Article 81 EC's goals are unclear. There are two main schools of thought. The predominant view is that only consumer welfare considerations are relevant there. However, a recent book argues that this position is erroneous and that other Member State and European Union public policy goals (such as public health and the environment) should also be considered there. If this argument is correct then it could have a profound effect on the outcome of cases as well as the Modernisation process as a whole.
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