How the regulatory state differs. The constitutional dimensions of rulemaking in the European Union and the United States

摘要: Drawing on recent literature regulatory constitutionalism, this article examines the EU state in comparative perspective, using US as contrast case. We find that whilst most observers were preoccupied with high-level constitutional politics and Treaty of Lisbon, a quiet change was under way EU, triggered by mundane procedural requirements concerning rulemaking. compare first explaining factors behind institutionalization rulemaking requirements; then discussing effects change.