ABSTRACT

In the 1970s, both Britain and Japan experienced large-scale reforms of competition law. In Britain, the Office of Fair Trading (OFT), a quasi-independent body engaged in the administration of British competition policy, was newly established under the framework of the Fair Trading Act (FTA) in 1973. In Japan, attempts were made to strengthen the Anti-monopoly Act (AMA) by means of legislative change in 1977, which was the first such change in the history of Japanese competition law. It is important to keep in mind that these cases represent the invention-type policy innovation, rather than the transfertype policy innovation. The idea of harmonisation with international standard practices failed to gain much support, and the policy output was not seen as the result of policy transfer from other jurisdictions.