ABSTRACT
At the end of the first decade of the twenty-first century, U.S. federal regulation was gathered in the United States Code, the register of all U.S. federal regulation. In Europe, community regulation was gathered in the Directory of Community Legislation (Government Printing Office 2009; European Communities 2010). In the U.S. as in Europe, this regulation constituted the minimum requirement that must be respected by all the parties (the states in the U.S., and the various members of the EU). This meant that individual states in the U.S. and individual EU members in the EU might have additional regulations if they wished, but must comply with the existing regulation. In the EU, the acceding member states (in 2011, the EU consisted of twenty-seven member states) had the obligation to fully and correctly transpose and implement the ‘acquis communautaire’ (the EU acquis) by the date of accession so as to guarantee equivalent rights and obligations to all citizens of the enlarged European Union. The ‘acquis communautaire’ amounted to some 1,600 directives. Beginning from the date of accession, the acceding countries were monitored in the same way as the previous member states, and monitoring and compliance updates were published at regular intervals (European Commission 2004). Eur-Lex, the portal to European Union law (https://europa.eu.int/eur-lex/en/index.html" xmlns:xlink="https://www.w3.org/1999/xlink">https://europa.eu.int/eur-lex/en/index.html) also provided studies and statistics concerning the application of community law in member states. In the U.S., individual states must follow federal regulation more or less in the same manner and, on the whole, both systems worked in a fairly similar fashion.
