Varieties of regional integration: the EU, NAFTA and Mercosur

Abstract:

The closing of the twentieth century witnessed the proliferation of regional trade areas: a reinvigorated EU became one of almost 170 integration efforts. The first comparative analyses have suggested that these RTAs, despite sharing broadly similar objectives, are remarkably different projects. This article contributes to these works by examining two under-explored dimensions of variation: the laws of RTAs and how organizations - in particular interest groups, businesses and national administrations - have adjusted to their new legal environments. The article then suggests that the observable variation is likely to endure: the legal systems of RTAs reflect institutional realities in the member states, especially local legal traditions and power arrangements. The analysis focuses on the EU, NAFTA and Mercosur, using evidence from three realms: working women, dairy products and labour rights. The article concludes with some reflections on cross-RTA trade and the possibility of future convergence, competitiveness and the function of regulation in RTAs.