Commercial Law - Importation of Chemicals - European Law - New EC Regulations

The case of Mebrom MV v European Commissionimporters; and
[2007] concerned the importation of pesticides. The- Limiting imports of methyl bromide on a case by
applicant was an importer of the chemical methylcase basis, thus preventing importers from building up
bromide into the European Union. Methyl bromide wasstocks.
a pesticide applied to crops by fumigation and as itThe interpretation therefore gave practical effect to
depleted the ozone layer, its importation was subjectthose provisions and ensured that they were applied
to restrictions provided by Council and Europeancoherently and in a manner that corresponded to the
Parliament Regulation (EC) 2037/2000 ("theoverall scheme and the objectives of the Regulation.
Regulation"). The Regulation concerned substancesThe overall objectives of the Regulation sought to
which deplete the ozone layer.limit the production and use of methyl bromide in
Articles 3 and 4 of the Regulation imposedorder to protect the ozone layer.
restrictions on the production, use, marketing andIt followed that the European Commission was not
selling of methyl bromide. Articles 6 and 7 of theobliged under the Regulation to award an import
Regulation created a system of licences and quotasquota in 2005 to the applicant as an importer. It was
for the chemical's importation and free circulation.also held that the new system established by the
Each year importers applied for import quotas for theEuropean Commission constituted a lawful application
following year, and pursuant to that system theof Articles 3, 4, 6 and 7 of the Regulation that was
applicant had been awarded quotas from 1996 tocompatible with those provisions.
2004. However, in 2004, the European CommissionSecondly, according to settled authority the right to
changed the system. According to the new system,freedom to pursue a trade or profession was not
the fumigators now had to request authorisation toabsolute but should be viewed in relation to its social
import or produce methyl bromide, before requestingfunction. Its exercise might therefore be restricted,
importers, such as the applicant, to actually importprovided that such restrictions corresponded to
the amount of methyl bromide granted under theobjectives of general interest pursued by the
licence.European Community. It is also important that the
In addition to this, importers were no longer entitledtrade or profession did not constitute, with regard to
to import quotas from the 1st of January 2005the aim pursued, a disproportionate and intolerable
onwards, as well as being prevented from building upinterference which infringed upon the very substance
stocks. Accordingly, the European Commissionof the rights thus guaranteed.
adopted a decision refusing the applicant a quota forIn this case, the new system introduced by the
the year 2005.European Commission simply changed the
The applicant brought an action to annul that decisioncircumstances in which methyl bromide was imported
in the Court of First Instance of the Europeanand did not mean that the applicant was obliged to
Communities. It submitted the following arguments:cease trading. Furthermore, it did not lead to a
- Firstly, that the European Commission haddistortion of the competition in the market, since
misapplied the legal framework established in theimporters were not prevented from competing with
Regulation;fumigators for the importation and sale of methyl
- Secondly, that the Regulation obliged the Europeanbromide.
Commission to grant it a quota; andEven if the new system were to be regarded as a
- Thirdly, that the new system would oblige currentrestriction, the general public interest pursued by the
importers to close their businesses, since they wouldEuropean Community was the protection of the
be excluded from the new system of importation,ozone layer and any restriction there might be was
which would be at odds with the freedom to pursuejustified by the fact that it was imposed in application
a trade.of the Regulation, with which it was consistent. It
The action was dismissed.could not be regarded as disproportionate, intolerable
Firstly, in view of the restrictions on the production,or as infringing upon the very substance of that right
use and placing on the market of methyl bromidesince the applicant could continue to pursue its
imposed by Articles 3 and 4 of the Regulation, itprevious economic activities, albeit in a different way.
followed from the overall scheme of the RegulationPlease contact us for more information on assessing
that the purpose of Articles 6 and 7 was to ensuredamages due under termination of a contract at Visit
that the importation of methyl bromide did not go
beyond what was strictly necessary for the critical© RT COOPERS, 2007. This Briefing Note does
uses specifically identified.not provide a comprehensive or complete statement
The European Commission's interpretation of Articlesof the law relating to the issues discussed nor does it
3, 4, 6 and 7 of the Regulation achieved theconstitute legal advice. It is intended only to highlight
following:general issues. Specialist legal advice should always be
- No longer any allocation of import quotas tosought in relation to particular circumstances.