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FRBSF

WEEKLY LETTER

Number 93-09, March 5, 1993

A Single Market for Europe?
January 1, 1993 marked the scheduled completion date of the European Community's Single
Market Program, an ambitious plan to remove
most of the remaining internal barriers to trade
among its current twelve member countries. The
new year was awash with stories heralding the
removal of border check points within the Community and of happy Europeans traveling across
national borders to take advantage of shopping
bargains. But how far has the Single Market Program proceeded? Is Europe now operating as a
single integrated market encompassing roughly
350 million consumers and a quarter of the
world's economic output? This Letter gives an
update of the progress of the Single Market
Program.

Single European Act
The achievement of closer economic integration
has been a long-term goal of the member countries of the European Community (EC) since its
establishment in 1958. Significant progress toward this goal was achieved in 1968 with the full
elimination of tariff and quantitative restrictions
to trade in goods and services within the EC. A
program for eliminating all remaining restrictions
on intra"Community movements of goods, capital, and labor was presented in the 1985 White
Paper Report "Completing the Internal Market"
and subsequently incorporated into the EC Treaty
via the Single European Act. The program proposed almost 300 specific steps or directives
designed to help create a single European market
by eliminating physical barriers (such as customs
and passport border controls), technical barriers
(such as product, health, and safety standards),
and fiscal barriers (such as different taxation, subsidy, and public procurement policies) among
member countries with a target date of completion by the end of 1992.
Why the desire for a single market? The foremost
reason is the economic efficiency benefit such a
market would provide. Reduced physical, technical, and fiscal barriers to cross-border trade
should improve resource allocation and lower
operating costs within the EC. A report prepared
for the European Commission (the Cecchini Re-

port) in 1988 estimated that the internal market
program would raise the EC's level of output by
2.5-6.5 percent compared to what would otherwise have happened. Other estimates taking a
more dynamic perspective suggested that growth
rates might be permanently increased by firms
operating with larger scale economies in a unified
market, and indicated a medium-term GNP effect
roughly double the Cecchini estimate within
10 years of completion of the internal market.
Needless to say, there is little consensus among
analysts over the ultimate growth effects from the
single market program, but most view them as
fairly substantial.
Another anticipated benefit of greater market
integration is enhanced global competitiveness.
Improved resource allocation and economies of
scale should allow European Community-based
firms to compete more effectively with their
North American and Japanese counterparts.
Awareness of the competitive advantages associated with a large home market provided to
American and Japanese firms has been fundamental to the support of European business for
the internal market program.
In addition, many believe that closer market integration will encourage stronger political relationships among members, a long-term goal of the
founders of the European Community. The Maastricht Treaty drafted in December 1991 seemed
to confirm this view, as far-reaching common
ground was reached on issues ranging from an
EC defense policy to a single central bank.
Of course, the transition toward a single market
is not without costs. The opening of national borders is expected to result in the widespread relocation of firms and workers within the EC. Indeed,
the achievement of economies of scale in production entails the concentration of production
facilities. More competition also may mean fewer
firms in any given industry for the EC as a whole.
In addition, as long as national differences in tax
rates and labor costs remain, resource movements are likely to increase as it becomes easier
for firms to search for low-cost production sites,

FABSF
for workers to look for high-paid jobs, and for
consumers to seek !ow tax rates on purchases.

Progress to date
By the beginning of this year, the EC Council of
Ministers had formally adopted 95 percent of the
directives suggested in the 1985 White Paper for
market integration. At the national level, most of
the adopted directives have been implemented
into law, ranging from Denmark's 81 percent implementation rate to Italy's 73 percent rate. Although not meeting the January 1st goal for all of
the directives, the steps taken so far represent a
considerable achievement. Many trade barriers
have been removed, while others have either been
reduced or are soon scheduled to fall, and the
effects are being felt throughout Europe.
Perhaps most striking is the removal of border controls for travel within the EC. Cargo trucks carrying.
goods which used to stop for time-consuming
administrative checks at each border-crossing now
in principle may drive from Denmark to Portugal as
easily as one may travel from New York to California. Administrative formalities are now handled
at the beginning and end of transport journeys.
Cross-border shoppers are able to take home virtually unlimited quantities of goods for personal
consumption as long as they pay the value-added
tax (VAT) and excise duties where the goods are
bought. With prices on such products as electronic
goods, clothing, and food varying as much as
50 percent from one country to another, incentives for cross-border shopping abound.
The cross-border flow of goods also has been
promoted by the recent adoption of a Common
Customs Code that standardizes and streamlines
customs procedures and by significant progress
toward the harmonization of safety, health, and
environmental product standards. This helps facilitate the import of goods from third countries.
By accepting each other's technical and product
safety standards, once a product enters the EC
it may in principle be transported freely into all
twelve member states.
The elimination of border controls also applies
to services, capital, and people. Controls on the
movement of capital, such as bank deposits,
bonds and stocks, and so on, were in large part
eliminated by mid-1990 in most EC countries.
Exceptions were granted to Greece and Portugal
until 1995. Troubles in Europe's exchange rate
mechanism last fall led Spain and Ireland to in-

voke an escape clause and temporarily reimpose
some exchange restrictions. (See the Weekly Letter of October 16, 1992.)
EC members have agreed that banks can nowoperate throughout the Community on the basis of a
single "passport" issued by their home-country
regulator. The introduction of single operating
licenses should facilitate greater competition for
financial services and provide consumers a larger
selection of products and service providers. Consumer benefits will be greatest in countries where
banking markets are currently relatively less
competitive, for example, Belgium and Italy.

Shortcomings
Market integration is well short of being complete.
For example, the goal of unrestricted travel is yet to
be achieved. Residents and visiting foreigners traveling within the Community will have to present
passports at airports until December 1994. The
U.K., Ireland, and Denmark intend to make passport and baggage checks beyond this date.
A number of exceptions or delays in implementation to market integration have been granted to
various industries. Perhaps most visible are the
exceptions in the automobile industry. Currently,
European car prices vary enormously, by as much
as 50 percent, because of national tax rate differences, exclusive dealership practices, and
remaining document requirements and technical
standards that inhibit cross-border importing of
cars. While Community law says the consumers
should be free to buy goods in any EC country at
local prices, automobiles (as well as boats and
aircraft) are covered by a separate law where
consumers will continue paying taxes at the rate
charged by the importing, not the selling, ECmember country. Moreover, exclusive dealerships
which give automobile manufacturers greater influence over dealer pricing will continue to be
allowed at least until 1995. In addition, an ECJapan agreement which allows a phased-in opening of the single market to Japanese automobiles
between 1993 and 2000 is already being questioned by Italy, which has largely closed its border to the importation of Japanese automobiles
from other EC-member countries.
In the financial arena, there are also delays in
implementation. Common licensing of insurance
companies is not scheduled until mid-1994; for
investment and stock brokerage firms, not until
1996. Moreover, the branches of foreign banks
will not be allowed access to stock exchanges
in Spain, Portugal, and Greece until 1999.
The EC also has a long way to go before it ends
state monopolies and allows cross-border com-

petition in such traditionally protected sectors as
telecommunications, postal, and energy services.
A telephone call that crosses a national border
within the EC costs on average three times more
than a call over the same distance inside a single
country. There is no single EC electric plus or
phone jack, let alone a television broadcast
standard.

There are other areas in which the need for action
at the EC level remains. For example, company
law and intellectual property rights are remaining
issues which are not likely to be resolved soon.
Thus, for example, there are no common rules on
establishing an EC corporation or on attempting
a hostile takeover, nor is there? common trademark standard.

Progress toward fiscal harmonization, particularly
of taxation, generally has been slower than the
removal of physical and technical barriers. Disputes about taxation policies are by their nature
often pol itically contentious because they may
reflect differences in social and economic philosophy and can be perceived as limiting national
sovereignty and discretionary policymaking.
Moreover, under current EC rules agreements on
taxation require unanimity among all EC members, unlike the case in most other areas affected
by the Single Market Program.

On balance, great strides have been taken toward
a unified single European market. However, there
is still the need to translate all EC directives which
have been accepted at the Community level into
national law. To prod governments and speed up
the process of implementing the EC directives
into national law, the EC Commission is considering starting emergency complaint proceedings before the European Court of Justice on any directive
where a member state has not met the January 1
deadline.

Nonetheless, in an attempt to limit tax flight
through cross-border shopping, minimum valueadded tax rates (VAT) have been agreed upon in
the EC, effectively narrowing national differences.
But divergences remain large: Germany, Spain,
and Luxembourg maintain the minimum VAT rate
of 15 percent, in-effect since January 1, while
Denmark maintains the highest rate in the EC at
25 percent. To avoid losing tax revenue, Denmark
as passed controversial laws restricting its residents from purchasing goods in Germany. Similarly, postal mail-order business in the EC has become more, not less, restrictive in an attempt to
avoid tax flight in responseto VAT rate differentials.
In the case of corporate income taxes, there also
has been some convergence. Most countries
maintain corporate tax rates between 33 percent
(U.K.) and 40 percent (Ireland). Efforts are underway to eliminate the withholding of taxes on
cross-border payments and ending double taxation on distributions to their parent firms in other
member states. Pressures may build for more
convergence of both VAT and corporate tax rates
if tax flight proves to be a major problem. In addition, pressure for tax convergence may arise
from the governments of those countries with relatively high expenditure and debt levels, such as
Italy, Belgium, and Greece.

Outlook

The success of the single market program also
will depend on the power to enforce single market rules. Currently, governments that violate
single market rules can be taken to the European
Court, but enforcement power is limited. Numerous court rulings against EC Qovernments
remain unenforced~ Th~ Maast;icht Tr~~ty,-i(rati­
fied, would enhance Court enforcement powers
by allowing it to levy fines on national governments. Ultimately the directives agreed to and
the laws passed are only as good as the willingness of governments to live up to the spirit, as
well as the letter, of a barrier-free internal European market. Experience shows governments
worldwide are enormously creative in circumventing those parts of international agreements
that are unpopular at home. Many politically difficult steps lie ahead if EC governments are to
integrate their economies fully into a unified
market.

Reuven Glick
Assistant
Vice President

Michael Hutchison
Visiting Scholar and
Associate Professor,
University of California,
Santa Cruz

Opinions expressed in this newsletter do not necessarily reflect the views of the management of the Federal Reserve Bank of
San Francisco, or of the Board of Governors of the Federal Reserve System.
Editorial comments may be addressed to the editor or to the author.... Free copies of Federal Reserve publications can be
obtained from the Public Information Department, Federal Reserve Bank of San Francisco, P.O. Box 7702, San Francisco 94120.
Phone (415) 974-2246, Fax (415) 974·3341.

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Index to Recent Issues of FRBSF Weekly Letter

AUTHOR

DATE NUMBER TITLE
92-31
92-32
92-33
92-34
92-35
92-36
92-37
92-38
92-39
92-40
11120 92-41
11127 92-42
12/4 92-43
12/11 92-44
12125 92-45
93-01
1/1
93-02
1/8
1/22 93-03
1/29 93-04
93-05
2/5
2/12 93-06
2/19 93-07
2/26 93-08

9/11
9/18
9/25
10/2
10/9
10/16
10/23
10/30
11/6
11/13

Pegging, Floating, and Price Stability: Lessons from Taiwan
Budget Rules and Monetary Union in Europe
The Slow Recovery
Ejido Reform and the NAFTA
The Dollar: Short-Run Volatility and Long-Run Adjustment
The European Currency Crisis
Southern California Banking Blues
Would a New Monetary Aggregate Improve Policy?
Interest Rate Risk and Bank Capital Standards
Banking
NAFTA and
A Note of Caution on Early Bank Closure
Where's the Recovery?
Diamonds and Water: A Paradox Revisited
Sluggish Money Growth: Japan's Recent Experience
Labor Market Structure and Monetary Policy
An Alternative Strategy for Monetary Policy
The Recession, the Recovery, and the Productivity Slowdown
Banking Turnaround
Competitive Forces and Profit Persistence in Banking
The Sources of the Growth Slowdown
GOP Fluctuations: Permanent or Temporary?
The Twelfth District Agricultural Outlook
Saving-Investment Linkages in the Pacific Basin

u.s.

u.s.

Moreno
Glick/Hutchison
Throop
Schmidt/Gruben
Throop
Glick/Hutchison
Zimmerman
Motley
Neuberger
Laderman/Moreno
Levonian
Cromwell /Tren hoime
Schmidt
Moreno/Kim
Huh
MotleY/Judd
Cogley
Zimmerman
Levonian
Motley
Moreno
Dean
Kim

The FRBSF Weekly Letter appears on an abbreviated schedule in June, July, August, and December.