Application dans le temps des règlements de l’Union européenne

Application dans le temps des règlements de l’Union européenne

  • Posted by admin
  • On 2 février 2012
  • 5540 Comments

Ldroit-communautaire’application dans le temps des règlements de l’Union européenne n’est pas homogène. Certains précisent leur date d’entrée en vigueur, sans donner d’indication sur la date d’application. D’autres précisent leur date d’application sans préciser leur date d’entrée en vigueur. D’autres encore contiennent des dispositions transitoires. Inutile de dire combien ces éléments sont essentiels lors de la mise en œuvre de textes obligatoires et à effet direct. Le Règlement (CE) n°  864/2007 du Parlement Européen et du Conseil du 11 juillet 2007 sur la loi applicable aux obligations non contractuelles (Rome II) illustre parfaitement les difficultés qui peuvent en résulter. Il convient donc de saluer les éclaircissements apportés en ce domaine par un arrêt de la Cour de justice du 17 novembre 2011 (CJUE, 17 nov. 2011, Deo Antoine Homawoo contre GMF Assurances SA, C-412/10).

La victime d’un accident de la circulation, survenu en France le 29 août 2007, avait, le 8 janvier 2009, introduit une action en réparation de son préjudice devant une juridiction britannique (High Court of Justice). Un conflit de lois a été soulevé devant cette juridiction.

Chacune des parties invoquait une règle de conflit différente pour déterminer la loi applicable. Le demandeur revendiquait l’application du droit international privé anglais tandis que le défendeur (une compagnie d’assurances française) prétendait voir appliqué le Règlement (CE) n°  864/2007.

Aux termes de l’article 31, le Règlement « s’applique aux faits générateurs de dommages survenus après son entrée en vigueur ». Quant à l’artie 32, il dispose que le Règlement « est applicable à partir du 11 janvier 2009, à l’exception de l’article 29, lequel est applicable à partir du 11 juillet 2008 ».

Le Règlement ne s’applique pas aux faits générateurs de dommages survenus avant le 11 janvier 2009 : telle était la thèse du demandeur. La compagnie d’assurances prétendait au contraire qu’il était bien applicable en l’espèce puisque, conformément à l’article 31, le fait générateur était survenu après l’entrée en vigueur du règlement.

Certes, le Règlement ne prévoit aucune date d’entrée en vigueur. Mais, dans un tel cas, cette date doit être déterminée en vertu de l’article 297 § 2 al. 2 du Traité sur le fonctionnement de l’Union européenne qui dispose que : «  Les règlements, les directives qui sont adressées à tous les États membres, ainsi que les décisions, lorsqu’elles n’indiquent pas de destinataire, sont publiés dans le Journal officiel de l’Union européenne. Ils entrent en vigueur à la date qu’ils fixent ou, à défaut, le vingtième jour suivant leur publication. »

Le Règlement (CE) n°  864/2007 a été publié le 31 juillet 2007 au Journal officiel.  Il est donc entré en vigueur le 20 août 2007. L’accident étant survenu le 29 août 2007, il est bien survenu après l’entrée en vigueur.  Tout portait donc à croire que l’argumentation de la compagnie d’assurances pouvait prévaloir.

La Cour de Justice a finalement retenu la thèse défendue par la victime : « Les articles 31 et 32 du règlement (CE) n° 864/2007 du Parlement européen et du Conseil, du 11 juillet 2007, sur la loi applicable aux obligations non contractuelles («Rome II»), lus en combinaison avec l’article 297 TFUE, doivent être interprétés en ce sens qu’une juridiction nationale est tenue d’appliquer ce règlement uniquement aux faits, générateurs de dommages, survenus à partir du 11 janvier 2009 ».

Cette décision peut surprendre car elle paraît contraire à la lettre des textes. La Cour la fonde, d’une part, sur l’esprit du Règlement et, d’autre part, sur la logique juridique.

Pour ce qui est de l’esprit du texte, la Cour considère qu’ « Une telle interprétation est la seule qui permette d’assurer, selon les sixième, treizième, quatorzième et seizième considérants du règlement, le plein accomplissement des finalités de celui-ci, à savoir de garantir la prévisibilité de l’issue des litiges, la sécurité juridique quant à la loi applicable et l’application uniforme dudit règlement dans tous les États membres. »

L’argument est à double tranchant. Il n’est certes pas contestable que le principe de sécurité juridique doit se traduire par la possibilité de prévoir l’issue des litiges. Personne ne peut en outre discuter l’argument de l’uniformisation. Mais si la Cour avait retenu l’autre thèse, le droit aurait été tout aussi prévisible et la sécurité n’aurait pas été moindre.

Reste l’argument de logique juridique. La Cour souligne qu’en cas d’admission de la thèse de la différenciation des dates d’entrée en vigueur et d’application, « il n’est pas exclu que deux faits survenus le même jour, avant le 11 janvier 2009, puissent alors être régis par des lois différentes selon la date de l’engagement de la procédure en indemnisation ou celle de la détermination de la loi applicable par la juridiction saisie. De plus, les obligations découlant d’un fait qui a causé des dommages dans un même lieu à plusieurs personnes pourraient être régies par des lois différentes selon l’aboutissement des diverses procédures judiciaires. »

Certes, il n’est pas souhaitable de faire dépendre le choix de la loi applicable de la date de saisine du juge. Il convient aussi d’observer que l’arrêt présente l’avantage de la simplicité. Il n’en demeure pas moins que la lettre de l’article 31 semble militer en faveur de l’autre solution.

Sur un plan pratique, le règlement (CE) n° 864/2007 ne devra être mis en œuvre pour déterminer la loi applicable que si les faits générateurs se sont produits après le 11 janvier 2009. Il est inutile de relever que deux faits générateurs situés l’un juste avant, l’autre juste après cette date, seront traités différemment, ce qui est de nature à remettre en cause l’argument logique de la Cour.  Mais c’est là une constante dans l’inconstance du droit qui diffère dans le temps.

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