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63
* Adam A. Ambroziak – SGH Warsaw School of Economics,
e-mail: Adam.A.Ambroziak@sgh.waw.pl, ORCID ID: 0000-0002-4618-8497.
DOI: 10.33067/SE.3.2023.4
Adam A. Ambroziak*
Integration of the European Single Market
Thirty Years After Its Creation
Abstract
The European single market was launched on 1st January 1993. Presumably,
it is at that time that three fundamental barriers (physical control at the
border, various technical requirements, and differing systems of indirect
taxation) were formally removed to ensure four treaty-based freedoms: free
movement of goods, freedom to provide services, free movement of people
and free movement of capital. The EU single market is characteristic in
nature due to the scope of legislation governing businesses and consumers,
which is largely subject not to unifi cation, rather only harmonisation.
Regrettably, this has resulted in EU legislation being (deliberately at
times) not always correctly implemented into the national legal system.
This leads to market fragmentation and creates barriers, rather than
eliminating them. This study aims to identify the relationship between
full and correct implementation of EU legislation into the Member States’
legal systems versus progress in European single market integration.
Therefore, the evolution of indicators defi ning how much EU single market
legislation in the Member States has been implemented was examined. At
the same time, changes in transposition defi cit (from 1997 to 2021) and
conformity defi cit (from 2004 to 2021) for particular Member States were
critically analysed. Further, it was analysed how much the single market
was integrated from the perspective of goods being the main components
of the single European market. To this end, intra-EU trade was analysed
as broken down into exports and imports of goods, versus the global trade
of individual Member States (including trade with non-EU partners). The
outcome of the study shows that both transposition and conformity defi cit
levels are quite high. In turn, intra-EU trade in goods does not largely
correspond to the extent of implementation of EU legislation, which may
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Studia Europejskie – Studies in European Affairs, 3/2023
be caused by growing interest in non-EU partners without compromising
EU presence.
Keywords: Single European Market, Transposition Defi cit, European
Union, Trade in Goods
Introduction
The European single market is defi nitely one of the most important
achievements of economic integration within the European Union. This
is because it ensures not only the free fl ow of products, i.e. manufactured
goods and offered services, but also the factors of production necessary to
produce them, i.e., capital and labour. The European single market was
launched on 1st January 1993 in its expanded form as defi ned by Bélla
Balassa. Presumably, it is at that time that three fundamental barriers were
formally removed to ensure four treaty-based freedoms: physical control
at the border, various technical requirements, and differing systems of
indirect taxation. This undertaking posed a huge challenge to Member
States’ economies, as it aimed to eliminate the remaining barriers that
businesses, consumers and employees faced in effectively functioning on
the EU market.
The adoption of political decisions and operational documents across
European institutions relating to the functioning of the EU internal
market shows how important it was. Within only a few months of the 1993
launch of the single market, the European Council underscored in EU
membership criteria that each candidate country was required to ensure
“the existence of a functioning market economy as well as the capacity
to cope with competitive pressure and market forces within the Union”
(EUCO, 1993). Subsequently, as the extensive 2004 enlargement, including
Poland’s accession, approached, the EU institutions repeatedly stressed
the nature and essence of the single European market. The quintessence
of these activities is the reports (scoreboards) currently prepared by the
European Commission on the implementation of market legislation in
national legal systems by all Member States (EC, 2013). It shows the
special nature of the EU internal market which, being subject to shared
competences between the European Union and the Member States, is not
largely unifi ed, rather harmonised. Regrettably, this resulted in the EU
legislation being (deliberately at times) not always correctly implemented
into national laws. This leads to market fragmentation and creates barriers,
rather than eliminating them. Hence, it is not surprising that thirty years
after the market’s symbolic implementation the European Council still
“supports the renewed focus on enforcing existing Single Market rules and
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A.A. Ambroziak, Integration of the European Single Market Thirty Years...
on removing barriers” (EUCO, 2023), whereas the Commission devises
subsequent strategies and communications (EC, 2023b, Ambroziak, 2012;
Kurczewska, Stefaniak, 2022). That the European market is attractive and
it plays a role in the global economy is also shown by numerous non-
EU countries being interested in closer integration through contracts
establishing free trade zones or even joining the market (Norway, Iceland,
Liechtenstein), without being an EU member.
The reason for EU institutions continuing to claim it is necessary to
eliminate barriers in the internal market may be down to four factors:
a) the existing EU legislation has not been fully or correctly implemented,
b) there is a lack of adequate legislation for the rapidly developing digital
market, for instance, c) EU legislation is not able to cover all aspects of
economic activity, as some of them fall under the exclusive competence
of Member States, and d) the existing impediments are not barriers in
the sense of the EU treaties, but are administrative burdens applied by
Member States on a non-discriminatory basis.
The study on EU legislation transposition has so far primarily
focused on the analysis of the legislative process (Haverland, Romeijn,
2007), including with respect to particular countries or country groups
(Sverdrup, 2004; De Coninck, 2015; Lazar, Lazar, 2015; Musiałkowska,
2017; Toshkov, 2008), the determinants of delays in implementation
(Kaeding, 2006), including for selected sectors (Kaeding, 2008;
Michelsen, 2008), as well as with respect to economic or political
turbulences (Pircher, Loxbo, 2020). Other studies ventured to analyse
the outcome of EU directive transposition from the perspective of the
Commission affecting the efforts of Member States (Moriana et al., 2017)
and integration processes in the EU (Ručinská, Fečko, 2019; Howarth,
2022). To the best of the author’s knowledge, however, the lacking aspect
is the relationship between the extent of the implementation of EU
legislation (i.e., the extent of market unifi cation) and economic links in
the form of intra-EU trade.
Therefore, this study aims to identify the relationship between full
and correct implementation of the EU legislation into the Member States’
legal systems versus progress in European single market integration.
Therefore, the evolution of indicators defi ning how much EU single market
legislation in the Member States has been implemented was examined. At
the same time, changes in transposition defi cit and conformity defi cit for
particular Member States (from 1997 to 2021 as well as from 2004 to 2021,
respectively) were critically analysed. Further, it was analysed how much
the internal market was integrated from the perspective of goods being
the main components of the single European market. To this end, intra-
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Studia Europejskie – Studies in European Affairs, 3/2023
EU trade was analysed as broken down into exports and imports of goods,
versus the global trade of individual Member States (including trade with
non-EU partners). The resulting data were compared with the extent of
EU legislation transposition into EU Member States’ legal systems.
This study employed the available European Commission’s data
published as part of annual Scoreboard reports, as well as data in
international trade statistics and the balance of payments of EU Member
States. The period from 2004 to 2021 was taken as the main period
surveyed (unless otherwise indicated), since it encompassed all the EU
Member States excluding the UK.
The fi rst part of the paper presents the evolution of indicators defi ning
the extent of implementation of EU legislation into Member States’
legal systems. The follow-up part describes the extent of integration of
the market of goods. A comparative analysis was employed of intra- and
extra-EU trade in goods along with trends in trade versus transposition
parameters of market legislation. Conclusions are provided in the fi nal
part.
Evolution of Transposition
and Implementation of EU Law
The legislation on the European single market (ESM) consists of
the Treaty on the European Union, the Treaty on the Functioning
of the European Union, and the entire secondary law of the EU, from
regulations, directives, and decisions, to guidelines and notices of
individual EU institutions. The legal basis for the introduction of the
ESM became the Single European Act of 1986, which introduced Article
8a into the then Treaty establishing the European Economic Community,
which stipulated that “the Community shall adopt measures with the aim
of progressively establishing the internal market over a period expiring
on 31 December 1992”, and that “the internal market shall comprise an
area without internal frontiers in which the free movement of goods,
persons, services and capital is ensured”. While treaty provisions do
not fundamentally change, the regulations adopted across various EU
institutions do, and this occurs much more often. The changes address the
needs of politicians, businesses, as well as the CJEU case law. Consequently,
bureaucracy escalation or even infl ation of EU legislation are often noted.
This is because of two parallel processes: increasing regulation due to
bureaucratisation of economic life (Berglund et al., 2006) and the need to
introduce new solutions to rectify the identifi ed shortcomings in existing
legislation on account of ever deeper and broader integration. In the fi rst
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A.A. Ambroziak, Integration of the European Single Market Thirty Years...
case, the new legislation is conducive to increasing harmonisation and
to expanding it over successive elements in a given area, e.g., free fl ow of
goods, whereas in the other case, EU legislation is implemented in new
activity domains, e.g., digital trade. Consequently, it is now very diffi cult
to clearly determine the scope of an internal market, which covers not
only four treaty-based freedoms, but it also elements of industrial policy,
competition and consumer protection, and health, environmental, climate
and energy policies.
The original process of developing the internal market chiefl y envisaged
directives being acts in law leading to harmonisation of Member States’
laws. This is because the intention was to eliminate severe discrepancies
in the national regulations. A perfect legal basis for that was the current
Article 26 of TFEU, which holds that “the Union shall adopt measures
with the aim of establishing or ensuring the functioning of the internal
market, in accordance with the relevant provisions of the Treaties” and
Article 114, which refers to “the measures for the approximation of the
provisions laid down by law, regulation or administrative action in Member
States which have as their object the establishment and functioning of the
internal market”. Such an attitude implied it was necessary for Member
States to introduce complex legislative procedures into the national legal
system. Thus transposition, which is incorporating EU legislation into
the national law, and then implementing the laws adopted, was vital. The
quality and effi ciency of the process, however, may have varied depending
on the procedure model in particular Member States (Steunberg, Rhinard,
2010), political will, and the so-called state failure. A signifi cant delay
in transposition and delays in keeping the prescribed deadlines were yet
another issue (Borghetto et al., 2006).
In fact, the problem was acknowledged at the very beginning of the
ESM. As early as in 1996, i.e. three years after the launch of the ESM, the
European Council noted that “whilst noting the progress that has been
accomplished in this area, it remains concerned with the delays in the
transposition and implementation of a number of Directives” (EUCO,
1996). In response, the European Commission, as guardian of the treaties
and of compliance with EU legislation, prepared the fi rst Action Plan
for better implementation of EU Legislation (EC, 1997a) which was
fully endorsed by the European Council in 1997 (EUCO, 1997). It is at
that time that the Commission noted that it was necessary to take up
“renewed political effort to remove remaining obstacles”, and underlined
“the crucial importance of timely and correct transposition of all agreed
legislation into national law (…) and the necessity of active enforcement
of Community law in the Member States”. It is also worth noting that
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Studia Europejskie – Studies in European Affairs, 3/2023
the EU leaders agreed to request “the Commission to examine ways and
means of guaranteeing in an effective manner the free movement of goods,
including the possibility of imposing sanctions on Member States”. Given
the European Council’s aforesaid instructions, the Commission launched
multi-layered and growing ever more complex annual examination of
the extent of transposition and implementation of EU legislation. The
main indicator analysed by all the parties concerned is transposition
defi cit. It is calculated as the percentage of single market directives not
yet completely notifi ed to the Commission as a ratio of the total number
of directives that should have been notifi ed by the deadline. Internal
Market directives covered by the aforementioned calculations are those
that have an impact on the functioning of the internal market as defi ned
in Articles 26 and 114 (1) of the TFEU. This includes the four freedoms
and the supporting policies having a direct impact on the functioning
of the Internal Market (such as taxation, employment and social policy,
education and culture, public health and consumer protection, energy,
and transport and environment, except nature protection) (EC, 2023).
In the fi rst study of 1997, the transposition defi cit was estimated at 6.3%
for the whole EU, while it varied markedly, ranging from 3% in Denmark
to 10% in Austria (EC, 1997b). From that moment on, the European
Commission started to use the Scoreboard, more or less openly, to “name
and shame” the Member States which, politically, had so far endorsed
transposition improvement and the implementation of EU legislation.
Consequently, as early as the next year, the average transposition defi cit
fell to 3.9% (the lowest in Finland at 1.2% and the highest in Belgium at
7.1%) (EC, 1998).
The years that followed saw a further decline in the transposition
defi cit of EU directives, reaching 3% in November 2000. At that time,
countries such as Denmark, Sweden and Finland recorded a rate of 1.1–
1.3%, while the three countries with the highest rate were Greece, France,
and Portugal (4.4–6.5%) (EC, 2000). In a wave of this rather radical
reduction in the transposition defi cit, in the spring of 2001, the European
Council (under the Swedish presidency) urged “Member States to accord
high priority to transposing internal market directives into national law,
aiming at an interim transposition target of 98.5% for the 2002 Spring
Council” (EUCO, 2001), which was seen as determining the maximum
defi cit level at 1.5%. By the next year, the EU had reached a level of 2%.
This was due to a large reduction in the rate of unimplemented directives
in countries with the highest transposition defi cits to date (Greece, France
and Austria down to 2.9–3%) and an even greater reduction in the lowest-
rate countries, that is Sweden, Denmark and Finland (down to 0.7–0.8%)
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A.A. Ambroziak, Integration of the European Single Market Thirty Years...
(EC, 2001). This inspired the EU leaders to agree that the Member States
should “make further efforts to meet that target and for a transposition
target of 100% to be achieved by the Spring European Council in 2003
in the case of directives whose implementation is more than two years
overdue” (EUCO, 2002). This was a departure from solely quantitative
analysis to a kind of political analysis. This is because not only a general
number of unimplemented, but also severely delayed directives came
under scrutiny. The two-year period indeed demonstrates not so much
a prolonged and perhaps more complicated legislative process in a given
Member State, but an intentional postponement. This is important
because, in deciding to use directives as the legal acts governing the ESM,
qualifi ed majority voting was introduced under the Single European Act
for their adoption. Consequently, it was assumed, apparently wrongly,
that in spite of the failure to approve a given act in the EU decision-
making process, relevant provisions would be incorporated into the
national systems.
A downward trend in the transposition defi cit continued until 2000,
when the rate was at 2%. In turn, in the following years, a growing
tendency became conspicuous, which prompted the European Council
in 2003 to repeat that “Member States must make a renewed effort (…) to
meet the Stockholm and Barcelona targets for transposing Internal Market
legislation”, this time by July 2003 (EUCO, 2003). In its 2003 Scoreboard,
the European Commission recorded further defi cit growth up to 2.3%.
At that time, the highest defi cits were recorded for France, Greece and
Figure 1. Evolution of the Transposition Defi cit in the European Union
from 1997 to 2021 (%)
Source: EC 2023a.
6,3%
3,9%
3,6%
3,0%
2,0%
2,1%
2,3%
3,6%
1,6%
1,2% 1,2%
1,0%
0,7%
0,9%
1,2%
0,6%
0,7%
0,5%
0,7%
1,5%
0,9%
0,7%
0,6%
1,0%
1,6%
27%
15%
13%
13%
10%
9%
9%
27%
10%
7%
8%
6% 5% 5% 6% 5% 4% 4% 4%
7%
5% 5% 4% 5%
6%
0,8%
0,6%
0,7%
0,7%
0,7%
0,7%
0,6%
0,8%
1,2%
1,4%
1,3%
0,0%
0,2%
0,4%
0,6%
0,8%
1,0%
1,2%
1,4%
1,6%
0%
5%
10%
15%
20%
25%
30%
Transposition deficit (in%) - left axis Incompleteness rate (in %) - left axis Conformity deficit (in %) - r ight axis
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Studia Europejskie – Studies in European Affairs, 3/2023
Germany (4.1–3.5%), whereas the lowest were for the United Kingdom,
Spain and Denmark (1.2–0.7%) (EC, 2004). In view of the approaching
enlargement, this was an alarming trend. Hence, at the beginning of the
next year, the European Council underlined “the need to address the
unacceptably high defi cits in transposing agreed measures into national
law, and to complete the legislative programme arising from the Lisbon
Agenda” (EUCO, 2004).
The enlargement of 2004 not only markedly increased the number of
Member States, but it also raised the defi cit to 7.1% in May. In November
that year, however, the defi cit rebounded to 3.6%, due to delays not so much
in implementation as in the administrations of the new Member States
giving notifi cation of the implementation (EC, 2005). Consequently, it
was primarily the new Member States (Lithuania, Hungary and Slovenia
at 0.7%) that in mid-2005 had already become the leaders in implementing
market directives, the worst performers being Greece, Luxembourg and
Italy (3.7–4.1%).
Four years into enlargement, in 2008, the average transposition defi cit
of ESM legislation fell to 1%, demonstrating that, in spite of twelve new
Member States joining, the 2003 target result could be achieved. At that
time, a decision was made to adopt an even more ambitious goal of 1% by
2009 at the latest, while stressing the importance of determining relevant
transposition deadlines. The rationale was that “clear and consistent
EU rules are a prerequisite for a well-functioning Internal Market as are
timely, correct and high-quality transposition of Community legislation
and effective application and enforcement of common rules” (EUCO,
2007). The level reached in 2009 was 0.7%, much as the following years
saw a rise to 1.2% in 2011, to which the ongoing economic and fi nancial
crisis probably partly contributed. It was at that time that the Commission
proposed in its “Single Market Act” to initiate “a more determined policy
in this fi eld” and announced that it “will call on the Member States to
improve the transposition of – and compliance with – their national
legislation, using numerical targets.” The Commission also noted that
“this approach has already enabled the transposition defi cit to be reduced
to 1%.” (EC, 2011). This proposal was not, however, repeated in any other
document of the European Council, so it did not gain political approval,
which is not to say the Member States failed to make efforts to reduce
the transposition defi cit, which went down to as much as 0.5% in 2014.
At that time, it was Croatia, Malta, Greece, Sweden, and Denmark which
posted particularly low levels of the said indicator (0.1–0.2%) with Cyprus,
Romania and Slovenia recording the highest numbers (1–1.4%) (EC,
2015). The year 2016 was noteworthy, when the defi cit exceeded 1.5% with
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A.A. Ambroziak, Integration of the European Single Market Thirty Years...
a number of countries contributing whose national rates went even beyond
2%, including, for example, Romania, Finland, Croatia, Luxembourg,
Bulgaria, Spain, Cyprus and Portugal (EC, 2017). This was mainly due to
the adoption of a signifi cant number of new directives, which defi nitely
caused the statistical performance of some Member States to worsen. On
the other hand, however, there were also countries that maintained a low
defi cit level of 0.4–0.7% (Malta, Denmark, Slovakia).
A return to markedly lower defi cit values of 0.6–0.7% up to 1% will be
seen in 2020 and 1.6% in 2021. The most recent doubling of values can be
linked to the COVID-19 pandemic and the shift in priorities of Member
States from implementing new legal solutions to pursuing autonomous
policies to support entrepreneurs (Ambroziak, 2022) despite ensuring
a relatively smooth functioning of the EU market (Ambroziak, 2021).
Given how the transposition defi cit is spread among the Member
States, in fact the defi cit went down over the 2004–2021 period in the
vast majority of them. For such countries as Germany, Italy, Greece, and
Luxembourg, as well as Czechia, Latvia, Estonia and Slovakia, the defi cit
fl uctuated considerably. Ultimately, following almost thirty years of the
European single market, the lowest average transposition defi cits were
recorded for Latvia, Poland, Bulgaria, Croatia and Hungary, as well as
Germany, Spain and the Netherlands (below 1%), and the highest for
Cyprus, Greece, Ireland and Belgium (over 1.5%).
That analysis shows that it is impossible to clearly demarcate between
the best and the worst countries with respect to EU membership
compliance construed as transposition of EU legislation into the national
systems. In the following years of the surveyed period, the composition
of country groups with the highest and the lowest ratio varied. Both of
these groups included the countries that joined the EU somewhat later
and the founders of the EU and ESM. Both of these groups included
countries big and small, of the South and North, or West and East, as
well as those of a better or worse level of development, more and less
affl uent.
The foregoing is due to a number of reasons. First, the study date
was not correlated with the adoption dates of new regulations and the
necessity to implement them. Such an argument is rather ill-founded, as
all the countries faced similar legislative challenges. Second, the reasons
for defi cit should be identifi ed, including the links to electoral cycles in
particular Member States, and the resulting delays, for instance, in the
parliamentary legislative process. Third, not all legislation adopted at
the EU level was a priority for all the Member States. Thus the national
processes could be expected to be obstructed by governments that did not
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Studia Europejskie – Studies in European Affairs, 3/2023
necessarily support or which downright opposed the adoption of certain
acts in law.
The qualifi ed majority system in the Council and the very strong position
of the European Parliament makes it very diffi cult or, in many cases,
impossible, to block the adoption of given legislation at the EU level. In
such cases, Member States resorted to certain solutions that blatantly defi ed
EU law, but which were expected at the national level, and postponed the
correct implementation of EU legislation. The legislation was unknowingly
improperly implemented, or openly obstructed to some extent knowingly.
In the fi rst case, it is true that Member States notify the Commission of
the implementation of EU legislation, including primarily directives, but
based on information from businesses, consumers, other Member States,
and sometimes national decision-makers’ own enunciations, it turns out
that it was implemented incorrectly. Due to a failure to align the national
legislation with EU law, the Commission may initiate an infringement
proceeding. In such a case, a particular legal act is classifi ed as conformity
defi cit. The Commission only took notice of this problem in the latter
years of the second decade of the ESM, hence the available data covers
the period from 2011 to 2021. Initially during that period, the conformity
Figure 2. Evolution of the Transposition Defi cit in the EU Member States
from 2004 to 2021
Black bar: a decrease, white bar: an increase in 2021 as compared to 2004.
Note: the value in parentheses is the average value of transposition defi cit during the
study from 1997 to 2021 (for countries which joined after 1997, the accession year is
the start date).
Source: The author’s own calculations based on EC 2023a.
(%).
0,0
1,0
2,0
3,0
4,0
5,0
6,0
7,0
8,0
9,0
10,0
2004
min
max
2021
73
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
defi cit remained relatively low at 0.6–0.7%, however, as of 2018, it began
to rise signifi cantly in almost all Member States to 1.3% for the whole EU
(Figures 1 and 3). The highest values were recorded by Italy and Poland,
with Czechia, Germany, Bulgaria, Hungary, Greece and France joining
in recent years. It should be borne in mind that this indicator does not
necessarily refl ect national regulations being actually inconsistent with EU
law, as the ultimate adjudication in this regard is made by the European
Court of Justice. However, the European Commission’s inclusion of specifi c
cases in these statistics means that it had serious doubts and there were
reasons to initiate an infringement proceeding.
0,0
0,5
1,0
1,5
2,0
2,5
2011 min max 2021
Figure 3. Evolution of the Conformity Defi cit in 2004–2021 (%)
Black bar: a decrease, white bar: an increase in 2021 as compared to 2004.
Source: The author’s own calculations based on EC 2023a.
Thus, with both the percentage demonstrating the transposition
defi cit and the percentage of incorrectly implemented directives, the
overall indicator of failure to fully and correctly implement the directives
of the single European market would be much higher. This hypothetical
index, constructed by adding up the aforementioned indicators, presents
national legislation implementing ESM directives differently (Figure
4). From the perspective of both a business and a consumer, it does not
matter whether a directive has been ill-transposed or not implemented at
all, as their rights are not secured uniformly across the European Union.
This leads to a conclusion that there is internal market fragmentation. In
2021, the highest accumulated percentage for both of these indicators was
posted for Romania, Spain, and Sweden (over 4%). It is only Denmark
and Germany that did not exceed the critical threshold of 1.5%. At the
same time, the highest averages were recorded for Italy (3.9%) and Poland
(3.1%).
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Studia Europejskie – Studies in European Affairs, 3/2023
0,0
0,5
1,0
1,5
2,0
2,5
3,0
3,5
4,0
4,5
0,0
0,5
1,0
1,5
2,0
2,5
3,0
3,5
4,0
4,5
5,0
DK DE FR HU FI EE EU IT MT HR CY AT LT EL PT PL NL SK LU BG LV SI CZ IE BE SE ES RO
Transposition deficit (left axis) Conformity deficit (left axis) Average for 2011-2021 (right axis)
Figure 4. Summary (Transposition and Conformity) Indicator of a Failure
to Fully and Correctly Implement EU Internal Market Directives
in 2021 (%)
Source: The author’s own calculations based on EC 2023a.
The European single market consists of 27 national markets, however
the adoption of EU regulations should ensure similar/approximate
business conditions across all the EU Member States. In fact, any
derogations, whether regarding incorrect transposition, non-transposition,
or late transposition, give rise to single market fragmentation. In order
to encapsulate this trend, the European Commission introduced an
incompleteness rate index which refl ects the number of unimplemented
directives as a percentage of all internal EU market directives (Figure 1).
Evolution of this index follows a trajectory that coincides with the
percentage of the transposition defi cit, but at a much higher level. This is
because it identifi es any directive that has not been properly implemented
(even in a single Member State) as market fragmentation. In recent years,
this percentage ranged from 4 to 5%, although it rose to 6% at the EU level
in 2021.
As a consequence of the above struggle with the process of transposition
and implementation of EU directives, the European Commission
is gradually replacing them with regulations, i.e., legal acts directly
applicable in all EU Member States. The original plans for the creation of
a single European market envisaged almost 300 directives. In subsequent
years, the number increased rapidly until the culminating year of 2006,
when the pool of internal market directives amounted to 1639 items.
At that time, however, the rate of enactment of EU regulations i started
to accelerate, to outnumber directives more than fi vefold in 2021 (5669
versus 997) (Figure 5).
75
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
0
1000
2000
3000
4000
5000
6000
Directives Regulations
Figure 5. Number of Directives and Regulations in the European Union
from 1997 to 2021
Source: EC 2023a.
Developments in Trade in Goods as an Example
of the Integration of the European Single Market
The level of real integration of the European single market is evidenced
by indicators defi ning the geographic location of trade in goods. Intra-
EU exports increased from EUR 1.5 trillion in 2004 to EUR 4.2 trillion
in 2022, or almost three times, while extra-EU exports went from EUR
1 trillion to EUR 2.6 trillion, an increase of 2.6. This implies a higher
rate of growth of intra-EU exports in goods versus extra-EU exports from
2004 to 2021 (Figure 6). However, this was not a constant rate of growth
throughout the surveyed period, and the rate of growth of extra-EU
exports remained higher than intra-EU exports for years. Each change in
the direction of goods exports occurred during an economic crisis: from
2009 to 2010 and from 2020 to 2021. Nonetheless, whatever the rate of
growth, the share of intra-EU trade in the Member States’ overall foreign
exports of goods remained relatively high (over 60%, incl. 62.2% in
2021), much as it dropped to 57.5% in 2012. During the surveyed period,
intra-EU imports also markedly exceeded extra-EU imports, although to
a somewhat lesser extent than for exports. Also in this case, considerable
growth was identifi ed in 2022 versus 2004. It was, however, signifi cantly
lower, and the share of intra-EU imports fell to 57.7% in 2022 following
a gradual increase between 2013 and 2019 to 61.4%.
It follows that both intra-EU exports and imports of goods remain a vital
part of foreign trade in a majority of Member States. A particularly high
percentage (more than 70%) of intra-EU sales versus the global exports
was recorded for countries that have joined the EU since 2004, as well
76
Studia Europejskie – Studies in European Affairs, 3/2023
54%
56%
58%
60%
62%
64%
0
2 000 000
4 000 000
6 000 000
8 000 000
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Value of and relations between intra -EU and extra-EU
exports
Intra-EU export (left axis)
Extra-EU export (left axis)
Percentage of Intra EU export (right axis)
1,0
1,2
1,4
1,6
1,8
2,0
2,2
2,4
2,6
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Dynamics of intra-EU and extra-EU exports (base year -
2004)
Intra-EU export
Extra-EU export
55%
56%
57%
58%
59%
60%
61%
62%
63%
0
2 000 000
4 000 000
6 000 000
8 000 000
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Value of and relations between intra -EU and extra-EU
imports
Intra-EU import (left axis)
Extra-EU import (left axis)
Percentage of Intra -EU import (right axis)
1,0
1,2
1,4
1,6
1,8
2,0
2,2
2,4
2,6
2,8
3,0
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Dynamics of intra-EU and extra-EU imports (base year -
2004)
Intra-EU import
Extra-EU import
Figure 6. Intra-EU and Extra-EU Trade in Goods from 2004 to 2022
(in mln EUR)
Source: The author’s own calculations based on the Eurostat data.
20%
30%
40%
50%
60%
70%
80%
90%
CZ
LU
SK
HU
PL
RO
NL
PT
EE
AT
HR
BE
LV
BG
ES
SI
EU
LT
FI
FR
DK
EL
DE
SE
IT
MT
IE
CY
exports
2004 min max 2022
20%
30%
40%
50%
60%
70%
80%
90%
LU
LV
EE
SK
AT
CZ
RO
PT
HR
HU
DK
FI
PL
SE
LT
FR
DE
CY
BE
MT
EU
BG
SI
IT
ES
EL
NL
IE
imports
2004 min max 2022
Figure 7. Share of Intra-EU Trade in Global Foreign Trade of EU Member
States from 2004 to 2022
Black bar: a decrease, white bar: an increase in 2022 as compared to 2004.
Source: The author’s own calculations based on the Eurostat data.
77
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
as for smaller countries of the old EU, including, for example, Czechia,
Luxembourg, Slovakia, Hungary and Poland. By contrast, in countries
such as Italy, Sweden, Germany, Greece or Denmark and France, the share
was lower, at 53–56%. The lowest rate was registered in island states, due
to their ties with non-EU countries: Malta, Cyprus and Ireland. A similar
trend was recorded for imports of goods: the highest share of intra-EU
imports in goods in global foreign imports (more than 70%) was recorded
for Luxembourg, Latvia, Estonia, Slovakia, Austria and Czechia, and the
lowest (about 50%) for Slovenia, Italy, Spain, Greece, the Netherlands and
Ireland (Figure 7).
Transposition Defi cit
and Trade in Goods in the EU
Along with the reduction in the transposition defi cit of EU internal
market directives, intensifi cation of trade in goods is to be expected on the
ESM. For the EU as a whole, this process was encapsulated by analysing
the change in the share of intra-EU trade in the overall trade of EU
Member States. This country-by-country approach is important because
it is not the entire EU that trades with itself, rather businesses located in
individual Member States that export and import goods. This trade follows
regulations applicable for the exporter’s and importer’s country (the term
intra-EU trade refers to trade between EU Member States). Consequently,
the degree of trade intensifi cation within the EU is presumably inversely
proportional to the transposition defi cit. It follows that the greater the
conformity of national legislation with EU requirements for the internal
market, the greater the intensity of trade with other Member States
should be. At the same time, the relationship should work inversely, i.e.
the lower the percentage of correctly implemented legislation, the more
trade is obstructed, which translates into lower turnover within the EU.
To verify this hypothesis, the evolution of the transposition defi cit was
compiled with changes in the share of Member States’ intra-EU trade in
their foreign trade overall.
Several comments need to be made regarding the proposed research
solution. First, the transposition defi cit data available and presented above
refer to the number of unimplemented directives, not the degree of real
unifi cation. This is because a failure to implement a single directive can
make it signifi cantly more diffi cult or even impossible for a given product
to enter a Member State’s market. Second, the available data is aggregated
at the level of all internal market directives, and a lack of transposition, if
any, may not necessarily affect an area which directly impacts trade. On
78
Studia Europejskie – Studies in European Affairs, 3/2023
the other hand, any impediment to the recognition of qualifi cations, for
example, which results in reduced movement of workers, may prompt
reduced demand for certain goods (for example those from a country from
which workers do not come) and ultimately translate into trade decline.
Third, the identifi ed transposition defi cit did not necessarily affect trade
in a given year, as the implementation problem data concern the end of a
given year, whereas trade was ongoing throughout the year. Fourth, amid
lacking disaggregation of the transposition defi cit data, the trade data
were not aggregated for individual groups of goods either. Fifth, primarily
in the case of smaller countries, trade undergoes signifi cant fl uctuations
which are not necessarily associated with the legal situation in the target
country. Sixth, the shift in importance of intra-EU trade in the overall
foreign trade of Member States may be due to increased trade with one
or a group of third countries with which the EU has recently established
preferential trade relations.
Therefore, a decision was made nevertheless to compile data (including
those treated by simple statistical calculations) on transposition defi cit
and the share of intra-EU trade in goods in the overall foreign trade of
Member States. Since the extent to which national legislation is unifi ed
can affect trade in various ways, exports (intra-EU sales) and imports
(intra-EU acquisitions) were shown separately. In addition, the period
from 2004 to 2021 was taken as the period under review to cover the
trade of majority of current EU members (the UK was disregarded in the
calculations). Having regard for the above limitations and the comments
made, the study employed the following:
• 2021 transposition defi cit;
• change in 2021 transposition defi cit versus 2004;
• average transposition defi cit in the period 2004–2021;
• share of intra-EU exports in goods in total exports of 2021;
• change in the share of intra-EU exports in goods in total exports of
2021 versus 2004;
• average share of intra-EU exports in goods in total exports from the
period 2004–2021;
• share of intra-EU imports in goods in total imports of 2021;
• change in the share of intra-EU imports in goods in total imports of
2021 versus 2004;
• average share of intra-EU imports in goods in total imports from
the period 2004–2021.
The above shares were determined on the basis of European Commission
data included both in the Scoreboard of 2022 as well as in the Eurostat
database. In order to encapsulate the changes and in an attempt to fi nd
79
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
links between the transposition defi cit and intra-EU trade orientation,
they were disaggregated at the level of EU Member States (Table 1).
In compiling data on the level of ESM integration and EU Member
States’ trade orientation towards the European single market, it can be
concluded that the countries with the lowest values of the transposition
indicator in 2021 (less than 1%) and average values for the period 2004–
2021 include Denmark, France, Hungary and Finland, as well as Germany
(with a one-off increase of up to 9% in 2007 left aside). They typically
recorded a relatively low share of intra-EU exports in goods in their overall
foreign sales (at 53.0 to 54.6% in 2021, save for Hungary at 78%). In the
surveyed period, the values were gradually giving way to non-EU exports.
In turn, intra-EU imports are strikingly different for the countries. In this
case, the transposition leaders recorded above-average growth and the
ultimate value of the share of intra-EU acquisition versus all the foreign
imports of goods throughout the period from 2004 to 2021 under review.
This may be down to the countries’ legislation being radically adapted to
the EU requirements.
It is hard to fi nd common tendencies for those Member States which
recorded the transposition defi cit at 1–1.5% and 1.5–2% at the end of
2021. As for the exports, many countries recorded the highest shares of
intra-EU sales of goods in overall foreign exports (Slovakia, Luxembourg,
Poland, and Portugal at 71.5–80.5%), and also posted the transposition
defi cit at levels largely surpassing the political goals in place. It is also
worth noting that a share of intra-EU exports well above the EU average
was recorded for such countries as Czechia, Romania and Bulgaria (80.4%,
73.2% and 66.5%, respectively). At the same time, these countries recorded
the highest transposition defi cit (2.4%, 2.9% and 2.2%, respectively).
In posting above an average transposition defi cit, the above-mentioned
countries with high intra-EU exports were joined by those for which the
EU market was not as important as exports to non-EU partners (in the
case of Cyprus, it accounted for only 27.8% of all foreign sales, Ireland –
28.1%, for Sweden and Greece – about 53% each).
The case is somewhat different for imports. Countries with the lowest
transposition defi cit at the end of 2021, as well as its value over the
2004–2021 period, being average (allowing for the comments made above
regarding Germany), also recorded an above average share of intra-EU
imports in their total imports of goods. However, the highest reliance
on intra-EU acquisition was recorded by countries such as Luxembourg
(88.7%), Slovakia (78.2%), Austria (76.4%), Czechia (73.7%), Latvia
(73.2%) and Romania (72.5%), whose 2021 transposition defi cit exceeded
not only 1%, but 2% at times. Consequently, although the fi rst group of
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Studia Europejskie – Studies in European Affairs, 3/2023
countries could hint at a link between low transposition defi cit and a high
share of EU imports in these countries’ global imports, the other group
is completely random and it is diffi cult to fi nd a clear link between these
indicators.
Conclusions
This study makes it possible to formulate several conclusions and
recommendations for further analysis. First, during the period under
review, a general increase in transposition defi cit was recorded with a
concomitant increase in conformity defi cit. This means that, in principle,
Member States poorly transpose and implement EU internal market
legislation. No genuine efforts at the national level to ensure harmonisation
of laws follow the political guidelines of the European Council on the role
of the single European market. With the single European market in place
for thirty years, there is no clear demarcation line between the best and
worst performers of EU membership obligations, i.e. transposing EU
legislation into national law. In the subsequent years of the analysed period,
the composition of groups of countries with the highest and the lowest
indicators varied. Both of these groups included the countries that joined
the EU somewhat later and the founders of the EU and ESM. Both of these
groups include countries big and small, of the South and North, or West
and East, as well as those of a better or worse level of development, more and
less affl uent. With not only transposition defi cit, but also the conformity
indicator being relatively high, progressive market fragmentation ensued.
In response to this, the nature of the single European market legislation
is gradually changing. Instead of directives requiring transposition and
implementation, the European Commission is increasingly proposing
regulations directly applicable in all Member States.
In this way, the traditional internal market model based on directives
requiring transposition and implementation in the Member States as an
element of harmonization (i.e., the elimination of signifi cant differences
between Member States’ laws), is gradually being abandoned. In addition
to the aforementioned weaknesses of having to implement EU legislation
into national legislation, it turns out that the directives do not in fact
leave, as previously thought, “space” for interpretation and adaptation
of national law with regard to the substantive issues. Consequently, the
Member States, albeit not blatantly, are increasingly embracing both the
swap of existing directives for regulations (e.g., on technical provisions
and product safety), as well as the regulations governing new areas of
economic activity (roaming, digital commerce).
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
Contrary to the negative results of legislative transposition, the
shares of intra-EU exports and imports in goods in total foreign sales
of EU Member States are relatively high. This means that the relative
harmonization currently underway to unify laws ensures that products
from other Member States are included. However, the relationship
between the compatibility of national regulations with EU law and the
geographic orientation of trade in goods cannot be clearly identifi ed.
In the former case, this may be due to the internal market for EU goods
being free, as a rule, from major barriers, while those barriers that exist
do not affect trade so much (much as it may slightly vary for individual
goods). In addition, the value of intra-EU trade in goods continues to
grow, and increasing trade with non-EU countries means a gradual
improvement in the competitiveness of European goods and, thanks to
EU trade policy, entry into new markets.
In order to more precisely encapsulate the link between the transposition
of EU legislation, that is the openness of Member State economies to
entities from other EU countries, data disintegration and analysis would
be necessary for individual areas of legislation, groups of goods.
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Studia Europejskie – Studies in European Affairs, 3/2023
ANNEX
Table 1. Trade Defi cit and Shares of Intra EU Trade in Goods
in 2004–2021
Transposition defi cit Share of intra EU export
in total export
Share of intra EU export
in total export
2021
Change
2021–
2004
Aver-
age
2004–
2021
2021
Change
2021–
2004
Average
2004–
2021
2021
Change
2021–
2004
Aver-
age
2004–
2021
DK 0.40 -1.90 0.51 53.0% -9.15 56.9% 68.0% 3.11 65.9%
DE 0.40 -2.10 1.37 54.3% -2.37 53.7% 63.7% 3.98 60.5%
FR 0.60 -2.60 0.91 54.6% -2.09 54.1% 66.0% 3.35 63.8%
HU 0.70 -1.30 0.83 78.1% -0.63 76.3% 71.2% 5.18 70.0%
FI 0.80 -1.50 0.83 56.2% 5.06 52.1% 69.7% 6.93 64.3%
MT 1.10 -4.90 0.77 48.1% 10.01 42.2% 59.7% -1.76 60.6%
EE 1.20 -3.80 1.02 67.0% -9.57 68.4% 72.0% 0.53 75.7%
IT 1.20 -3.30 1.44 52.7% -2.82 52.2% 56.7% -1.68 55.0%
SI 1.20 -2.00 1.19 67.7% -6.78 73.4% 56.0% -28.03 70.6%
PT 1.40 -1.80 1.44 71.5% 0.99 69.1% 73.6% 1.12 72.7%
SK 1.40 -4.90 0.92 80.5% -3.78 81.1% 78.2% 0.99 75.5%
PL 1.50 -1.40 1.50 75.0% -0.21 72.9% 66.4% -5.60 68.4%
EU 1.60 -2.00 1.12 61.2% -0.24 59.8% 61.4% -0.09 60.1%
HR 1.60 1.60 0.87 67.4% 2.79 62.1% 74.3% 5.24 69.0%
NL 1.60 -0.40 0.84 69.4% -0.45 68.2% 41.2% -5.62 41.6%
LT 1.70 0.70 0.66 57.6% -4.33 56.6% 68.5% 7.33 61.9%
CY 1.80 -2.60 1.51 27.8% -17.08 45.7% 64.5% 3.99 59.6%
EL 1.80 -3.30 1.46 53.8% -5.28 52.1% 51.6% -7.72 52.4%
LU 1.80 -2.40 1.79 80.8% -1.00 79.1% 88.7% 14.12 77.4%
AT 1.90 -0.40 1.22 69.1% -1.52 68.6% 76.4% -5.24 76.7%
LV 2.00 -5.00 1.06 63.7% -1.07 63.8% 73.2% -0.52 75.2%
SE 2.00 0.00 0.79 53.7% 2.16 51.9% 66.4% 1.27 64.0%
BG 2.20 2.20 0.91 66.5% 6.32 61.4% 60.5% 5.74 59.5%
IE 2.20 -0.20 1.07 38.1% -6.85 41.6% 38.0% 8.27 33.5%
ES 2.20 0.90 1.23 62.1% -3.37 60.8% 54.6% -6.98 55.4%
CZ 2.40 -7.20 1.81 80.4% -2.64 79.5% 73.7% -3.71 74.9%
BE 2.80 -0.60 1.58 66.7% -1.76 65.7% 62.6% -3.35 62.1%
RO 2.90 2.90 1.10 73.2% 4.33 69.4% 72.5% 9.67 70.3%
Source: The author's own calculations based on EC (2023) and Eurostat.
83
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
References
Ambroziak, A.A. (2012) “Bilans dwudziestolecia istnienia rynku
wewnętrznego Unii Europejskiej – aspekty wdrażania legislacji
unijnej”, Studia Europejskie. Vol. 64(4), pp. 51–78.
Ambroziak, A.A. (2013) “Handlowe skutki ewolucji prawa swobodnego
przepływu towarów. Bilans dwudziestolecia istnienia rynku
wewnętrznego UE”, Studia Europejskie. Vol. 65(1), pp. 75–100.
Ambroziak, A.A. (2021) “Does the European Single Market Exist in
the Era of a Coronavirus Pandemic? The Case of Intra and Extra-EU
Trade in COVID-19-related Products”, Studia Europejskie – Studies in
European Affairs. Vol. 25(1), pp. 63–83. DOI: 10.33067/SE.1.2021.3.
Ambroziak, A.A. (2022) Poland’s State Aid Policy During the COVID-19
Outbreak in Ambroziak, A.A. (ed.) Poland in the European Union. Report
2022. Warsaw: SGH Publishing House, pp. 39–78.
Berglund, S., Gange, I. and van Waarden, F. (2006) “Mass production of law.
Routinization in the transposition of European directives: a sociological-
institutional account”, Journal of European Public Policy. Vol. 13, pp.
692–716. DOI: https://doi.org/10.1080/13501760600808550.
Borghetto, E., Franchino, F. and Giannetti, D. (2006) “Complying with
the transposition deadlines of EU directives: evidence from Italy”,
Rivista Italiana di Politiche Pubbliche. Vol. 5, pp. 7–38.
De Coninck, I. (2015) Transposition of European legislation: Flemish and
Scottish performance, Working Paper No 1. Available at: https://www.
ippapublicpolicy.org/fi le/paper/1434093631.pdf (Access 1.05.2023).
EC (1997a) Draft Action Plan for the Single Market, COM(97) 184 fi nal,
Brussels, 6.05.1997.
EC (1997b) Single Market Scorebord, No 1, November 1997, Brussels.
EC (1998) Single Market Scorebord, No 2, May 1998, Brussels.
EC (2000) Single Market Scorebord, No 7, November 2000, Brussels.
EC (2001) Single Market Scorebord, No 9, November 2001, Brussels.
EC (2004) Single Market Scorebord, No 13, July 2004, Brussels.
EC (2005) Single Market Scorebord, No 14, July 2005, Brussels.
EC (2011) Single Market Act. Twelve levers to boost growth and strengthen
confi dence. “Working together to create new growth”, COM(2011) 206
fi nal, 13.04.2011, Brussels.
EC (2015) Single Market Scorebord, Performance per governance tool,
Reporting period: 5/2014–11/2014. Available at: https://single-market-
scoreboard.ec.europa.eu/enforcement-tools/transposition_en (Access
6.05.2023).
EC (2017) Single Market Scorebord, Performance per governance tool,
Reporting period: 12/2015–12/2016. Available at: https://single-
84
Studia Europejskie – Studies in European Affairs, 3/2023
market-scoreboard.ec.europa.eu/enforcement-tools/transposition_en
(Access 6.05.2023).
EC (2023a) Single Market Scorebord, Performance per governance
tool. Available at: https://single-market-scoreboard.ec.europa.eu/
enforcement-tools/transposition_en (Access 6.05.2023).
EC (2023b) The Single Market at 30, COM(2023)162 fi nal, Brussels.
EUCO (1993) Presidency Conclusions, 21–22 June 1993.
EUCO (1996) Presidency Conclusions, 13–14 December 1996, Dublin.
EUCO (1997) Presidency Conclusions, 17–18 June 1997, Amsterdam.
EUCO (2001) Presidency Conclusions, 23–24 March 2001, Stockholm.
EUCO (2002) Presidency Conclusions, 15–16 March 2002, Barcelona.
EUCO (2003) Presidency Conclusions, 20–21 March 2003, Brussels.
EUCO (2004) Presidency Conclusions, 25–26 March 2004, Brussels.
EUCO (2007) Presidency Conclusions, 8–9 March 2007, Brussels.
EUCO (2023) Conclusions, EUCO 4/23, 23 March 2023.
Howarth, D. (2022) The increasingly differentiated European Single Market?
in Leruth, B., Ganzle, S. and Trondal, J. (eds.) The Routledge Handbook
of Differentiation in the European Union. Routledge, pp. 391–407. DOI:
https://doi.org/10.4324/9780429054136-27.
Haverland, M. and Romeijn, M. (2007). “Do member states make
European policies work? Analysing the EU transposition defi cit”,
Public Administration. Vol. 85(3), pp. 757–778. DOI: https://doi.
org/10.1111/j.1467-9299.2007.00670.x.
Kaeding, M. (2006) “Determinants of transposition delay in the European
Union”, Journal of public Policy. Vol. 26(3), pp. 229–253. DOI: https://
doi.org/10.1017/s0143814x06000547.
Kaeding, M. (2008) “Lost in translation or full steam ahead: the
transposition of EU transport directives across member states”,
European Union Politics. Vol. 9(1), pp. 115–143. DOI: https://doi.
org/10.1177/1465116507085959.
Kuczewska, J. and Stefaniak, J. (2022) Implementacja programu
rynku wewnętrznego Unii Europejskiej z uwzględnieniem efektów dla
przedsiębiorstw in Gorynia, M., Kuczewska, J. and Nowak, A.Z. (eds.)
Polskie przedsiębiorstwo na jednolitym rynku europejskim: wyzwania
współczesności. Warszawa: Polskie Wydawnictwo Ekonomiczne, pp.
25–44. DOI: https://doi.org/10.31338/uw.9788323553489.pp.75-86.
Laursen, K. (1998) Revealed comparative advantage and the alternatives as
measures of international specialisation, Danish Research Unit for Industrial
Dynamics (DRUID). Working Paper No 98–30. Aalborg: Copenhagen
Business School and Department of Business Studies, Aalborg
University.
85
A.A. Ambroziak, Integration of the European Single Market Thirty Years...
Michelsen, J. (2008) “A Europeanization defi cit? The impact of EU
organic agriculture regulations on new member states”, Journal of
European Public Policy. Vol. 15(1), pp. 117–134. DOI: https://doi.
org/10.1080/13501760701702256.
Moriana, V.F., Vida, A.M. and De Lombaerde, P. (2017) The European
Commission Single Market Scoreboard in De Lombaerde, P. and Saucedi
Acosta, E.J. (eds.) Indicator-Based Monitoring of Regional Economic
Integration: Fourth World Report on Regional Integration, No. 13, pp.
3–26. DOI: https://doi.org/10.1007/978-3-319-50860-3_1.
Lazar, C. and Lazar, M. (2015) “Perceptions of good governance in Romania
through statistical indicators”, Journal of Law and Administrative
Science, Vol. 441.
Musiałkowska, I. (2017) “Implementation of European Union law in
Poland”, Common Values. December, pp. 179–192. DOI: https://doi.
org/10.5771/9783845284774-179.
Pircher, B. and Loxbo, K. (2020) “Compliance with EU Law in Times of
Disintegration: Exploring Changes in Transposition and Enforcement
in the EU Member States between 1997 and 2016”, Journal of Common
Market Studies. Vol. 58(5), pp. 1270–1287. DOI: https://doi.org/10.1111/
jcms.13030.
Ručinská, S. and Fečko, M. (2019) “European Union Internal Market
and its barriers: mission accomplished or never ending story?”, Online
Journal Modelling the New Europe. Vol. 29, pp. 25–52. DOI: https://doi.
org/10.24193/ojmne.2019.29.02.
Steunenberg, B., and Rhinard, M. (2010) “The transposition of European
law in EU member states: Between process and politics”, European
Political Science Review. Vol. 2(3), pp. 495–520. DOI: 10.1017/
S1755773910000196.
Sverdrup, U. (2004) “Compliance and confl ict management in the
European Union: Nordic exceptionalism”, Scandinavian Political
Studies. Vol. 27(1), pp. 23–43. DOI: https://doi.org/10.1111/j.1467-
9477.2004.00098.x.
Toshkov, D. (2008) “Embracing European law: compliance with EU
directives in Central and Eastern Europe”, European Union Politics. Vol.
9(3), pp. 379–402. DOI: https://doi.org/10.1177/1465116508093490.
