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Original article (peer-reviewed)

Journal European Foreign Affairs Review
Title of proceedings European Foreign Affairs Review


For decades, the EU and the US have been the most important "suppliers" of global trading rules. This widely shared understanding also applies to the area of government procurement, where bilateral EU-US concertation was crucial for the creation of the plurilateral WTO Government Procurement Agreement (GPA), which defines binding rules on non-discrimination and transparency in public procurement. Meanwhile, EU and US efforts to broaden the GPA membership base appear to hit a wall when it comes to emerging economies such as Brazil, India and China (BIC). In light of the latter's resistance to becoming GPA members, the paper investigates EU and US approaches to transfer procurement rules to emerging countries as well as the demand for procurement-related reform in the BIC. Relying on the expanded framework of external governance and policy diffusion, several insights emerge. Regarding coercive efforts, the EU – in its quest for market access – has developed a more assertive bargaining approach over time as compared to the US. EU actors hereby strategically invoke the openness of the EU procurement market, which itself is the product of regulatory capacity on the side of the European Commission. In contrast, US state-level fragmentation and entrenched discriminatory policies – due to the lack of a central regulatory authority – undermine US (and EU) efforts of pushing market openness abroad by inspiring emerging countries to introduce "bad" practices of protectionism against foreign companies. Regarding socialization-based efforts, both the EU and US aim to complement hierarchical with horizontal efforts of rule transfer through technical assistance. These strategies are, however, contingent on variance in the BIC's demand for external input, with Chinese authorities being more inclined to learn via bilateral technical assistance projects and to lock-in reforms through binding commitments as compared to India and Brazil. These insights are based on primary and secondary literature as well as extensive field research conducted in the EU, US, Brazil, India and China.