- Law of the European Union
The Law of the European Union is the unique legal system which operates alongside the laws of Member States of the
European Union(EU). EU lawhas direct effect within the legal systems of its Member States, and overrides national law in many areas, especially in terms of economic and social policy. The EU is not a federal government, nor is it an intergovernmental organization. It constitutes a new legal order in international law [ [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:61962J0026:EN:NOT Case 26/62 Van Gend en Loos v. Nederlanse Administratie der Belastingen] ] for the mutual social and economic benefit of the Member States. It is sometimes classified as supranational law.
European Union law has evolved gradually since it was established, when the Treaty of Paris was signed in 1951, it established the
European Coal and Steel Community, and comprised just six Member States. Five years later the European Economic Community was founded by the same six Member States. Currently there are around 500 million EU citizens in 27 Member States subject to EU law, making it one of the most encompassing modern legal systems in the world.
EU law has what is known as a three pillar structure. The first, oldest and most important 'pillar' deals with law concerning economic and social rights and how European institutions are set up. This is found in the Treaty of the European Communities, signed in Rome 1957 and subsequently amended by other Treaties concluded between the Member States. The second and third pillars were established under the Treaty of the European Union, signed in Maastricht 1992. The second pillar concerns the European Union
Common Foreign and Security Policy(CFSP). The third pillar concerns Police and Judicial Co-operation in Criminal Matters(formerly 'Justice and Home Affairs'). Technically speaking, "EC law" denotes anything to do with the first pillar and "EU law" denotes the law regarding all three pillars.
History and development
Initially, the Consultation procedure was the primary interplay of the institutions. Under it,Council must wait (unless it initiates an emergency procedure) for the EP’s opinion before adopting the legislation. This possibility for delay was in the early days the EP’s only weapon.
The role of the European Parliament in this institutional triangle has been gradually strengthened.Major landmarks in this gradual strengthening process have been
* the transferral of budget responsibilities during the early 70s,
* the first direct elections in 1979,
* the introduction of the
Cooperation procedurewith the Single European Act(1986/87) and
* the codecision procedure with the Maastricht Treaty (1993/93), whose scope was expanded considerably by the
Treaty of Amsterdam(1997/99) and the Treaty of Nice(2001).
The development of law of the European Community has been largely moulded by the European Court of Justice (ECJ). In the landmark case of Van Gend en Loos in 1963, the ECJ ruled that the European Community, through the will of Member States expressed in the Treaty of Rome, "constitutes a new legal order of international law for the benefit of which the states have limited their sovereign rights albeit within limited fields."
The distinction between European Community (EC) law and European Union law is that based on the Treaty structure of the European Union. The European Community constitutes one of the 'three pillars' of the European Union and concerns the social and economic foundations of the single market. The second and the third pillars were created by the Treaty of the European Union (the Maastricht Treaty) and involve Common Security and Defence Policy and Internal Security. Decision-making under the second and third pillars is not subject to majority voting at present. The Maastricht Treaty created the Justice and Home Affairs pillar as the third pillar. Subsequently, the Treaty of Amsterdam transferred the areas of illegal immigration, visas, asylum, and judicial co-operation to the European Community (the first pillar). Now Police and Judicial Co-operation in Criminal Matters is the third pillar. Justice and Home Affairs now refers both to the fields that have been transferred to the EC and the third pillar.
Several principles such as
subsidiarity, proportionality, the principle of conferral, and the precautionary principlehave become prominent in the development of European Union law. Scholars such as Catherine Barnard argue that the Four Freedoms form the substantive lawof the EU: free movement of goods, services, capital, and labour within the internal market of the EU.
In 2006, a toxic waste spill off the coast of Côte d'Ivoire, from a European ship, prompted the Commission to look into legislation against toxic waste. Environment Commissioner
Stavros Dimasstated that "Such highly toxic waste should never have left the European Union". With countries such as Spain not even having a crime against shipping toxic waste Franco Frattini, the Justice, Freedom and Security Commissioner, proposed with Dimas to create criminal sentences for "ecological crimes". His right to do this was contested in 2005 at the Court of Justice resulting in a victory for the Commission. That ruling set a precedent that the Commission, on a supranational basis, may legislate in criminal law - something never done before to outlined in treaties. So far though, the only other use has been the intellectual property rights directive.cite news|last=Charter|first=David|coauthors=|title=A new legal environment|work=E!Sharp|pages=23-5|publisher=People Power Process|date=2007|url=|accessdate=] Motions were tabled in the European Parliament against that legislation on the basis that criminal law should not be an EU competence, but was rejected at vote.cite web|last=Gargani|first=Giuseppe|authorlink=|coauthors=|title=Intellectual property rights: criminal sanctions to fight piracy and counterfeiting|work=|publisher=European Parliament|date=2007|url=http://www.europarl.europa.eu/news/expert/infopress_page/057-4356-078-03-12-909-20070319IPR04284-19-03-2007-2007-false/default_en.htm|format=|doi=|accessdate=2007-06-30] However in October 2007 the Court of Justice ruled the Commission could not propose what the criminal sanctions could be, only that there must be some.cite web|last=Mahony|first=Honor|authorlink=|coauthors=|title=EU court delivers blow on environment sanctions|work=|publisher=EU Observer|date= 2007-10-23|url=http://euobserver.com/9/25028|format=|doi=|accessdate=2007-10-23]
The primary legislation, or treaties, are effectively the constitutional law of the European Union. They are created by governments from all EU Member States acting by consensus. They lay down the basic policies of the Union, establish its institutional structure, legislative procedures, and the powers of the Union. The Treaties that make up the primary legislation include:
* the ECSC Treaty of 1951 (Treaty of Paris)
* the EEC Treaty of 1957 (Treaty of Rome)
EURATOMTreaty of 1957 (Treaty of Rome)
Merger Treatyof 1965
* the Acts of Accession of the United Kingdom, Ireland and Denmark (1972)
* the Budgetary Treaty of 1970
* the Budgetary Treaty of 1975
* the Act of Accession of Greece (1979)
* the Acts of Accession of Spain and Portugal (1985)
Single European Actof 1986
Treaty of Maastrichtof 1992 (Treaty of European Union)
* the Acts of Accession of Austria, Sweden and Finland (1994)
Treaty of Amsterdamof 1997
Treaty of Niceof 2001
Treaty of Accession 2003
Treaty of Accession 2005
The various annexes and protocols attached to these Treaties are also considered a source of primary legislation. The heads of State and government of the member states of European Union signed a constitution in 2004, but it has not yet been ratified by the Member States and as of March 2007 it was unclear if it would be ratified.
Passing of laws
European laws are passed by the EU institutions through a number of procedures. In nearly all cases the
European Commission(the executive branch) has a monopoly on legislative initiative. In such situation the Commission sends draft legislation to the Council of the European Unionand European Parliamentfor amendments and approval. The former body is composed of national government ministers and the latter by directly elected politicians.
There are four main legislative procedures in the EU, with the main difference between them being how the European Parliament interacts with the Council of the European Union. These are the
Codecision procedure, Assent procedurethe Cooperation procedure and the Consultation procedure. [ [http://www.europa.eu/institutions/decision-making/index_en.htm How the EU takes decisions ] ]
The European Parliament, the Commission and the Council of Ministers are empowered by the Treaties to legislate on all matters within the EU's competence. [see Art.2 TEC; "The Community shall have as its task, by establishing a common market and an economic and monetary union and by implementing common policies or activities..." [http://eur-lex.europa.eu/en/treaties/dat/12002E/htm/C_2002325EN.003301.html] ] Examples of this
secondary legislationare regulations, directives, decisions, recommendations and opinions. Secondary legislation also includes inter-institutional agreements, which are agreements made between European Unioninstitutions clarifying their respective powers, especially in budgetary matters. The Parliament, Commission and Council are capable of entering into such agreements.
The classification of legislative acts varies among the First, Second and Third Pillars. In the case of the first pillar: Secondary legislation is classified based on to whom it is directed, and how it is to be implemented. Regulations and directives bind everyone, while decisions only affect the parties to whom they are addressed (which can be individuals, corporations, or member states). Regulations have direct effect, i.e. they are binding in and of themselves as part of national law, while directives require implementation by national legislation to be effective. However, states that fail or refuse to implement directives as part of national law can be fined by the European Court of Justice.
Directives and regulations can comprise of a mixture of
maximum harmonisationand minimum harmonisationclauses, and can be enforced on either a home state or a host state basis. All EU legislation must be based on a specific Treaty article, which is referred to as the "legal basis" of the legislation. The European Constitutionwould have codified EU law and reduced secondary legislation to six clear types: EU laws, EU framework laws, decisions, regulations, recommendations and opinions.
The European Court of Justice (ECJ), has jurisdiction in various specific matters, conferred on it by the Treaties. In particular Article 220 EC charges the ECJ (and the Court of First Instance) with ensuring that the law is observed "in the interpretation and application of this Treaty", [Art. 220 TEC ] and this provision has been used by the Court to extend its powers beyond those otherwise expressly granted. [Craig and de Burca (2007) p.72f] Since the Maastricht Treaty, the Court has been empowered to impose pecuniary penalties on Member States who disobey. [see Art. 228 TEC] The Court has been instrumental in shaping law in the EU, and its approach is generally described as purposive or teleological [Craig and de Burca (2007) p.73] The jurisprudence of the Court, together with that of the courts of the member states, has established and defined a number of principles of European Union law, which bind EU institutions and member states, including direct effect, the supremacy of European Union law over that of Member states, and state liability for damages. [Craig and de Burca (2007) p.73]
According to the Treaty, the Court comprises one judge per member state; as of 2007 it has 27 judges. The judges are appointed "by common accord of the Governments of the Member states". [Article 223; Craig and de Burca (2007) p.67] The judges are appointed for a (renewable) period of six years. [Article 223; Craig and de Burca (2007) p.67] The Court is assisted by eight
Advocates General. [Article 222; Craig and de Burca (2007) p.67] The Court usually sits in Chambers of three or five, but in some cases as a single judge, in especially important cases as a Grand Chamber of thirteen judges or as a full court. [ Craig and de Burca (2007) p.67] [cite web | url = http://curia.europa.eu/en/instit/presentationfr/cje.htm | title = The Court of Justice of the European Communities | accessdate = 2007-12-01 ]
Court of First Instance(CFI) was established on the basis of the Single European Act in 1988 and was originally "attached to" the ECJ in a subsidiary role. Following the Treaty of Niceit was given greater independence and its own jurisdiction. [Craig and de Burca (2007) p.68] The jurisdiction of the CFI includes direct actions by natural or legal persons against Community institutions for their acts (or failure to act), actions by Member states against the Commission, and actions relating to Community trade marks. [cite web | url = http://curia.europa.eu/en/instit/presentationfr/tpi.htm | title = The Court of First Instance | accessdate = 2007-12-01 ]
According to the Treaty, the court comprises at least one judge per member state; as of 2007 it has 27 judges. The judges are appointed for a (renewable) period of six years. [cite web | url = http://curia.europa.eu/en/instit/presentationfr/tpi.htm | title = The Court of First Instance | accessdate = 2007-12-01 ] Like the ECJ, the CFI usually sits in Chambers of three or five, but in some cases as a single judge, as a Grand Chamber of thirteen judges, or as a full court. [cite web | url = http://curia.europa.eu/en/instit/presentationfr/tpi.htm | title = The Court of First Instance | accessdate = 2007-12-01 ] Decisions of the CTI can be appealed to the ECJ on matters of law. [Craig and de Burca (2007) p.68] To reduce the workload of the ECJ and the CFI, the Treaty of Nice (Article 225a) introduced "judicial panels" to be used in some areas, with appeal to the CFI. [Craig and de Burca (2007) p.69]
EU legal principles
It has been ruled several times by the
European Court of Justicethat EC(European Community-first pillar) law is superior to national laws. Where a conflict arises between EC law and the law of a Member State, EC law takes precedence, so that the law of a Member State must be disapplied. This doctrine, known as the supremacy of EC law, emerged from the European Court of Justicein " Costa v. ENEL". [Case 6/64, [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:61964J0006:EN:NOT"Falminio Costa v. ENEL"]  ECR 585, 593] Mr Costa was an Italian citizen opposed to nationalising the Italian energy company ENEL, because he had shares in it. He refused to pay his electricity bill in protest, and argued that nationalisation infringed EC law on the State distorting the market. [now found in Art. 86 and Art. 87] The Italian government believed that this was not even an issue that "could" be complained about by a private individual, since it was a national law decision to make. The Court ruled in favour of the government, because the relevant Treaty rule on an undistorted market was one on which the Commission alone could challenge the Italian government. As an individual, Mr Costa had no standing to challenge the decision, because that Treaty provision had no direct effect. ["But this obligation does not give individuals the right to allege, within the framework of community law... either failure by the state concerned to fulfil any of its obligations or breach of duty on the part of the commission."] But on the logically prior issue of Mr Costa's ability to raise a point of EC law against a national government in legal proceeding before the courts in that Member State the ECJ disagreed with the Italian government. It ruled that EC law would not be effective if Mr Costa could not challenge national law on the basis of its alleged incompatibility with EC law.
It follows from all these observations that the law stemming from the treaty, an independent source of law, could not, because of its special and original nature, be overridden by domestic legal provisions, however framed, without being deprived of its character as community law and without the legal basis of the community itself being called into question. [Case 6/64, [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:61964J0006:EN:NOT "Falminio Costa v. ENEL"]  ECR 585, 593]
However, while Community law is accepted as taking precedence to the law of Member States, not all Member States share the analysis used by the European institutions about why EC law overrides national law, when a conflict appears. [in the U.K. see, [Factortame case|"Factortame Ltd. v Secretary of State for Transport (No. 2)  1 AC 603"] ; in Germany see "Solange II" ("Re Wuensche Handelsgesellschaft", BVerfG decision of 22 October 1986  3 CMLR 225,265); in Italy see "Frontini v. Ministero delle Finanze"  2 CMLR 372; in France see, Raoul George Nicolo  1 CMLR 173]
Many countries' highest courts have stated that Community law takes precedence provided that it continues to respect fundamental constitutional principles of the Member State, the ultimate judge of which will be the Member State (more exactly, the court of that Member State), rather than the European Union institutions themselves [see especially, "Solange II" ("Re Wuensche Handelsgesellschaft", BVerfG decision of 22 October 1986  3 CMLR 225,265)] This reflects the idea that Member States remain the "Master of the Treaties", and the basis for EC law's effect. In other cases, countries write the precedence of Community law into their constitutions. For example, the
Constitution of Irelandcontains a clause that, '"No provision of this Constitution invalidates laws enacted, acts done or measures adopted by the State which are necessitated by the obligations of membership of the European Union or of the Communities..."
However, the difference of positions remained of solely academic importance. As of now, no court of any Member State has ever challenged the validity of any legal act of the European Union by any other means than referring the question to the European Court of Justice. The German legislature even accepted the judgment of the European Court of Justice in the case of
Tanja Kreil, which rendered void a provision in the German constitution barring women from voluntary service in the armed forces, subsequently amended the constitution and accepted women for any position in the forces.
EU law covers a broad range which is comparable to that of the legal systems of the Member States themselves. [see Article 3 TEU for a list] Both the provisions of the Treaties, and EU regulations are said to have "
direct effect" horizontally. This means private citizens can rely on the rights granted to them (and the duties created for them) against one another. For instance, an air hostess could sue her airline employer for sexual discrimination. [under Art. 141 TEC, C-43/75 "Defrenne v. Sabena"  ECR 455] The other main legal instrument of the EU, "directives", have direct effect, but only "vertically". Private citizens may not sue one another on the basis of an EU directive, since these are addressed to the Member States. Directives allow some choice for Member States in the way they translate (or 'transpose') a directive into national law - usually this is done by passing one or more legislative acts, such as an Act of Parliamentor statutory instrumentin the UK. Once this has happened citizens may rely on the law that has been implemented. They may only sue the government "vertically" for failing to implement a directive correctly. An example of a directive is the Product liabilityDirective, [ [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31985L0374:EN:HTML 85/374/EEC] ] which makes companies liable for dangerous and defective products that harm consumers.
The core of European Union economic and social policy is summed up under the idea of the four freedoms - free movement of goods, workers, capital and the freedom of establishment to provide services.
Movement of goods
Under the first title of the Treaty of the European Communities one finds the provisions dealing with the free movement of goods. In the years between the two world wars, and leading into the
Great Depression, governments around the world had employed vigorous policies of national protectionism. The erection of tariffs and customs duties on imports and sometimes the export of goods was widely seen as contributing to a fall in trade and hence the stalling of economic growth and development. Economists had long said, since Adam Smithand David Ricardothat the Wealth of Nationscould only be strengthened by the long term lowering and abolition of barriers and costs to international trade. The abolition of all such barriers is the function of the treaty provisions. According to Article 28 EC,
"28. Quantitative restrictions on imports and all measures having equivalent effect shall be prohibited between Member States."
Article 29 EC states the same for exports. The first thing to note is that the prohibition is simply between member states of the European Community. One of the institutions' primary duties is the management of trade policy to third parties - other countries such as the United States, or China. For instance, the controversial
Common Agricultural Policyis regulated under Title II EC, Article 34(1) authorising "compulsory coordination of national market organisations" with common European organisation. The second thing to note is that Article 30 sets out the exceptions to the prohibition on free movement of goods.
"30. The provisions of Articles 28 and 29 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."
So governments of member states may still justify certain trade barriers when public morality, policy, security, health, culture or industrial and commercial property might be threatened by complete abolition. One recent example of this was that during the
mad cow diseasecrisis in the United Kingdom, France erected a barrier to imports of British beef. [ [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:62000J0001:EN:NOT Case C-1/00] "Commission v. France" n.b. this case was brought under Art. 226, for France's failure to fulfill its obligations under various EU directives, which are in turn sourced on the Art. 28 and 31]
Movement of workers
Movement of capital
Freedom of establishment
The Social chapter in the European Union refers to parts of the treaty which deal with the equal treatment of men and women under Article 141 EC and the regulation of working time under the
Working Time Directive. One recent piece of anti-discriminationlegislation is Directive 2006/54/EC"on the implementation of the principle of equal opportunities and equal treatment of men and women in matters of employment and occupation".
The UK secured an opt-out from the Social Chapter as many members of John Major’s government were fundamentally opposed to extension of the EU’s competence into social areas. The issue was so divisive that it threatened to split the Cabinet.
Defrenne v. Sabena (No.2)"
Foster v. British Gas plc."
* [http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:61984J0170:EN:HTML C-170/84] "Bilka-Kaufhaus Gmbh v. Karin von Weber"  ECR 1607 - on the interpretation of "objective justification" for indirect discrimination between men and women, under Article 141 TEC
Since the goal of the
Treaty of Romewas to create a common market, and the Single European Actto create an internal market, it was crucial to ensure that the efforts of government could not be distorted by corporations abusing their market power. Hence under the treaties are provisions to ensure that free competition prevails, rather than cartels and monopolies sharing out markets and fixing prices. Competition lawin the European Union is largely similar and inspired by United States antitrust.
Collusion and cartels
The Treaty of the European Communities (TEC), under Article 81 (1), prohibits
"all agreements between undertakings, decisions by associations of undertakings and concerted practices which may affect trade between member states and which have as their object or effect the prevention, restriction or distortion of competition within the common market."
Agreements, decisions and concerted practices, known collectively as "collusion" are deemed automatically void under Article 81 (2). Article 81 (3), however, makes exceptions for collusion that could be of economic benefit.
"The provisions of paragraph 1 may, however, be declared inapplicable in the case of (i) any agreement or category of agreements between undertakings; (ii) any decision or category of decisions by associations of undertakings; (iii) any concerted practice or category of concerted practices, which contributes to improving the production or distribution of goods or to promoting technical or economic progress, while allowing consumers a fair share of the resulting benefit, and which does not (a) impose on the undertakings concerned restrictions which are not indispensable to the attainment of these objectives; (b) afford such undertakings the possibility of eliminating competition in respect of a substantial part of the products in question.
The term "undertaking" essentially refers to businesses, but also any economic entity which carries on a trade.
Dominance and monopoly
Article 82 TEC is designed to prohibit abuse by very large corporations who dominate the market.
"Any abuse by one or more undertakings of a dominant position within the common market or in a substantial part of it shall be prohibited as incompatible with the common market insofar as it may affect trade between Member States.
This provision is then clarified through the use of some specific categories of behaviour which are deemed "abusive".
"Such abuse may, in particular, consist in (a) directly or indirectly imposing unfair purchase or selling prices or other unfair trading conditions; (b) limiting production, markets or technical development to the prejudice of consumers; (c) applying dissimilar conditions to equivalent transactions with other trading parties, thereby placing them at a competitive disadvantage; (d) making the conclusion of contracts subject to acceptance by the other parties of supplementary obligations which, by their nature or according to commercial usage, have no connection with the subject of such contracts.
Mergers and acquisitions
Under the authority of Article 82 TEC, the European Commission became able not only to regulate the behaviour of large firms it claims abuse their dominant positions or
market power, but also the possibility of firms gaining the position within the market structurethat enables them to behave abusively in the first place. Regulation 139/2004 deals with mergers that have a "Community dimension" and lays out a procedure whereby all "concentrations" (i.e. mergers, acquisitions, takeovers) between undertakings are subject to approval by the European Commission.
Public sector regulation
Public sector industries, or industries which are by their nature providing a public service, are involved in competition law in many ways similar to private companies. Under EC law, Articles 86 and 87 create exceptions for the assured achievement of public sector service provision. Many industries, such as railways, telecommunications, electricity, gas, water and media have their own independent sector regulators. These government agencies are charged with ensuring that private providers carry out certain public service duties in line of
*European Company and Cooperative Statutes
Corpus Jurisor Acquis
EU competition law
Charter of Fundamental Rights of the European Union
Directive 95/46/EC on the protection of personal data
Home state regulation
Host state regulation
Four Freedoms (European Union)
List of European Court of Justice rulings
Master of European Law
*cite book | last = Craig | first = Paul | authorlink = Paul Craig | coauthors = Gráinne de Búrca| title = EU Law, Text, Cases and Materials | edition = 4th ed.| year = 2007| publisher = Oxford University Press | location = Oxford, New York | isbn = 978-0-19-927389-8
*cite book | last = Steiner | first = Josephine | coauthors = Lorna Woods; Christian Twigg-Flesner | title = EU Law | edition = 9th ed. | year = 2006 | publisher = Oxford University Press | location = Oxford, New York | isbn = 978-0-19-927959-3
*cite book | last = Barnard | first = Catherine | title = The Substantive Law of the EU: The Four Freedoms | edition = 2nd ed. | year = 2007 | publisher = Oxford University Press | location = Oxford, New York | isbn = 978-0-19-929839-6
*cite book | last = Kaczorowska | first = Alina | authorlink =
coauthors = | title = EU Law|edition= 1st ed.
date = 2008-07-25 | publisher = Routledge-Cavendish| location=London| isbn = 978-0-415-44798-0
* [http://eur-lex.europa.eu/ EUR-Lex] - online access to existing and proposed European Union legislation
* [http://eur-lex.europa.eu/en/treaties/index.htm EUR-Lex: Treaties]
* [http://europa.eu/scadplus/scad_en.htm Scadplus (summaries of EU legislation)]
* [http://ec.europa.eu/publications/booklets/eu_documentation/02/index_en.htm The ABC of Community Law]
* [http://eulaw.typepad.com/ EU Law Blog]
* [http://www.law.ed.ac.uk/europa/ Europa Institute, University of Edinburgh] - Research and Education in European Law and Institutions
* [http://www.unifr.ch/euroinstitut Institute of European Law, University of Freiburg] - Research and Education in European Law
* [http://www.europainstitut.de: Europa-Institut, University of Saarlandes] - Education in European Law
* [http://www.ecjblog.com ECJBlog.com, weblog with daily news about the European Court of Justice]
* [http://www.eulaw.ru/ EU Law and Russia: analysis]
* [http://www.dirittoue.info/ DirittoUE.info - EU Law Blog in italian]
* [http://www.ena.lu History and institutions of the united Europe since 1945] — European Navigator
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