Libre circulation des marchandises

Libre circulation des marchandises

  • Posted by Loïc Panhaleux
  • On 28 mars 2013
  • 5888 Comments
  • Libre circulation, Marchandises

La circulation des marchandises dans le marché intérieur peut être entravée de multiples manières par les Etats membres.

Afin de garantir une libre circulation, le droit communautaire s’est développé dans deux directions. D’un côté, la Cour de Justice (CJCE, aujourd’hui CJUE) a admis le principe de reconnaissance mutuelle dans l’arrêt Cassis de Dijon qui signifie qu’un Etat membre ne peut interdire la vente sur son territoire d’un produit légalement fabriqué selon des prescriptions techniques ou qualitatives difdroit-communautaireférentes de celles imposées à ses propres produits. Ce principe a poussé les Etats membres à adopter des normes communautaires. Nombreux sont ainsi les textes dérivés, notamment les directives d’harmonisation, dans des domaines particuliers qu’il faut considérer avant le droit primaire afin de vérifier si une réglementation viole la liberté de circulation des marchandises.

A défaut ou au-delà d’un texte spécial, le traité TFUE interdit dans ses articles 34 et suivants les restrictions quantitatives à l’importation ou à l’exportation ainsi que toutes mesures d’effet équivalent. La notion de restriction quantitative vise les contingents d’importation ou d’exportation ou les quotas qui constituent des mesures clairement protectionnistes des marchés nationaux. Ces dispositions visent à éviter que des produits d’autres Etats membres soient désavantagés par rapport aux produits nationaux.

A défaut de textes clairs, les mesures d’effet équivalent à des restrictions quantitatives (MEERQ) ont été définies par la CJUE. La définition traditionnelle résulte de l’arrêt “Dassonville du 11 juillet 1974 (CJCE, II juill. 1974, aff 8/74, Dassonville : Rec. CJCE, p. 837). Il s’agit de “Toute réglementation commerciale des Etats membres susceptible d’entraver directement ou indirectement, actuellement ou potentiellement le commerce intracommunautaire”.

Cette définition a été précisée dans un arrêt du 24 novembre 1993, “ Keck et Mithouard”(CJCE, 24 nov. 1993, aff C-267/91 et C-268/91, Keck et Mithouard : Rec. CJCE, 1, p. 6097). Le litige portait sur la réglementation française interdisant les reventes à perte. M. Keck et M. Mithouard étaient poursuivis en justice du fait de la violation de cette interdiction. Ils soutenaient que la réglementation française en cause était incompatible avec plusieurs dispositions du traité CE, dont l’article 28 (auj. 34 TFUE) parce qu’elle aurait privé les opérateurs d’un moyen de promotion commerciale, ce qui aurait réduit le volume des ventes, y compris en ce qui concerne les produits importés d’autres Etats membres. La Cour de justice a considéré qu’une législation nationale qui interdit de façon générale la revente à perte n’a pas pour objet de régir les échanges de marchandises entre les Etats membres et elle a posé le principe suivant : “n’est pas apte à entraver directement ou indirectement, actuellement ou potentiellement, le commerce entre les Etats membres,(…), l’application à des produits en provenance d’autres Etats membres de dispositions nationales qui limitent ou interdisent certaines modalités de vente, pourvu qu’elles s’appliquent à tous les opérateurs concernés exerçant leur activité sur le territoire national et pourvu qu’elles affectent de la même manière, en droit comme en fait, la commercialisation des produits nationaux et de ceux en provenance d’autres Etats membres”.

La Cour a précisé que les réglementations “ relatives aux conditions auxquelles doivent répondre ces marchandises (telles que celles qui concernent leur dénomination, leur forme, leurs dimensions, leur poids, leur composition, leur présentation, leur étiquetage, leur conditionnement) sont toujours soumises à l’interdiction prévue par l’article 28 du traité CE même si ces règles sont indistinctement applicables à tous les produits”.

Les mesures distinctement applicables sont donc toujours interdites en principe. En revanche, parmi les mesures indistinctement applicables, seules celles qui sont relatives aux conditions relatives aux produits sont interdites. En toute hypothèse, il convient d’analyser les éléments suivants pour déterminer si une MEERQ est constituée. En premier lieu, il convient de s’interroger sur la présence de marchandises. En second lieu, il convient de rechercher si l’on est en présence d’une mesure ou réglementation commerciale des Etats membres. Les activités d’organes publics, d’institutions normatives, administratives ou judiciaires sont prises en considération de même que toutes les règles d’administrations centrales, régionales ou locales. De même, l’exercice de pouvoirs réglementaires et disciplinaires relève de l’article 34 TFUE. Les actes d’ une organisation professionnelle du secteur de la pharmacie constituent, s’ ils sont susceptibles d’ influencer le commerce entre États membres, des “mesures” au sens de l’ article 28 du traité CE (CJCE, 15 déc. 1993, aff C-292/92, Hünermund Ruth : Rec. CJCE, I, p. 6816). Les mesures ne doivent pas forcément avoir un caractère contraignant ( affaire 249/81, Commission contre Irlande 1982, rec. 4005).L’inaction d’un Etat peut également être sanctionnée. Il en va ainsi lorsqu’il ne prend pas les mesures nécessaires pour rendre effectif le principe de libre circulation. La France a par exemple été condamnée pour ne pas prendre de mesures suffisantes pour empêcher des manifestations qui constituaient des entraves à la libre circulation des marchandises (aff. C- 265/95, commission c/ République française1997).

En troisième lieu, il convient de s’interroger sur l’objet ou l’effet de ces mesures. Celles-ci doivent être susceptible d’entraver directement ou indirectement, actuellement ou potentiellement le commerce intra-UE. Le commerce intra-UE est évidemment concerné lorsque l’on est en présence d’une réglementation concernant les produits nationaux et les produits d’autres Etats membres. Mais l’article 34 TFUE s’applique aussi à des faits purement internes qui n’impliquent pas dans les faits un mouvement intra-UE de marchandises. Il suffit que le marché intérieur soit potentiellement concerné (CJCE, 7 mai 1997, aff C-321 à 324/94, Pistre : Rec. CJCE, 1, p. 2343 ; v. n° 110; CJCE, 5 déc. 2000, aff C-448/98, Jean-Pierre Guimont : Rec. CJCE, 1, p. 10663 ; v. n° 110). Le transit lui-même est concerné (CJCE 23 octobre 2003, Rioglass et Transremar C-115/02).

Enfin, il faut rechercher s’il existe une restriction et si celle-ci porte sur les modalités de vente ou sur les conditions relatives aux produits. Dans le premier cas, la mesure n’est condamnable que si elle crée en fait ou en droit une discrimination entre les produits nationaux et les produits importés. Dans le second cas, elle est condamnable qu’elle soit distinctement ou indistinctement applicable. Ce dernier examen n’est pas en outre sans conséquences sur les exceptions admissibles. Elles sont de deux ordres.

D’une part, l’article 36 du traité TFUE prévoit certaines justifications. D’autre part, la jurisprudence a admis des justifications sur le fondement de l’article TFUE. Certains arrêts de la Cour pouvaient laisser penser que seules les premières pouvaient être mises en oeuvre en cas de mesures distinctement applicables tandis que toutes les exceptions pouvaient jouer en cas de mesures indistinctement applicables. La jurisprudence n’est en vérité pas d’une interprétation évidente de sorte que l’on peut, dans le cadre d’un recours, invoquer toutes les exceptions quitte à ne voir retenir que certaines d’entre elles. Le praticien se débarrasse ainsi à bon compte d’une question sur laquelle la doctrine hésite.Droit des affaires de l'Union européenne

Quelles sont ces justifications ? Aux termes de l’article 36 TFUE :“Les dispositions des articles 34 et 35 ne font pas obstacle aux interdictions ou restrictions d’importation, d’exportation ou de transit, justifiées par des raisons de moralité publique, d’ordre public, de sécurité publique, de protection de la santé et de la vie des personnes et des animaux ou de préservation des végétaux, de protection des trésors nationaux ayant une valeur artistique, historique ou archéologique ou de protection de la propriété industrielle et commerciale…” Les autres exceptions appelées exigences impératives sont relativement nombreuses. Il s’agit notamment du bon fonctionnement des services publics (CJCE, 7 mars 1990, C-362/88, GB-lnno-BM SA Confédération du commerce luxembourgeois : Rec. CJCE, 1, p. 667), de la protection de la loyauté des transactions commerciales (CJCE, 18 mai 1975, C-126-91, Yves Rocher : Rec. CJCE, 1, p. 2361), de l’’efficacité des contrôles fiscaux :(CJCE, 25 févr. 1988, C-299/86, Drexl . Rec. CJCE, p. 1213), de la protection de l’environnement (CJCE, 20 sept. 1988, C-302/86, Commission c/ Danemark Rec. CJCE, p. 4607) ou encore de la protection des consommateurs (CJCE, 12 sept. 2000, C-366/98, Yannick Geoffroy et Casino SNC : Rec. CJCE, I, p. 6596)…

La mise en oeuvre de ces exceptions est contrôlée par la CJCE. D’abord, l’article 36 TFUE lui-même dispose que “ces interdictions ou restrictions ne doivent constituer ni un moyen de discrimination arbitraire ni une restriction déguisée dans le commerce entre les États membres”. Par ailleurs, toute mesure nationale manifestement disproportionnée par rapport à l’objectif mis en avant au titre des justifications est contraire au droit communautaire, même si l’objectif est légitime (CJCE 23 septembre 2003, Commission/Danemark, C-C-192/01, Rec. p. I-9693). Une abondante jurisprudence de la CJCE rend compte des discussions relatives à la mise en oeuvre de ces exceptions. Dès lors qu’une réglementation restrictive ne peut être justifiée, elle est interdite au titre des articles 34 et suivants du traité.

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