the inclusion of the protection of public health in the examples of ‘mandatory requirements’ (case-law-based justifications) in Cassis de Dijon has now been cleared up: the protection of public health falls under the protection of health and life of humans in article 36 TFEU (article 30 EC). However, it can be argued that some safety matters which the ECJ now seems to treat as separate case-law-based justifications, i.e., road safety, shipping safety, and product safety, could equally well be brought under the protection of the health and life of humans, and thus, in relation to goods, under article 36 TFEU (article 30 EC). The merit of a separate approach is that a clear distinction is drawn between more classic health and life issues and specific safety issues. This view only strengthens the argument that the case-law-based justifications and the treaty-based justifications, although they have certain characteristics in common, are and should remain distinct. As is well known, the ECJ has consistently refused to add to the list of treaty-based justifications.’
In summary
This week’s work has been designed to introduce you to the justifications available in respect of national measures creating prima facie barriers to the free movement of goods, examining the express derogations and mandatory requirements.
Next week you will go on to consider examine the free movement of workers in the single market, how this was legally possible and the restrictions over such free movement.
Footnotes
1‘Free Movement of Goods—Guide to the Application of Treaty Provisions Governing Free Movement of Goods (Articles 34-36 TFEU)’ (2009) SEC 673 final
2C-473/98 Kemikalieinspektionen v Toolex Alpha AB Case [2000] ECR I-05681 CELEX 61998J0473.
‘[Para 25] It should be observed at the outset that, whilst Article 36 of the Treaty allows the maintenance of national restrictions on the free movement of goods, justified on grounds which constitute fundamental requirements recognised by Community law, recourse to Article 36 is not possible where Community directives provide for harmonisation of the measures necessary to achieve the specific objective which would be furthered by reliance upon that provision.’
3Case 34/79 Regina v Maurice Donald Henn and John Frederick Ernest Darby [1979] ECR 3795 CELEX 61979J0034.
4 Case C-120/95 Nicolas Decker v Caisse de Maladie des Employés Privés [1995] ECR I-01831 CELEX 61995J0120.
‘[Para 39] It must be recalled that aims of a purely economic nature cannot justify a barrier to the fundamental principle of the free movement of goods.’
5N Shuibhne, ‘The Free Movement of Goods and Article 28 EC: An Evolving Framework’ (2002) 27 ELRev 408, 423.
6Case C-124/97 Läärä and others [1999] ECR I-06067 CELEX 61997J0124.
7Case C-244/06 Dynamic Medien Vertriebs GmbH v Avides Media AG [2008] ECR I-00505 CELEX 62006J0244.
8Case C-434/04 Ahokainen and Leppik [2006] ECR I-9171 para 28 CELEX 62004J0434. The ECJ stated that legislation:
‘which has as its objective the control of the consumption of alcohol so as to prevent the harmful effects caused to health and society by alcoholic substances, and thus seeks to combat alcohol abuse, reflects health and public policy concerns recognised by Article 36 [30 TEC].’
9Case 7/78 R v Thompson [1978] ECR 2247 CELEX 61978J0007.
10Case 72/83 Campus Oil [1984] ECR 2727 CELEX 61983J0072.
11Case C-367/89 Criminal proceedings against Aimé Richardt and Les Accessoires Scientifiques SNC [1991] ECR I-4621 CELEX 61989J0367.
12Case C-83/94 Leifer [1995] ECR I-3231 CELEX 61994J0083; Case C-70/94 Fritz Werner Industrie-Ausrüstungen GmbH v Federal Republic of Germany [1995] ECR I-3189 CELEX 61994CJ0070.
13Case C-67/97 Criminal Proceedings against Bluhme (the Danish beekeeping case) [1998] ECR I-8033.
14185 Council Directive 93/7/EEC of 15 March 1993 on the return of cultural objects unlawfully removed from the territory of a Member State.
15Case 7/68 Commission v Italy [1968] ECR 423 CELEX 61968J0007.
16Case C-235/89 Commission v Italy [1992] ECR I-777 CELEX 61989J0235.
17Case C-2/90 Commission v Kingdom of Belgium [1992] CELEX 61990J0002.
19Case 320/03 Commission v Austria [2005] ECR 9871 CELEX 62003J0320.
20‘Free Movement of Goods—Guide to the Application of Treaty Provisions Governing Free Movement of Goods (Articles 28–30 EC)’ (2009) SEC 673 final
21Case 178/84 Commission v Federal Republic of Germany [1987] ECR 4607 CELEX 61984J0178.
22Case 302/86 Commission v Kingdom of Denmark [1988] ECR 4607, para 8 CELEX 61986J0302.
23Case C-2/90 Commission v Belgium [1992] ECR I-4431CELEX 61990J0002.
24Case 302/86 Commission v Denmark [1988] ECR 4607 CELEX 61986J0302.
25Case C-473/98 Toolex Alpha [2000] ECR I-5681 CELEX 61998J0473.
26Case C-379/98 PreussenElektra v Schleswag [2001] ECR I-2099 CELEX 61998J0379.
27LW Gormley, ‘Free Movement of Goods and Their Use—What Is the Use of It?’ (2011) 33 Fordham International Law Journal 1589.
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