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Supremacy, Direct Effect, and Dairy Products in the Early History of European Law

As the European Court of Justice’s (ECJ’s) two most famous decisions, Van Gend en Loos and Costa v. ENEL, are commemorated on their fiftieth anniversaries, attention has also turned to another of the ECJ’s early decisions. On November 13, 1964, in Commission v. Luxembourg & Belgium, the Dairy Products case, the ECJ rejected the use of “self-help” countermeasures in the Community legal order, and therefore marked the fundamental distinction between European law and general international law. Drawing on writings by Robert Lecourt, Paul Reuter, and Paul Kapteyn, this paper demonstrates that a direct causal link between these three cases was recognized by ECJ judges and legal scholars as early as 1965. The historical evidence presented here therefore supports previous comparative analysis that has argued that these three decisions—Van Gend, Costa, and Luxembourg & Belgium—should be acknowledged as profoundly inter-connected, in that national court application of European obligations should be understood as a substitute for the enforcement of European obligations through inter-state countermeasures.