Discretion in European merger control: The German regime in context

Abstract
Merger control is used in this article to illustrate the exercise of discretion in economic regulation. It suggests that discretion is unavoidable and examines the various modes of discretion exercised by institutions such as the Bundeskartellamt and Directorate‐General IV of the European Union. It argues that institutions should be structured to deploy discretion productively and to modify both legal and economic modes of analysis. Four elements in the article can be stressed. First, it provides an analysis of the important and under‐emphasized area of German merger control; secondly, it offers a comparative critique of the operation of German policy; thirdly, it suggests that an impoverished European theory of regulation could benefit from a transfusion of American concepts and, fourthly, it provides a sceptical perspective on current proposals for reform of EC competition policy institutions.

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