Case Study 14: The Road to Cancún: the French Decision-Making Process and WTO Negotiations07/07/2020 9
I. The problem in context: how does France participate in multilateral trade negotiations?
France is a major trading power and has steadily followed a long-term path of trade liberalization since the launch of the European Common Market. ‘France’s exports rank fourth for goods and third for services, with a structural surplus representing approximately 2 per cent of GDP. Five millions jobs are based on exports. Foreign companies are responsible for one-third of our industrial production.’(1) While not directly engaged in negotiations in the WTO, France participates in the European common trade policy and is deemed a ‘pivotal’ state, particularly on agriculture. Yet little research attention has been devoted to the political economy of trade reform in France.
This study surveys French decision-making relating to trade, from summer 2002 to the Cancún WTO Ministerial. It focuses on market access issues, which by no means embrace France’s trade negotiating priorities. Following Rodrik, we assume that ‘all the political economy models provide a particular story about how organized groups or individual voters can take political action to reinforce or alleviate the income-distributional consequences of trade flows…. The conclusion in common is: trade is not free because politically influential groups can be made better off by policy interventions on trade.’(2)
One of the suggestions presented in this paper is that standard assumptions about the influence of organized groups on trade reforms are globally verified: France’s political economy entails no cultural exception. Another suggestion is that institutional settings, both at national and at European Union (EU) level, substantially affect the outcome of French decision-making.
II. The players and their role: setting the French political economy variables
Conventional models root the demand side of trade policy in individuals’ preferences, channelled through organized groups, and the supply side in policy-makers’ preferences expressed through the institutional structure. While acknowledging that ‘values, identities, and attachments, play an important role in explaining the variations in preferences over trade’,(3) this paper concentrates on decision-making, thus dropping the analysis of French public opinion preferences. One reason is that opinion polls do not reveal, prima facie, striking differences between French and other European opinions on trade, the WTO, or even the Common Agricultural Policy (CAP).(4)
Trade and agriculture. Players acknowledge that a consensus exists among policy-makers: agricultural goods are not considered common goods, because what is at stake outweighs trade interests. President Chirac of France often stated this vision:
It is essential to remember that agriculture does not reduce to the trading framework in which international negotiations too often pretend to lock it…. Before involving international trade, debates over agriculture, on the global scale, are really debates over food sovereignty, which relies above all on agricultural development. The goal that we must pursue in agricultural matters is to achieve food security for all. Trade negotiations must not lose sight of it.(5)
Diplomatic advisers to the Trade and Agriculture Ministers explain, ‘The WTO negotiations always cloud political issues with coded language. Behind technical negotiations, what is always at stake is the very legitimacy of agricultural policies. France systematically reformulates what the negotiation really is about, politically.’
Trade and diplomacy. The French elite may grant second-rate status to trade policy. ‘Trade policy is not a French notion; trade is considered a by-product of diplomacy’, suggests Hubert Testard, Deputy Chief Trade Negotiator. Players admit that French trade policy integrates broader foreign policy options. Some mention the stakes of transatlantic relations and development policies in that regard.
Trade and partisan politics. Players do not support the claim of a right/left partisan divide on trade.(6) ‘The right may seem slightly more flexible on public services and the left on agriculture. Such nuances are infinitesimal. There is no French political divide on trade policy’, asserts Philippe Gros, permanent delegate to the WTO.
For Damania and Frederiksson,(7) ‘to influence trade policy, special interest groups must influence all such (collective or individual) actors with veto rights over policy changes. The empirical literature…. has ignored the fact that trade policy is determined by more than one veto player.’
Three features are particularly relevant for trade policy within the French democratic framework. The French Constitution grants pre-eminence to the president, over the government, on foreign policy (domaine réservé;). The Trade Minister(8) runs a specialized administration (DREE)(9) within a strongly institutionalized interministerial decision-making process: a secretariat (SGCI)(10) headed by the Prime Minister’s office exclusively clears French positions on EU policies. Parliament’s involvement is slight.
As an EU member state, France promotes its positions through the EU Council of Ministers (Foreign Affairs); trade policy decisions are prepared by the Article 133 Committee, where the EU Commission consults with member states; other Council formations are also relevant, particularly those relating to agriculture, environment and development. To that end, building coalitions with other EU member states is needed. A good bilateral dialogue with the EU Commission, at all levels, is also considered a decisive channel.
Players adapt their strategy to this multi-dimensional institutional design.
Lobbying strategies. ‘We simultaneously promote our positions at all levels’, says Francis Delemotte, Head of International Trade of UIC.(11) Marc Maindrault, his counterpart at MEDEF,(12) adds: ‘Many businesses privilege trade lobbying through European Industrial Branches Federations. These are the heart of power: they hold the information that the Commission needs to elaborate its proposals. Other important business organizations can influence the Commission, for instance the European Round Table.’ Hence the lobbying efforts may prove asymmetrical: ‘Offensive sectors tend to go to Brussels, while defensive one speak both in Brussels and Paris. So the government hears much more from the latter’, analyzes Laurence Dubois Destrizais, Assistant Secretary for Multilateral Affairs, Trade Ministry.
Bureaucratic influences. The confrontation of administrations’ views can modify the influence of vested interests: some administrations represent selected political constituencies, others global interests. ‘The inter-ministerial process allows us to blend purely conceptual approaches of trade liberalization with grounded facts and sector-specific stakes. It makes our positions more accurate,’ thinks Fabrice Gourdellier, Head of the Trade Policy Unit of SGCI. Most players support this claim.
Political strategy. Positions taken by the government must be interpreted against the background of EU competences. Sylvain Lambert, diplomatic adviser to the Agriculture Minister, stresses that ‘France does not talk as a first-rank negotiator. Its role is not to substitute for the EU negotiator but to nuance his arguments, remind him of priorities and signal red lines.’ Hubert Testard remarks that ‘We are not overall defensive on the WTO. But since 80% of the negotiating time is spent on agriculture, the political level is forced to intervene more on it, which gives a defensive tone to our positions.’ Otherwise, the government’s positions on trade must be understood within a global dialogue with the Commission: trade negotiations are but one dimension within EU policies (CAP, competition, economic co-ordination, fiscal discipline and so on).
Bilateral relations. Member state coalitions are decisive. Within the wider Franco-German dialogue, the Trade Minister regularly consults with German counterparts. ‘Germany is the only country with which we have such an institutional dialogue’, observes Philippe Gros. Players suggest that the Franco-German agreements on CAP reform were decisive in the making of EU positions for Cancún. But they also stress a difficult Franco-German co-ordination on trade, due to opposing defensive priorities. Thus, case-by-case coalitions are also built with other countries, depending on issues.
Vocal agricultural lobbying
‘We make sure that our voice is heard at the national and European levels’,(13) claims Patrick Ferrere, Director General of FNSEA.(14) Players see the French agricultural lobbying on WTO negotiations as better organized and more efficient than other sectors. Agricultural organizations maintain a constant public pressure on the government at each step of the trade negotiations. What is at stake? Ferrere explains:
‘France is the agricultural country in Europe. Our agriculture represents roughly 25 per cent of Europe’s total agriculture, and accounts for 400,000 equivalent full-time jobs involving 1.2 million people through seasonal activities. The agro-food industry employs 600,000 people. Both factors make it the first French employer. These incomes have multiplying effects on all our rural life. Therefore, recognizing agriculture was, and remains, the condition for French participation in European integration. Due to higher labour, environmental, sanitary and quality standards, our agriculture bears higher costs than anywhere else. This is why, since its inception, Europe has twinned its trade and agriculture policies: controlling market access is a prerequisite to organizing agriculture.
In 2000, agriculture and the agro-food industry accounted for 2.3% and 3% of French GDP, respectively. France received 22% of the € 44.5 billion spent by the EU-15 in 2002 on the Common Agricultural Policy (CAP). Benefits from subsidies are highly concentrated. Main public supports for market regulation break down as: arable crops (57%), bovine meat (22%) and the dairy sector (6%). With a decreasing number of farms since 1990, the average farm payments ‘almost doubled in real terms, to reach € 18,679 in 2003, 81% of which came from the EU’.(15) The highest farm payment averages were geographically very concentrated.(16)
‘Public support for our agriculture has been very substantially reduced since 1992’, observes François de la Gueronnière, Deputy Director for International Affairs at the Agricultural Ministry. ‘First, because price support as a CAP tool has been much reduced since 1992; second, because subsidies and production have been essentially decoupled, which eliminates most of the trade distorting effects.’ This analysis is consistent with OECD findings.(17)
Hence virtual high stake ‘losers’ as a result of liberalization are increasingly concentrated. Conversely, players hardly identify a ‘winning side’ from agricultural negotiations.
First, the EU is not seen as a prospective international market player. ‘We really target the EU-25 market: 450 million consumers’, says Patrick Ferrere. Gueronnière adds, ‘Since the Uruguay Round the assertion of our agricultural export vocation faded. The agricultural surplus was then viewed as a major asset to balance our current account and strengthen the exchange rate. It is no longer the case. We now maintain a non-agricultural trade surplus and the euro took over from the franc, which eliminated the exchange rate problem. So our focus in trade negotiations shifted to the defensive side.’ Moreover, major French agro-food exports, such as wine and spirits,(18) do not rely on CAP supports.
Second, throughout CAP reforms, structural contradictions with the WTO Agricultural Agreement remained. Hubert Testard observes: ‘There was a structural incompatibility between the Agreement on Agriculture and historical CAP instruments. This essentially ended with the 2003 CAP reform.’ As Ferrere stresses,
First, the WTO undermines the CAP concepts of price and production support. Second, it does not acknowledge the supply side management limiting EU production since 1984, yet this allowed the Cairns Group and the United States to take over former European exports in third markets. Third, market access negotiations focus on tariffs and ignore the European demands for labelling of food origin, geographical indications and sanitary requirements.
Third, the US instruments are considered under-disciplined. ‘With deficiency payments, marketing loans, food aid, export credit, the US farmers get the full set of possible supports’, adds Ferrere. For all players, no domestic political support for agricultural reform can be built without strictly balancing the EU and US concessions.
Weak corporate lobbying
Players remark: ‘Businesses are silent’; ‘MEDEF’s negotiating positions are much too general’; ‘Businessmen almost never take up multilateral issues with ministers’; and ‘The president of MEDEF never speaks on the WTO.’
Jacques Desponts, chairman of MEDEF’s and UNICE’s(19) WTO committees, considers that
French business lobbying remains domestically centred. It is extremely hard to have businesses express priorities on trade negotiations. The first MEDEF position was constructed for Seattle and we achieved a similar position with UNICE. Yet French companies do not invest enough time in UNICE compared with northern Europeans. As a result, they are cashing the horserace bets in reverse order: we get ‘agriculture, industry and services’ instead of ‘services, industry and agriculture’.
Other business players concur. Dominique Jacomet, Vice-Chairman of UIT,(20) notes:
Internationalization in our sector is rooted in the multilateral system. We have strong interests, offensive and defensive, in WTO rules: TRIPS enforcement, tariff peak elimination, anti-dumping…. So we are very active internationally, at all levels. However, the priority given to agriculture hardly allows France to promote our interests.
Why are industrial and services sectors not better at trade lobbying?
First, WTO market access may have lost relevance. Hubert Testard notes that ‘a major change since the Uruguay Round comes from the trillion dollars of accumulated foreign direct investment, mainly involving multinational companies. They reduced pressure on market access. The big benefits of tariff reductions would now fall on small and medium-sized enterprises (SMEs), less influential than multinational groups within MEDEF.’ Others observe that France trades mostly within the EU, with preferential trading zones and OECD countries maintaining average low tariffs.
Second, evaluating the gains does not prove to be easy. ‘It is hard to measure robustly national gains from trade liberalization. Some statistics cannot be isolated from the EU’s. It is almost impossible to reach a simple measure of gains in the services sector. Thus policy-makers must balance certain and measurable losses in agriculture against vague and uncertain gains in other sectors’, says Mathilde Lemoine, economic adviser to the Trade Minister.
Third, the lobbying strategies of businesses vary. Marc Maindrault analyzes:
MEDEF permanently updates its negotiating priorities with information from members’ organizations. But the information is uneven because sectoral interests are diverse. Some branches efficiently monitor their WTO interests, others less so. Some have domestic and European objectives, without a stake in the WTO. Some federations represent one, or two, major groups: these have their own international strategies, without relying much on collective action. Major leaders directly discuss their important issues with the Trade Commissioner.
Politically efficient NGOs
Non-governmental organizations (NGOs) in France are considered influential on policy-making. Mathilde Lemoine explains: ‘They have a political approach to the negotiations. They usually focus on a single issue, for instance access to medicine. They bring in experience on the ground, especially on the development dimension. They have reactive international networks: policy-makers understand that NGOs may promote their political priorities more swiftly than heavy diplomatic channels.’
French authorities thus hold regular meetings with ‘civil society’, associating NGOs, businesses, trade unions and members of Parliament in trade negotiations. Business lobbies deplore the fact that an indiscriminate process grants disproportionate influence to NGOs. ‘Businesses make trade, not NGOs’, says Jacques Desponts.
III. Challenges and the outcome: the forming of French positions in the Cancún market access negotiations
This section analyzes the way in which the decision-making process translated French political objectives into the Cancún market access negotiations (agriculture, industry, services). For each major negotiating step, France took part in the consensus provided by the EU member states to the Commission.
Re-elected in 2002, President Chirac expressed his priorities for the Doha Development Agenda, particularly during France’s presidency of G8 in 2003. (i) He gave his overall vision of the trading system: trade is good for the economy if ‘openness to trade, defined in the WTO framework, comes with precise rules of the game’.(21) (ii) He drew the French ‘red lines’: ‘France favours free trade but not under any conditions. It trustfully takes up the Doha Round and will be vigilant on three sectors: cultural goods, which can never be considered common trading goods; agriculture, in order that the Doha Decision be compatible with the CAP; services, so that openness does not undermine great public services as education and health.’(22) (iii) He asserted his vision of development, focusing on the needs of the poorest countries, especially African countries. In a major address, the president made three proposals for Africa’s trade: ‘A moratorium decided by all developed countries on destabilizing export subsidies directed towards Africa, during the WTO negotiations’; ‘a special and privileged trade treatment for Africa’ through ‘a common and unique’ preferential scheme amongst developed countries; a new endeavour against commodities prices volatility, ‘in particular cotton’.(23)
The government promoted the presidential options. Trade Minister François Loos stated: ‘we want trade liberalization to come with the laying of a regulation’.(24) He subsequently insisted on his priority on access to medicines as a major regulatory issue for the WTO. The Agriculture Minister defended the compatibility between development and the CAP.(25) The government rejected the Cairns Group’s arguments: ‘No, the CAP does not strangle the poor countries!’(26)
‘The chicken is the CAP, the egg is the WTO’, the EU Trade Commissioner Pascal Lamy often said,(27) pointing out systemic links between the internal and external dimensions of agricultural reform. The French priority was really the chicken. ‘The WTO was not really on the political agenda. What politically mattered was the CAP reform proposed by the Commission. WTO negotiations were but one of the many variables of CAP reform’, assesses Fabrice Gourdellier. However, the EU Commission saw Cancún as a deadline motivating the reform. The Agriculture Minister explained to the French Parliament that ‘nothing that has happened in Brussels over the past few months can be understood unless it is linked with the discussions before the WTO’.(28)
The Franco-German dialogue was decisive for CAP reform. Step one occurred in October 2002, when the German Chancellor and the French President agreed to cap the CAP budget for 2006-13. Sylvain Lambert explains: ‘At stake was the future of the acquis communautaire in the EU-25. Germany accepted the phasing in of farmer’s direct payments for new members. France agreed to keep the CAP budget under control with a stabilized global envelope and budget correctors if the ceilings are reached.’
Step two resulted from the Luxembourg CAP reform of June 2003. France had vigorously opposed a deep reform, initially not planned to take place before 2006 (Agenda 2000). Minister Gaymard made it clear: ‘About the evolutions of the CAP, I wish to restate our complete opposition to the decoupling proposed by the Commission.’(29) Nevertheless, the Franco-German dialogue reached an agreement endorsing the idea of ‘partial decoupling’, which paved the way for the Luxembourg agreement. The general ‘decoupling’ of subsidies was decided, with room for manoeuvre left to governments willing to keep minimal links between subsidies and production levels. Patrick Ferrere stresses that ‘farmers resented Luxembourg as a major fracture: the EU was no longer willing to regulate agricultural markets and shifted supports from production to farm incomes. This raises a fundamental question of the legitimacy of subsidies: farmers want to work, not to sit and wait.’ Nevertheless, ‘the reform came about without dramatization or major conflict’, observes Sylvain Lambert.
France systematically engaged the WTO negotiations in defending the CAP status quo, while never departing from the EU consensus.
First, the EU negotiating offer included: a Uruguay Round tariff reduction formula — a 55% reduction in domestic subsidies and a 45% reduction in export subsidies. Farmers criticized an offer ‘which exhausted the full room for manoeuvre of the European Union before the real start of the negotiations’.(30) The French government nevertheless endorsed it.(31)
Second, Stuart Harbinson, chair of the WTO Agriculture Negotiating Group, presented two draft ‘modalities’ for negotiations: France, the EU, and a majority of WTO members rejected both as unbalanced.
Third, at the G8 Evian summit the EU had endorsed the French proposals for Africa, including a moratorium on all destabilizing export subsidies. ‘The Africa initiative signalled our readiness to move, provided all others would. It is still on the table’, analyzes Anne Cazala, diplomatic adviser to Trade Minister Loos. But the G8 stonewalled and watered down the proposals and the moratorium was not agreed.
Fourth, the CAP reform changed the EU negotiator’s mandate. For Sylvain Lambert,
the EU had fully delivered for Cancún. Looking at the facts instead of ideology, European agriculture is the only sector that has been reformed three times since the Uruguay Round. Meanwhile the United States raised support 70% and partially re-coupled their subsidies with the Farm Bill. This refutes arguments about our alleged defensiveness on agriculture. But reforming the CAP cannot be the only game in town. So we refused to pay once in Brussels, twice in Geneva.
The fifth crucial step resulted from the transatlantic agriculture agreement of August 2003. It departed from previous EU positions, especially with the concept of a ‘blended tariffs formula’. France was surprised by the Commission’s proposal but did not reject the move. The Agriculture and Trade Minister jointly ‘took note of the agreement between the EU Commission and the American negotiator on some of the topics of agricultural negotiations in the WTO’ and stated that ‘the government will exert the highest vigilance in respect of the mandate given by the Council to the Commission, who negotiates on behalf on the European Union, and in particular in respect of commitments made in the Luxembourg agreement of 26 June, reforming the CAP’.(32) Laurence Dubois Destrizais explains: ‘The Commission presented the EU-US agreement as a fait accompli. But while it was a clear change of strategy, the Commission had not crossed the red lines.’
Eventually, Cancún failed before agriculture was negotiated. ‘The agreement between the transatlantic negotiators had shown that the USA were not ready to put figures on a “modality paper,”’ thinks Sylvain Lambert. ‘This is why agriculture was not discussed in Cancún.’
So the egg did not challenge the chicken.
‘Ministers Mer and Loos launched an evaluation process to assess our offensive and defensive commercial interests. It helped progress towards a more offensive French attitude in spite of our agricultural sensitivity. The tariff negotiation was the main focus of businesses, yet they could hardly reach an aggregated vision of their offensive interests’, relates Christophe Lecourtier, international counsellor to the Economy and Finance Minister. ‘Under low pressure from businesses, the process was essentially fed by efforts from a few industrial sectors and economists to measure France’s interests’, reminds Laurence Dubois Destrizais.
The evaluation was positive.
The net job surplus derived from trade and investment is estimated between 500,000 and 600,000 net job creations over the last ten years. It is a very clear positive result, which leads the Ministry of Economy and Finance to promote, both in the domestic inter-ministerial debate and the negotiations, a globally offensive attitude, even though we have an agricultural sensitivity. We also assessed our defensive industrial interests, which involve some labour-intensive sectors, and they represent less than 10% of the tariff lines.
‘We are resolutely offensive and we argue for the elimination of all duties over 15%’, declared Minister Loos.(33) Hence, while most of its political capital was invested in agriculture, France fed the EU demands for ambitious industrial results. It supported the first Commission proposal of a tariff ‘compression mechanism’ (a complex harmonizing formula within tariffs bands) and sectoral negotiations for textile, clothing and footwear. In April 2003, France demanded improvements in the negotiating modalities proposed by Ambassador Girard, chair of the non-agricultural market access (NAMA) negotiating group.(34) In August 2003, France supported a transatlantic agreement endorsing the previous US call for a ‘Swiss formula’. In Cancún, France and the EU asked for improvements in Chairman Derbez’s draft ‘modalities’ for NAMA. Cancún’s failure left the business unfinished.
French political interest in services goes back to the Uruguay Round ‘cultural exception’ debate. Priorities were crystal clear for Cancún: two out of three presidential ‘red lines’ (culture and public services) fell on the services negotiations. They were shared by policy-makers and unchallenged by businesses.(35) Cultural diversity objectives were enshrined in the EU negotiating directives and Commissioner Lamy broadly shared the French position on public services.(36) France also promoted offensive demands. Minister Loos stressed: ‘France is the world’s third service exporter. The sector now provides 72% of jobs against 57% in 1980. We have an excellent negotiating position since the EU has already reached a high level of liberalization. Our objective is reciprocity from other countries, taking into account their level of development.’(37)
Nevertheless, France experienced strong NGO pressure during the preparation of the European services offer. Major campaigns were initiated against the General Agreement on Trade in Services (GATS) at national and EU levels.(38) NGOs asked for transparency of the EU offer and argued in defence of public services, national regulatory rights and access to basic services in developing countries. The campaigns had political effects. When the EU released its offer to the WTO (April 2003), the ‘AGCS [GATS]-free campaign’ could claim fifty French local government areas (four regions, twenty départements, twenty-six municipalities) as self-declared ‘GATS-free zones’. Members of parliament put questions to the government. The political debate then — temporarily — faded after the release of the Commission proposals on an NGO website.
The political debate stimulated a heavy inter-ministerial process, but problems were not found where the NGOs had indicated. Fabrice Gourdellier relates,
We started in November 2002 organizing sectoral meetings to identify the limits of our 1994 commitments, check the corresponding legislations, and assess our negotiating margins. In the end, we narrowed down to six sensitive issues needing discussion with the Commission. For the decisive 133 Committee meeting, only one technical problem was left, on Mode 4. We were not alone amongst member states. So the issue went to the Council of Ministers which eventually adopted the offer, with an interpretative statement. Mode 4 was especially difficult in the inter-ministerial debate because of conflicting bureaucratic cultures: DREE was unfamiliar with migration policies while the Department of Populations and Migrations had barely confronted the European process, much less the WTO.
Eventually, the services negotiations became peripheral to Cancún core political issues.
IV. Lessons for others
On its road to Cancún, France stuck to the European consensus and its long-term commitment towards progressive trade liberalization and multilateral negotiations. In so doing, French decision-making on trade revealed the following features.
- Overall, in keeping with theoretical predictions, protected producers are more likely to organize themselves efficiently when their interests are concentrated and their consumers dispersed. In a context of declining agricultural support, concentrated potential ‘losers’ proved very active. ‘There is a clear vision from the political level that our interests in the negotiations mainly involve agriculture, thus are fundamentally defensive’, confirms Anne Cazala.
- The national bureaucratic process influences decision-making in mitigating vested interests’ influence: economic analysis and the inter-ministerial co-ordination importantly contributed to the identification of France’s interests.
- The EU negotiating competences substantially impact the strategy of organized groups and the shaping of their interactions with domestic policy-makers and administrations.
- Consistency with Rodrik’s claim (1994) that ‘there is a natural status quo bias to policy-making whenever some of the gainers (or losers) from reform cannot be identified ex ante’. Most players’ perceptions support the claim. ‘Eventually our effort objectively to measure gains and losses was partly undermined by the macro-economic context of recession and the political interference of the CAP reform’, notes Christophe Lecourtier. The textile industry echoes: ‘Until Cancún we intensely promoted ambitious tariffs negotiations. There we felt overwhelmed by non-industrial stakes. Since then, the worsening economy, China’s soaring exports, and the approaching deadline for quota elimination changed the mood. Our companies are turning to more defensive demands.’ For Philippe Gros, ‘Our decision-making often leads us to favour defensive interests in the negotiations. A key problem is that the political level lacks a real “control board” to balance economic interests objectively.’
- France may lack more institutionalized government-to-business consultations on trade policy. Emmanuelle Butaud, director for international affairs at UIT, remarks: ‘Consultations take place on a case-by-case basis, usually under short notice linked with the 133 Committee’s agenda, and with little feedback afterwards.’ All business and agriculture representatives deplore the fact that they are denied access to official membership status in the French delegations to the WTO ministerial conferences. Business representatives therefore suggest that institutionalized consultations would significantly help in streamlining decision-making at national level and with interaction with the EU.
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