Land of the free, home of the (un)regulated: Public procurement in the EU and the USA.

Scholars tend to assume that in terms of institutional shape the US is generally more hierarchical and centralized than the EU and in terms of market integration the former is more of a single free market than the latter in the sense of fewer allowable trade restraints. This paper, however, in taking a closer look at the respective public procurement regimes of the United States and the European Union argues that in certain policy fields the European Union appears to have gone further than the United States in centralizing authority and eliminating interstate barriers to integrate the common market. It further contends that the arguments made in the US to explain the continuing existence of trade barriers in public procurement, based on the market participant exemption, don't hold up in comparative light and that the difference between the two polities is largely due to the role of the Commission as a federal-level entity specifically charged with creating a common market and a different attitude towards federal-level entities in this policy arena. [ABSTRACT FROM AUTHOR]