This chapter considers competition policy within the context of different varieties of capitalism: the free, hierarchical, and coordinated market models. Specifically, it discusses American, German, and French competition policy in relation to these three traditions. It first focuses on American competition policy and the free market tradition. Since competition policy by its very nature limits the freedom of market participants and leads to a larger government, it seems a priori at odds with the free market philosophy. The chapter argues, however, that competition policy is consistent with the free market model when the free market would effectively disappear without these rules of competition and shows that politicians involved in the development of the American competition law framework considered this possibility real.

The chapter then proceeds with German and French competition policy, both of which are discussed in connection to the hierarchical and coordinated market traditions. It is shown that these policies initially fitted well within the hierarchical framework but became more consistent with the coordinated market model during the last decades. This chapter argues that this transformation is not (yet) complete in the sense that both competition policies still provide scope for direct government intervention in merger cases.