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Indirect effect

Finally, even where Union law lacks direct effect, it may still have an indirect effect on the laws of member states, in the sense that a relevant provision of EU law may influence the interpretation of existing national laws of member states.

This proposition is sometimes known as the von Colson principle or the Marleasing principle after the leading cases of von Colson v Land Nordrhein Westfalen [1986] 2 CMLR 430 and Marleasing SA v La Comercial Internacional de Alimentacion SA [1992] 1 CMLR 305.

Table 1

Directly applicable? *Capable of direct effect?
Treaty Articles Yes Yes
Regulations Yes Yes
Directives No **Yes
Decisions Yes Yes

*A provision which is capable of having direct effect will not actually have direct effect unless it also satisfies the criteria for direct effect.

**Provided the Directive has not been implemented within the time allowed.

Table 2

Capable of vertical direct effect? Capable of horizontal direct effect?
Treaty Articles Yes Yes
Regulations Yes Yes
Directives Yes No
Decisions Yes Probably

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Source: Askey Simon, McLeod Ian. Studying Law. Macmillan Education,2014. — 239 p.. 2014

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