National tunes and a European melody? Competition law reform in the UK and Germany

This article examines domestic policy responses to processes of 'Europeanization' by discussing recent reforms in competition law in the UK and Germany. The article argues that the concept of 'lesson-drawing' can be usefully employed in the discussion policy reforms which use as their referent a 'European model'. The article provides a detailed account of the reform processes and investigates the extent of Europeanization in policy content. It is suggested that while the 'tunes' of competition policy may have become more similar, they remain nationally distinct. The analysis finally offers some suggestions about lesson-drawing.