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European Community: A Services Directive at Last

© 2007 William B. Bierce.  All rights reserved.

            On December 27, 2006, the European Union’s Parliament and Council of the European Union adopted Directive 2006/123/EC on “Services in the Internal Market.”  This pivotal directive represents the culmination of additional year’s negotiations following the failure to adopt a prior services directive on the same subject.  It represents an important step in cross-border flow of services within the European Union (EU).  More importantly, it distinguishes between rights of establishment and rights to provide and receive services across member states.   Member States must adopt implementing legislation before 28 December 2009.

            Key Value.   Services account for 70% of the GDP and employment in most EU Member States.  The Services Directive is one of the most important, yet most highly disputed, European Community directives.  Tensions were high between social protection for the labor force and economic freedoms of service providers and service recipients.   A prior services directive had failed.   As adopted, this directive will boost cross-border provision of services in the EU, which comes at an especially important time as the EU has enlarged to include new “low cost” countries on the periphery.   Such low-cost countries will be able to gain access to local high-value economies in the original EU.  

            Key Elements.  The Services Directive adopts key improvements to cross-border provision of services in the EU. 

  • One-Stop Shopping for Administrative and Regulatory Compliance.  Each member state must now make it easier for service providers to either establish a subsidiary in the target member state or to sell services cross-border without a local permanent establishment.  This simplification will reduce administrative costs in the creation and operation of new cross-border businesses for service providers based in the EU.  All this regulation must be online on the Internet, a move for e-government.
  • Retained Jurisdiction of National Requirements for Essential Public Policies.  Unlike the failed directive that would have largely excluded national requirements that might block cross-border services, the 2006 Services Directive preserves the rights of each member state to invoke certain key public policies in regulation of cross-border trade in services.   (This issue was worked out in the United States in early Supreme Court cases on federalism in the 19th and early 20th centuries.)   Based on EU Court of Justice decisions, local governments retain the right to protect their local interests in matters of:
    • Public health, security and “public policy”;
    • Consumer protection;
    • Animal health;
    • Protection of the urban environment;
    • Employment conditions (which are governed by the Directive on the Posting of Workers of the Provision of Services, Directive 96/71/EC of 16 December 1996, which regulates normal conditions of employment and specifically protects workers hired out by temporary employment undertakings).

 But no such authorization scheme or restriction may, under the 2006 Services Directive, discriminate on the basis of nationality.   To the extent of any local regulation, the Services Directive retains the principles of legitimacy of local regulation:

·        Non-discrimination (“the requirement may be neither directly nor indirectly discriminatory with regard to nationality or, in the case of legal persons, with regard to the Member State in which they are established”);

·        Necessity (“the requirement must be justified for reasons of public policy, public security, public health or the protection of the environment”); and

·        Proportionality (“the requirement must be suitable for attaining the objective, and must not go beyond what is necessary to obtain that objective”).  Services Directive, Art. 16(1). 

  • Cooperation and Coordination between Member States.   Member States will be obliged to cooperate to avoid duplication of controls and promote efficiency in supervision of cross-border service providers. 

 Implications for Non-EU Service Providers. 

  • Freedom of Establishment and Freedom of Movement of Services.  The 2006 Services Directive opens the door for acquisitions by non-EU service providers to acquire EU service providers to integrate with a global services delivery platform.  If a service provider is established under the laws of a Member State, it will enjoy the “freedom of establishment” in its local market and across the EU.   In contrast, if the service provider (“operator”) is not established in the Member State where the service is provided, its activities should be covered by the EU’s rules on freedom of movement of services.  Under Court of Justice rulings, no local establishment is required if the “temporary” services meet the applicable standards in light of the duration of the service, the regularity, periodical nature and continuity of the services. 
  • Contract Rights.  The Services Directive does not impose any rules on contractual relations between a service provider and a service recipient, or between an employer and an employee.  The directive leaves such matters to private international law (freedom of contract).
  • Freedom for the Consumer.  The Services Directive also directs that consumers be free to buy services from service providers in another Member State.  Consumers can be free of an obligation to obtain authorization from, or to make a declaration to, their competent local authorities.   

  Posted: January 22, 2007

Further Readings:

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