Comparing Canada, the European Union, and NAFTA: Comparative Capers and Constitutional Conundrums. Jean Monnet/Robert Schuman Paper Series, Vol. 3 No. 4, August 2003

(From the introduction). This is an exercise in comparative analysis. The paper examines Canada, the European Union, and the North American Free Trade Agreement (NAFTA). Its underlying premise - that political systems are best seen in comparative context - is an article of faith for students of comparative politics. Students of the European Union who began with the study of one or more of its member-states will have little problem with this, while those who started from International Relations and European integration studies will have greater doubts. Pooling the sovereignties of fifteen or more member-states, the European Union is in some respects sui generis. Although to be sure, it can be considered a multilevel system of governance, in some respects different from the federations with which it is often compared, the European Union is different enough to make any serious student of comparative politics pause. The EU, like many federal systems has complex decision-making procedures and impinges on the decision-making and sovereignty of its member-states, and appears as a single actor in international trade negotiations, but in other respects, it is very different: unlike many settled federations, the EU unites no well-defined people, and its inability to act as a single actor in foreign affairs or defense was documented well before current splits on Iraq and the Middle East. Difference has never stopped thoughtful students of comparative politics. The old adage that you can’t compare apples and oranges is easily met by noting that both are fruits. The EU may lack many features of federations but it is a complex multilevel system that may bear closer resemblance to lesser studied entities such as leagues and confederations. Examining the EU in comparative context is worthwhile not only because it gives us a clearer sense of what the EU is and is not, and how it has changed over time, but also because such regional systems like the EU are likely to become more common in an interdependent world.1 This paper is unorthodox: it compares the EU to another large trading bloc, the North American Free Trade Area (NAFTA) and to one of its components, Canada. Comparing the EU and NAFTA is straightforward and obvious enough. The two regional systems take in almost all of the world’s largest economies but are sufficiently different in their governance and politics that comparison in most areas can do little more than highlight difference. Comparing Canada and the EU is another matter. To some, the comparison may sound absurd, and appear to compare fruit and vegetables rather than apples and oranges. Nevertheless, Canada is a federation and a state, with membership in international organizations. However, it is not a pattern state from which models and theories have been extracted and does not figure prominently in the comparative literature. Like the EU, Canada can be considered unique and sui generis. It is difficult to find another country held together by two single-track railways, two broadcasting networks, (until recently) two airlines, and one very long border. That said, Canada’s center-periphery tensions, constitutional disputes, and disintegrative tendencies make it a case about which students of comparative politics should know more. The utility of this comparison will become more obvious if we consider not only current politics, but also the construction of the Canadian confederation (the official term), which was in some respects a battle, if not against nature, against geography and the pull of easier north-south relationships. We will begin by comparing the EU and NAFTA, highlighting differences and similarities, and then develop the more complex, but in many ways more tantalizing, Canada-EU comparison, and show why it is particularly relevant at a time, when the European Union’s constitution, like Canada’s, is in discussion.

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