The perception of growing compliance problems in the late 1980s, and the anticipation of further strains from the internal market program, propelled the Commission and the ECJ into action. As Claus-Dieter Ehlermann, then director-general of the Commission’s Legal Service, explained in a speech in 1986:

Actually, there will be no such area without internal frontiers if Community rules are not applied effectively in all the 12 Member States. Inevitably, therefore, the establishment of the internal market involves . . . the setting up of systems of control to ensure the full compliance of all Member States with Community legislation governing the internal market.

(Ehlermann 1988: 144-5)