National approaches to consumer protection in France and Germany, 1970-1990

Abstract

This research investigates the growth of product market regulation in France and Germany from 1970 to 1990. It finds that these countries have pursued divergent strategies for regulating their domestic product markets. France has treated consumers as citizens, granting them special political protections against product risk. Germany has treated consumers as producers, emphasizing consumer information as a means of combatting market failure. This policy divergence resulted from the different institutional contexts in which the issues of consumer policy were first raised and resolved. As a consequence of these broad institutional differences, France and Germany have put in place divergent national consumption regimes, in which different sets of consumer and producer interests are systematically emphasized in government regulation. Such national divergence in consumption regimes is important because it will increasingly influence consumer and producer decisions about product choice, and these choices in turn set the terms of national variations of capitalism.