 So good evening everybody. We're about to make a start just waiting for participants to come in. Good evening and welcome to today's Center for European Legal Studies evening seminar. I'm very happy to welcome you all. My name is Alicia Narejos and I'm delighted to welcome our speaker today, Professor Anna Bradford from Columbia Law School, who needs no introduction really, but here it goes. She's Henry L. Moses, Professor of Law and International Organizations at Columbia, and also Director of its European Legal Studies Center. She's an expert in international trade law, EU law and comparative and international competition law. And as you know, she's going to talk to us today about a wonderful book that she's written on the Brussels Effect. Now the book appeared this year in 2020, but the Brussels Effect is a term that she coined some time ago and that has become widely used and influential in the literature. So we are really looking forward to what she's going to say to us. She will speak for about half an hour or so. And then hopefully she'll have time at the end to answer your questions. Can I just remind everybody that as usual, it will be good if you could write your questions in the Q&A rather than the chat for our speaker. And here we go. That's all from me. Thank you so much to our speaker for taking the time. Professor Bradford, over to you. Thank you so much. Thank you for having me and many thanks everyone for tuning in. So let me start maybe by describing why I wrote the book. So the Brussels Effect is my response to this conversation that portrays the EU as an increasingly irrelevant, weak and declining entity whose best days are over and that has very little ability to influence the world affairs today. So this narrative of the EU's inevitable decline very much contradicts with the kind of EU that I see every day in my teaching and in my research. And this book is an attempt to write up that more complete and in my view more accurate narrative of the European Union's role in the world. So let me start by giving a couple of examples of the Brussels Effect. So let's start thinking about the digital economy and the powerful American companies. So if you think about, for instance, Microsoft or Apple or Google or Facebook, these companies have a global privacy policy that mirrors the general data protection regulation, the GDPR of the European Union. They are not only following these standards with respect to the internet users in the EU, but across the global marketplace. If you then think about, for instance, Twitter or YouTube or again Facebook, they turn to the European definition of what constitutes hate speech when they decide what kind of speech they take down from their platforms. They do not look to the First Amendment of the American Constitution as their local guide. And the Brussels Effect is not just a phenomena affecting the digital economy or American companies. The European Union regulations also determine how timber is harvested in Indonesia. What kind of pesticides African cocoa farmers use in their agriculture? What kind of chemicals Japanese toy manufacturers use in manufacturing those toys? What kind of equipment Chinese dairy factories install in those factories? Or how much privacy we afford to internet users in Latin America? So these are examples how the European law penetrates across the global marketplace. So by Brussels Effect, I refer to the European Union's unilateral ability to regulate the global marketplace. The EU is one of the largest and wealthiest consumer markets in the world, and there are very few global companies that can afford not to trade in the EU. So in order to trade in the EU, these companies must follow the EU regulations. But where it gets interesting is that often these companies conclude that it is in their interest to follow the EU rule globally. So they extend the EU rule across their global production or global operations in an effort to forgo the cost of complying with multiple different regulatory regimes. So all the EU needs to do is to regulate the single market. And it is then the global companies that are exporting those rules in their business business interest following the logic of the market forces to the other parts of the world. So one question is why the EU today is the only jurisdiction that is in the position to be a unilateral global regulator. So I started by mentioning how the EU is one of the largest and wealthiest consumer markets in the world. But we also have the United States. Why don't we have the Washington effect? We could also talk about the Beijing effect if you think about the size of the Chinese market. But the book argues that it is not enough to be a large market. You also need to have the regulatory capacity, the legal institutions that allow you to unleash that power of the market and convert it into tangible regulatory influence. And that is an example where China is still far behind the European Union. It is building its regulatory capacity, but it doesn't have anything comparable to the technical expertise that resides in the bureaucratic institutions in Brussels. And that explain how the EU is able to promulgate and enforce rules around the world. So Washington on the other hand, there is plenty of regulatory capacity in Washington DC. The difference is the US has made a political decision to let that capacity largely sit idle. There is very little will to deploy that capacity. Up until 1990, the US was largely the source of global standards. But since then, the US has pursued an active deregulatory agenda and inadvertently basically seeded the marketplace of regulation for the European Union. Right at the time when the EU started to ramp up, it's a goal to complete the single market. And how does the EU complete the single market? Primarily through integration, through regulation. So that explains why we do see today the Brussels effect and not the Beijing effect and not the Washington effect. But in many ways, the Brussels effect is a generic theory that gives you a roadmap of what it takes for any given jurisdiction or an entity to exert unilateral global influence. So another contribution that I think the book makes is that it invites us to rethink the concept of power and recognize law and regulation as a source of such power. It really elevates the regulatory power among the tools of influence, challenging the account that we should measure the country's influence focusing on the hard power, military capacity, or only focusing, for instance, on the ability to leverage economic sanctions. Those are the kinds of powers that are very costly to deploy. And compared to them, the Brussels effect, the regulatory power that the EU has is much less costly. It is much more easily deployed. And it's also very hard to undermine by others. First thing, for example, of the current US administration, it has not been easy to cooperate with President Trump. He has also made a big statement of what his policies towards multilateralism and walked away from the Paris Accord, walked away from the World Health Organization, walked away from the Iran deal, but he cannot walk away from the Brussels effect. Because ultimately he cannot prevent the EU from regulating its own market, and he cannot change the decisions of private global companies to follow, for instance, the EU's chemical regulation to follow the EU's privacy regulation, and so forth. So that is an example of why it is the kind of power that it really matters. It also matters in a way that all of us in this call feel the Brussels effect on a daily basis. It affects the food we eat, the air we breathe, and the products we produce and consume. And to me, that is influence, and that is power. So let me now maybe move towards the two last chapters of the book, where I asked two questions. One, whether this is a good thing, whether we should be celebrating the Brussels effect, or whether that should be a cause for concern. And then the last chapter that asks the question whether the Brussels effect will last, what kind of future will it have. So let me now focus on the normative question. The book itself, the main contribution is descriptive. It explains the phenomenon of the Brussels effect, whether you like it, or don't. It shows that it's pervasive, and it matters. The next chapter, asking whether this is a good or bad thing, I do engage with a couple of prominent criticisms that have been leveled against the Brussels effect. So let me now walk you through those questions. So first criticism that I often hear is that regulation is costly, and regulation reduces innovation. In any case, the Brussels effect only multiplies those costs, then all the companies, all the companies affected by the Brussels effect also need to scale back on the innovation in order to meet the regulatory requirements. So this is a valid question, and a question we should always force to ask when we evaluate any piece of regulation. And there was an interesting conversation I had with the tech executive, asking how he finds the big, what he thinks the biggest difference is when he deals with the regulators in the EU, and the regulators in the United States. And that the European Union wants us to satisfy a consumer need. That's what we should be doing. Whereas the Americans, they want us to change the world or allow the world to be changed. And I do think that if every company in the world was innovating towards satisfying a consumer need, as opposed to changing the world, some of the most disruptive innovations, some of which with massive potential to enhance the state of the world and humanity would But at the same time, I think it would be too quick to conclude that regulation always increases costs and reduces innovation. There are numerous examples of for instance energy efficiency regulations that have led to the product development that serve the goals of environmental protection, but that have also enhanced innovation and made products better and cheaper. There is also a wonderful book by a French economist, Thomas Philippen, who is that NYU, who wrote this great book called The Great Reversal, How America Gave Up on Free Markets. And he shows how the lack of antitrust, so competition regulation in the United States has led to excessive concentration of the markets, which have led to higher profits for corporations and higher prices for consumers. The opposite has been true in the EU that has chosen to pursue stringent competition regulation. That's why I pay so much less for my flight from Brussels to Madrid than I pay for my flight from New York to Chicago. That's why my cell phone plans are so much cheaper in the EU than in the United States. And it's actually fascinating that this morning we all were able to read that finally, after about two decades, the US is bringing its first big antitrust case against a big tech company, Google. So even the US is now conceding that it has not regulated enough and the market is not competitive as it is. So I think it's more nuanced question as to what is the relationship between regulation and innovation and regulation and costs. So let me now move to the second criticism, which is one related to protectionism. There is this perception that the EU's regulation is a reflection of the EU's attempt to give a leg up to its own companies that are unable to compete with more efficient and more innovative American companies. And I'm not surprised there is this perception, especially if you look at areas like competition law. All those big cases that Commission FH target is taking against big American companies. So there is this perception that big fines against Google, the state case against Apple and so forth are really a some kind of manifestation of trying to level the playing field because the Europeans can't do it on their own. But if you take a closer look at these cases, there is no European search engine that the EU is trying to protect. Who is the main beneficiary and who brought the case and asked the Commission to go after Google? It was Microsoft. If you think about a really big fine against Intel, who benefited from that? Another US company, AMD, there are normally US companies on both sides of the dispute fighting the civil war on the European territory because Washington DC has not been willing to extend them any remedies. So in that sense, this is not about US versus EU, often this is US versus US. And that's why I think the notion that this would be a big protection is zeal that that the Commission is pursuing is very questionable. If that had been the goal, we would have seen as Siemens-Astron merger be approved, we would have seen a desire to build a European national champion. I do mention though that I am concerned about how the conversation seems to be shifting. And now there have been increasing calls to pursue more industrial policy informed competition policy in the EU. And that to me is something that that may risk the kind of policy instrument that has served Europeans really well, and that has also served the European ability to externalize its competition policies and practices outside of the EU. So the EU might be extending and exporting competition protectionism as well if the EU wants to chase its own view. But to look at the EU's record to date, I am less worried about the criticism relating to the EU's protectionism. So let me now move on to the final criticism that I discussed in the book, and that is one relating to regulatory imperialism. This idea that the EU through the Brussels effect is compromising the political autonomy of foreign governments and their citizens when these foreign governments can no longer deliver regulatory outcomes that are reflecting the citizens in their own economies. Instead, the European consumers preferences get imposed on the consumers in the other markets. And I think it is another criticism that we should pause to reflect because it is true that we do have African farmers refraining from using GMOs in order to make sure that they exports are fit for the European market. And there is a question whether the GMOs would better serve Africa that needs to feed its growing populations. There is also a fair criticism that there are consumers in America, in Latin America, Asia, across the world who would not want to or can't afford to care about the environmental sustainability if it comes at the cost of the price of the products. But the criticism is somewhat less sustainable. If you think about what the EU actually is doing, it is not imposing its standards on anyone. It is regulating the single market, which it has the sovereign right to do. If global corporations then decide that it is in their interest to follow the EU standard globally, it is hard to attribute that choice to the EU's regulatory protectionism. So that is one of the strongest defenses that the EU can extend to the question of whether it is a regulatory imperialist. There is also a narrative that maybe the EU is not a regulatory imperialist but a benevolent hegemon globally, whereby the EU is for instance offsetting the regulatory deficits in the other parts of the world where the regulators are unable or unwilling to protect their own consumers. And there are many consumers in America for instance that are grateful that they will see and feel the Brussels effect, because for instance the role of money in the US politics has led to the status quo of regulation that may not fully correspond to what an American citizen and a consumer would want the level of regulation to be today. There is so much more corporate money in influencing through massive lobbying the kind of regulation that is coming out of Brussels, but maybe it is actually that that is coming out of Washington that it is maybe actually the Brussels effect making a benevolent and welcome effect by making inroads into the American regulatory landscape. So those are some of the thoughts on the normative analysis of the Brussels effect and let me now move to look to the future. And I raise some internal and external challenges to the Brussels effect. And let me maybe mention now the two of them. So one is the external challenge that comes from the rise of China and the other economies and the inevitable decline of the EU's market share when you think about that as in relative terms as a proportion of the global market. The EU's market share will go down the EU's relative GDP of the global GDP will go down. And it is possible that there will be the state of the world where the EU is no longer that big of a market that it would be an inevitable trading destination and that the global companies may consider diverting trade they trade elsewhere. But why I'm less skeptical that we see the Beijing effect, for instance, replace the Brussels effect anytime soon is that it is the GDP per capita, rather than the GDP that better predicts the countries or jurisdictions ability and willingness to regulate. It will be a while before the wealth of the Chinese consumer will be at the level of the wealth of the European consumer when China will actually be able to afford to care about food safety or environmental protection or data privacy to the extent that Europeans do so they will not be an alternative to the Chinese standard emerging anytime soon. And by the time the Chinese GDP per capita is high enough, the growth of overall GDP is likely so much slower that it is unclear whether the government will feel that it can afford to regulate if that would further dampen that slowing GDP growth. So there are certain the reasons that lead me to argue, not dispute that the relative importance of the European economy will decline, but rather to argue that the Europe's regulatory power will outlive its power measured in terms of the size of the GDP alone. Okay, so let me now think about and turn the conversation to some of the internal challenges. I talk about the rise of anti EU sentiment and populism, and I conclude in the end that even though I take that extremely seriously and consider that to be a genuine threat to the entire ethos of what European Union is and what it is about the ability of these populist anti EU parties to compromise and undermine the Brussels effect is much more limited. The EU's regulatory power is not a salient political issue for them. These governments care about who enters the country, so migration, the composition of the courts, they press the operation of the NGOs, arguing for chains in the government policies and their rights. Those are the concerns, not the idea that the EU would be leveraging its competition laws vis-a-vis foreign companies, or even data protection or food safety or any other key areas of the Brussels effect. But let me know, especially since I have a lot of UK audience and my remarks with raising the potential threat to the Brussels effect that comes with Brexit. And there certainly is a reasonable argument to say that the Brussels effect should be weakened by Brexit, because the starting point in the end is the market size, and the EU is just losing a big chunk of its market size. And I would like to argue it is also losing a lot of regulatory capacity. There were a lot of competent bureaucrats from the UK shaping the EU regulation. And I think they will be missed. But at the same time, it does not entail that Brexit would actually erode the Brussels effect, rather it is the Brussels effect that compromises Brexit. And the book argues that the regulatory sovereignty awaiting the UK on the other side of Brexit was one of the biggest false policies and promises of the Brexit campaign. There is no such thing as regulatory sovereignty awaiting the UK. The UK will not be able to unleash itself from the EU's regulations. So the EU is an important market for the UK. About half of the UK trade is destined to the EU. The EU is the number one destination for critical UK industries, whether we talk about aerospace, automobiles, chemical industry, whether we talk about pharmaceuticals, financial services, these industries need access to the European market after leaving the European market. And to do so, they need to follow the European rules. So the question to you is, if you are an automobile manufacturer in the UK, do you really want to follow the standard that gives you access to the market size that is six times your domestic market? Or then do you want to set up a second production line and produce something to an alternative UK only standard? The businesses know that they do need to continue to align their behaviour to the European rules and that it would be costly and not in their interest to start building those second alternative production lines. In fact, if anything, we might see that the UK businesses will be living in all the more regulated Europe after leaving the European Union. Because that pro-market voice, that voice that is sceptical of regulation is no longer around the table where those regulations are being set. There is much more space for France and Germany and other pro-regulation countries to decide how and how much the EU regulates. And that is the choice that the UK has made by becoming willingly through referendum and its implementation a rule taker as opposed to rule maker. So the book argues firmly that there will not be such thing as we would see the Brexit really being the biggest threat to the Brussels effect. But really the Brussels effect exposing the fallacy of their regulatory freedom that has been associated with Brexit. So let me make the end with those remarks and I warmly welcome questions on anything that I mentioned or failed to mention or anything that you want to discuss. Thank you very much. Thank you. That was extremely clear and very compelling just like your book. Let me perhaps start by asking this. You wrote the book in the times before COVID-19. To what extent is the pandemic or the longer term effects of the pandemic a threat to the Brussels effect? Will we see the EU becoming slightly more restrained when it comes to regulatory power? Will it become more pro innovation and competition? Will others become less likely to take up this or start following these rules? Yeah, so it is a terrific question and who would have envisioned the state of the world that we have right now when the book came out in the end of February? So the book obviously does not discuss COVID but I think it is one of the most fascinating questions. How it shapes the world, how it shapes the European Union and how it shapes its regulatory power. So first of all, let me be clear. I do not underestimate for a second that the magnitude of the challenges that COVID-19 is presenting to the world and presenting to the European Union, whether we talk about public health or whether we talk about economic ramifications of the disease. But the pandemic itself would undermine or bring the Brussels effect to health if the pandemic was also bringing the globalization to health. And at first we saw some evidence that it seemed like everybody was closing the borders. We did not see international trade do anything but contract and there was this economic nationalism setting in. And there was a lot of conversation how the companies are reshoring their production and cutting off their long supply chains. So that would be a path towards the end of globalization. But we have not seen that companies do that. They have re-evaluated the resilience of their supply chains. They have diversified and hedged, but they have not repatriated their production at the level that we expected. So we cannot imagine global companies starting sourcing and producing and selling globally. That would be the end of the Brussels effect. There would be no need to globalize any of your standards because you would only be producing to your own market. But that has not happened. So that's just the first comment. We will not see the end of globalization and we will not see the end of the Brussels effect. The second, even though this is a challenge for the EU and it is a crisis for the EU, if anything can be inferred from the last crisis and the past several crises, the EU's powers only tend to grow through a crisis. So if you think about the euro crisis that led into the reform of the economic financial architecture of the EU, which is why the European banks and the European financial institutions are actually better equipped now than they were the last time to absorb the financial economic shock that we are facing. If we think about the migration crisis that actually led to the strengthening of the front acts, the common border patrol, and I would not be surprised if COVID-19 will lead to the transfer of more powers to the EU when it comes to public health. I think few people now can conclude that global pandemics that do not respect the national borders would be better handled at the member state level. So in many ways, we might see even stronger the EU coming out of this and in some ways we already seeing through the recovery fund, for instance, where we now have the EU raising its own funds and gaining more powers and that way. And let me make one final comment. And if we think about the nature of the regulatory power, I think that kind of power is particularly resilient to crisis. So the Brussels effect rests on technocratic power. And in many ways, even though there's a massive political and economic crisis at the heart of the European Union, keeping the council preoccupied day and night. Who is writing the regulations? It's the bureaucrats at the commission. They will go to the debate desk every day and work on they assigned regulatory domain. They are right now working on implementing what the Green Deal I will look like, what regulations need to be in place. They are not all working on COVID-19. They are working on the digital services act. Again, those tasks have not been diverted to the crisis response. So in many ways, we also saw for instance the GDPR emerge at the time when it weathered the Brexit and the migration crisis, and those did not derail the GDPR. So in many ways, I think the Brussels effect will be quite untouched, if you like, by the depth of the sharp of the COVID-19. Thank you. We are getting lots of questions from the audience. So I'll just start putting some of them to you. Tom Bokenstein, for example, would like to know what the role is of the Court of Justice of the European Union in developing the Brussels effect. And he's thinking in particular of Shrems 1 and 2, how would you evaluate the court's role? Yes. So even though I focus a lot in the book on the Commission and the bureaucratic origins of the Brussels effect, obviously many of those legislations will get them to council and parliament and will have their views reflected in those regulations. And also then many of them are critically interpreted by the court. And the European courts have been very important in often expanding the powers of the EU and fading the way for more regulation from the EU to emerge with the pro-integration style of rulings. And many of the rulings directly have become the source of the Brussels effect, if you like. So if you think about the right to be forgotten, that was formulated by the court before it made its way into the GDPR. And that has been enormously influential. The Shrems 1 and 2, again, that has sent a very clear signal of the right forward fundamental, the right driven approach to the right to privacy, which has then struck down the safe harbor and the privacy shield as the means to transfer data between the US and the EU. And if anything, those regulations send a strong signal to the companies that there is often the only path to guarantee the continuing data flows is that they own jurisdiction would secure adequacy rolling from the European Union, meaning that we will see more and more equivalent legislations emerging in the other parts of the world. That is something that I call de jure Brussels effect as opposed to de facto. So not just affecting the company behavior, but also the way that the government start emulating the EU regulation. The right to privacy is a good example. We now have over 120 countries around the world that have a domestic data protection regulation, and it often is very similar, very much drafted to emulate the European GDPR. So in that sense, often that the court has been reinforcing the Brussels effect. But just last year we had a couple of rulings where this question of what are the outer boundaries of the Brussels effect where directly before the court. So for instance, whether this obligation to remove information under the right to be forgotten would explicitly be made global that whether Google for instance would need to remove the search results across the world. That's where the court did not go that route. But very soon after that the court did say when it was looking at another case relating to Facebook, and the obligation to remove speech that is considered harmful the hate speech that they can actually be an obligation to remove that speech, not just so that the Europeans can see it, but also more properly. So the court is an important player probably doesn't get enough ink in the book. And I really look forward to others expanding and building on the analysis and really those who are court experts and and and who can really look more clearly whether there is actually a some have called it the Luxembourg effect to complement the Brussels effect. We have a question from Marcus Gehring as well on Brexit. You do say in the book that strict rules may become easier to generate with the departure of the UK from the EU, because the UK has often opposed the EU's extent extensive rulemaking. Are we starting perhaps already to see evidence of this. So I think that conversation that that the example that I touch on is this push to pursue more industrial policy inspired competition laws and they will say a joint appeal by France and Germany to actually rewrite and revise the European competition laws to do take to take into account the external competition that Europe is facing and the industrial competitiveness of European companies. So I think that is a primary example where I would expect the UK to still more carefully think about the way the markets operate and the way we think about consumer welfare, even though I must say that now some of the trade aid for instance in the UK has been quite out of line with the more typical possession of the UK in this in these particular questions. But yeah so I think we might be starting to see but I think we will it will take a while before we see whether there is really the kind of legacy that the UK's exit will have whereby we will see more and more regulation to be to be coming out to the services act I think will be really interesting, but let me let me mention though that there have been areas where the UK has clearly contributed to the pro regulation stands. And one example I discuss in the book is the ETS the emissions trading state, and the UK has been a proponent of fighting climate change and the UK's domestic system, in addition to that of Denmark. We're saving the way for the European and we're models for the European emissions trading scheme so I do not want to paint with a to broad of a brush that the UK is always anti regulation, but I think it has that reputation for a reason, and we can conclude from that that there certainly would be a perception among other stakeholders that now it's they time to push for more regulation, because we will not need to worry about the UK's opposition. We have another question from Julian Miral. He wonders what the Brussels, what does the Brussels effect together if you put it together with the EU free trade agreements, what do those two parts together mean for the global reach of EU law. So I do thank you for raising the trade agreements I do dedicate one chapter in the book where I discuss the other instruments that the EU has to externalize its regulatory power, and I do discuss the trade agreements there. So the Brussels effect the unilateralism is certainly not the only way that the EU is able to export its rules and regulations. The EU is doing it in multilateral settings in international institutions, whether we talk about, for instance, international standard setting or for instance in the food safety specific organizations in the UN bodies and the WTO and so forth, but also very importantly, the EU is externalizing its rules through trade agreements. So we see competition law we see labor, human rights environmental various other rule of law related issues being incorporated into those preferential trade agreements. The difference, however, is that the EU's record of success through transforming regulatory for transforming regulatory regimes through trade agreements is mixed at best, because there the logic is very different, the EU needs to get the cooperation of the other government that would agree to the trade agreement. And then there is the question whether, even if the EU gets the countries to agree, how can we ensure that there's actually an enforcement and follow through. And there is not a great record that the EU would have for instance, transform some human rights practices rule of law provisions, even in its own neighborhood, where those have been very much part of the legal framework embedded into the trade agreement. So the enforcement is much harder, but I do not underestimate at least the efforts that the EU makes to also an occasional success in using those alternative tools. And even though that here I use your question I to also mention about multilateralism and the relative influence of the Brussels effect and the EU's ability to shape the regulatory environment through multilateral cooperation, especially today, where unilateralism is really in retreat, and many of the international organizations are struggling, including the WTO. There is even more demand and more of a vacuum for the EU's unilateralism to step in, and for the EU to then transform the world through the Brussels effect, because for instance the Paris Accord when the US walks away from that, it is going to be less effective. That doesn't mean that the EU is willing to abandon. The EU's ability is for bilateral regional and multilateral cooperation. EU is a multilateralist at heart, it is a construction of multilateralism itself. And the EU welcomes that cooperation when it is available, but the EU is not going to sit still and await if a cooperation is not forthcoming. In many ways I describe the EU as a contingent unilateralist that pursues unilateral regulation, often to pave the way for multilateral regulation, or then as an alternative if multilateralism is not yielding any results. Can I just piggyback on that answer? Because one thing that I found puzzling is, of course you do talk in the book about how there has been this retreat from multilateralism back to national borders, and isn't there an incentive for other states in the world to pursue this cooperation, the stronger the Brussels effect gets, because if the US retreats from this cooperation then necessarily they're going to see the EU setting standards by themselves. And that's not something they like, I gather. So if you don't like that then why don't you try to negotiate rather than just let the Brussels effect take hold the way it has? One would think Alicia, absolutely. So if you think about what the US is doing, so when President Trump is turning his back to for instance the Trans-Pacific Partnership, or does not want to negotiate a trade agreement with the EU, those are the best opportunities for the US to set the standards jointly with the EU, or in the form of the TPP provide an alternative global standards towards which the corporations can gravitate. But inadvertently, by turning his back to globalisation, the Trump administration is basically embracing more Europeanisation. I don't think that is the goal, that is not the intention, but it's certainly the implication and that is the outcome. So yes, I think it should provide the incentives for others to act and sometimes we see examples of it. So I discuss an example in the book which shows the limits of the Brussels effect. And that is the EU's somewhat failed attempt to extend its emissions trading scheme to aviation. So make sure that the foreign airlines will be paying for the greenhouse gases that they are emitting, not just when they are in the European airspace, but when for instance you are flying from New York to London, even before you enter the European airspace. And that's one of the rare instances where there was a concentrated and strong joint opposition by big local companies and the governments around the world. And the EU backed up. The EU actually halted the application of its emissions trading scheme extra-territorially in the aviation. But what the EU managed to do was that there was actually then an international agreement, maybe not exactly the way the EU would have drafted the legislation, but it brought the governments to the negotiation table. And there was this idea that the alternative is the EU's unilateralism. So we are better off setting these standards jointly because otherwise the EU will set them for the rest of us. Thank you. So, we have more questions coming in. Several of them about competition law and about this resurgence of or disappearance of a more protectionist language perhaps within the EU that you've mentioned as a concern. Will that be you think this is one of the questions? Could that be perhaps a good thing? Should the EU adopt a more protectionist stance when it comes to competition rules and what would the export of protectionist regulation look like in that area? Right. So it is hard for me to defend protectionism. I think it is unlikely to serve the European competitiveness. It is unlikely to serve the European companies well. And I think it is part of the conversation that there's been now this attempt to be more geopolitical EU and geopolitical commission. We have this willingness to even geopolitisize the tools of the Brussels effect and its various components including competition law. And I think the Brussels effect is quite ill suited for that kind of politicization because partially its success is explained by the lack of politicization. The idea that this has been a technocratic under the radar influence that does not get elevated to the level of political battles. But when you start pursuing industrial policy you are drawing in the other governments. You are inviting the kind of rhetoric that we now see dominate on economic nationalism and trade wars. You start seeing retaliation. You see tit for tat. And the exporting of the protectionism is a real threat. And I think the EU can export it in both ways. First it can export it within the EU where we start France the French competition agency blocking the attempts by German companies to acquire French companies. And it's very important that the commission sets the tone that protectionism is not the basis for evaluating these transactions. We would see the member states copy what the commission is doing. But then the EU would also export that to other jurisdictions. Next thing we see Brazilians pursuing competition policy that is protections and so forth. So the EU has already become a template with its competition law for over 100 competition laws system systems in the world. And I do fear that if the EU was to convert its own competition policy to towards protectionist ends, it would not be alone. It would be would have changed the global landscape for competition law. Let me perhaps ask you to finish with a very broad by asking a very broad question. I mean you do mention in your book that one of the problems or perhaps one of the unfortunate effects of the of the Brussels effect is that it has economic costs. But that's to a large degree this economic costs are distributional and they affect the less wealthy. Now this is something that is part of a larger pattern. This is something that is part of the larger pattern of European integration and I suppose more broadly of globalization in general. I know there are absolutely no easy answers to this but what are your thoughts on this what could be done to address this I mean this seems to be one of the problems at the root of the, you know, much of our political travels at the moment, you know the rise of populism everywhere in the world, etc. What are your thoughts on the on the distributional unfair economic costs of the Brussels effect. Yeah, so I think you raised the concern that I do share and I care about deeply and I think it is one of those unintended consequences of the GDPR, for instance, that it is not a problem for company like Google to comply with the GDPR. It is the small guys, it is the small startups, small and medium sized companies and organizations that are struggling. And that is not the intention of the EU at the same time when the EU is trying to reign in the power of the big tech, it is actually entrenching that power through some of the regulations where the cost of compliance are so unevenly distributed. I do take comfort in seeing that even now already the conversations about the Digital Services Act, the conversation about the EU starting to think about separate regulatory tools for competition law is making a distinction between big and powerful companies and smaller companies. And what might be the right way to regulate the big internet platforms may not be the regulation for the smaller medium sized companies. And the EU really needs to take a hard look of its own innovation ecosystem. So in the absence of the big Googles and Facebooks, we need to think about those were small startups at some point, and they were able to evolve into powerful companies, not only because of the lack of antitrust enforcement in the EU in the in the US partially because of that, but also because there was an regulatory framework that did not hamper the small companies ability to grow and succeed. So I do believe that the EU and all the big friends and supporters of the GDPR should be its biggest critics to allow for the EU to reevaluate and rewrite the regulations where they do have unintended consequences and the consequences that are not in line with the values that are informing the regulatory standards that the EU has taken. So I think it is a problem, but it is a problem with for which there is a remedy, and for which there is a remedy that the EU is well positioned to implement. And I hope that you will do that. Well, thank you for, thank you for finishing on such a positive note. I think we'll probably leave it here will probably wrap things up here because our speaker has another seminar right after this one would be good if she had a couple of minutes to rest. Thank you very much for a fantastic and very engaging talk and for answering all our questions. Thanks everyone for listening. Thank you to you, Anu for for giving us your time we really appreciate it. And can I just say that our next seminar, the next cell seminar will take place next week on the 28th of October, it will be a lunchtime seminar with Sir Stephen wall. And we look forward to seeing you there as well. Until then, everybody stay safe. And thank you again. Thank you. It was my pleasure. Thank you, Alicia. Thanks everyone for joining. Bye. Thank you.