欧盟是否‘统治世界’?竞争法扩散至新加坡和香港

Does the European Union ‘Rule the World’? Competition Law Diffusion to Singapore and Hong Kong

Regulation & Governance · 2026
被引 1 · 同刊同年前 2%
ABS 3

中文导读

通过检验四种扩散机制,发现新加坡和香港采纳竞争法主要源于美国或中国的政治压力,而非欧盟的市场影响,挑战了‘布鲁塞尔效应’的普遍性。

Abstract

ABSTRACT This article examines why Singapore and Hong Kong adopted competition law by testing four diffusion mechanisms: coercion, competition, learning, and the Brussels Effect. Using structured process tracing and extensive archival evidence, it evaluates the distinct observable implications of each mechanism. Singapore—often cited as a most‐likely case for the Brussels Effect—adopted competition law only when the United States made it a requirement of the USSFTA. Hong Kong, despite its greater exposure to EU competition enforcement, resisted reform for nearly 15 years and shifted only when Beijing signaled support for a general competition law. In both jurisdictions, firms did not internalize EU standards or lobby for EU‐style rules, and neither regime adopted EU‐type merger control. Competitive interdependence receives no empirical support, while learning operates mainly as an adaptive tool once external pressure is present. The findings refine the scope conditions of market‐driven regulatory diffusion and highlight the political foundations of ‘economic constitutions.’

竞争法政策扩散欧盟新加坡香港