Master of Arts Thesis Euroculture

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Master of Arts Thesis

Euroculture

University of Groningen University of Göttingen

August 2016

Eurasian Integration as a Case of Policy Diffusion

Submitted by:

Maria Ananchenkova Student number: S2807351 (Groningen) 11541121 (Göttingen) maria.ananchenkova@gmail.com

Supervised by:

Dr. Marek Neuman (Groningen) Dr. Simon Fink (Göttingen)

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MA Program Euroculture

Declaration

I, Maria Ananchenkova, hereby declare that this thesis, entitled “Eurasian Integration as a Case of Policy Diffusion”, submitted as partial requirement for the MA Program Euroculture, is my own original work and expressed in my own words. Any uses made within this text of works of other authors in any form (e.g. ideas, figures, texts, tables, etc.) are properly acknowledged in the text as well as in the bibliography.

I declare that the written (printed and bound) and the electronic copy of the submitted MA thesis are identical.

I hereby also acknowledge that I was informed about the regulations pertaining to the assessment of the MA thesis Euroculture and about the general completion rules for the Master of Arts Program Euroculture.

Signed:

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Acknowledgements

The author would like to express her innermost gratitude to Prof. Dr. Elizabeth Goering, Indiana University – Purdue University of Indianapolis, for her guidance during the initial stages of the search for the right methodological approach to the empirical analysis in this MA thesis.

Many thanks go to Dermot John Nolan for his excellent proof-reading skills, and his help in obtaining many otherwise inaccessible readings that contributed to the author's views on the subject of the thesis.

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List of Abbreviations

ASEAN Association of Southeast Asian Nations

CES Common Economic Space

CIS Commonwealth of Independent States

CSTO Collective Security Treaty Organization

EaP Eastern Partnership initiative

ECJ European Court of Justice

ECU Eurasian Customs Union

EEC European Economic Communities

EEU Eurasian Economic Union

ENP European Neighborhood Policy

EU European Union

EurAsEC Eurasian Economic Communities

Mercosur Mercado Común del Sur, Southern Common Market

NAFTA North American Free Trade Agreement

RTA Regional Trade Association

SADC Southern African Development Community

SCO Shanghai Cooperation Organization

SES Single Economic Space

WST World Society Theory

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Introduction

Various integration projects have existed in the post-Soviet space since the collapse of the USSR. While many attempts to re-integrate the markets of the newly independent states have been described as “ink-on-paper” integration, reflected in a multitude of bi-and multilateral treaties bi-and agreements that lacked both institutionalization bi-and implementation, the Eurasian integration project is often considered as an unprecedented in the region1_{. Its relevance for the European Union [EU] and its}

neighborhood policy is evident, as the integration project targets some of the same countries that are part of the Eastern Partnership initiative. At the same time, its similarity to the EU in terms of institutional set-up presents a curious and under-researched phenomenon, that could be explained with the help of policy diffusion approach. This thesis, therefore, aims to study Eurasian integration, embodied by the Eurasian Customs Union and its successor, the Eurasian Economic Union, from the perspective of policy diffusion.

Initially introduced in 1994 by Nursultan Nazarbaev, the President of Kazakhstan, the idea of a Eurasian union was taken up again by the Russian leadership in 2007, when the creation of the Eurasian Customs Union between Russia, Belarus and Kazakhstan was announced. The integration plan outlined was ambitious, as it presupposed the block evolving from a customs union to a single economic space by 2012, and then to a full-fledged economic union by 2015. At the time of writing, the Eurasian Economic Union has officially existed for over 18 months and managed to add two more countries, Kyrgyzstan and Armenia, to its members.

The Eurasian Customs Union [ECU], and subsequently the Eurasian Economic Union [EEU], were aiming to achieve the level of integration comparable to that of the European Economic Communities [EEC] after the adoption of the Single European Act in a very short time. The fast pace of integration envisioned is not the only outstanding feature of this particular post-Soviet integration project. The ECU and the EEU were

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conceived as highly institutionalized bodies established by legally-binding agreements between member states, with power delegating from national governments to a supranational executive and a supranational dispute settlement mechanism – dimensions that were absent in the previous integration attempts.

These new developments in Eurasian integration cannot but remind the observer of the EU's integration framework. One could talk about the resemblance of the institutional and legal frameworks of the two Unions, the general rule-based character of cooperation, the widening and deepening ambitions of the ECU and the EEC, etc. It has been explicitly stated by (then prime minister) Vladimir Putin that the ECU and the EEU were inspired by the success of European integration2_{, as it was implied in much}

of the Russian official discourse. The scholarship on the subject also considers the institutional similarities between the integration projects in Eurasia and in Europe, sometimes treating them as a secondary feature of the ECU and EEU, and sometimes explicitly comparing the two integration processes and evaluating the success of the ECU in comparison with the EU3_{. These resemblances and references to the EU could}

be in fact an indication of policy diffusion from the EU to the ECU and the EEU, which would mean that the integration model and institutional design were borrowed, at least to a certain extent, from the EU.

The EU has been known to promote its policies and norms abroad. This promotion has been studied within external governance and Europeanization perspective, for example, mostly pertaining to the EU's influence on policies in accession, candidate and neighborhood states4_{. Since the circle of countries influenced}

2 Vladimir Putin, “Novyi Integratsionnyi Projekt dlya Evrazii: Budutchee, Kotoroe Rozhdaetsya Segodnya [A New Integration Project for Eurasia: the Future Being Born Today],” Izvestiya, October 3, 2011, http://izvestia.ru/news/502761. All the translations from Russian into English are done by the author, unless specified otherwise.

3 Steven Blockmans, Hrant Kostanyan, and Ievgen Vorobiov, “Towards a Eurasian Economic Union: The Challenge of Integration and Unity,” CEPS Special Report (Brussels: Center for European Policy Studies, December 2012), https://www.ceps.eu/publications/towards-eurasian-economic-union-challenge-integration-and-unity; Sean Roberts et al., “The Eurasian Economic Union: Breaking the Pattern of Post-Soviet Integration?” (The Finnish Institute of International Affairs, September 2014), http://www.fiia.fi/en/publication/439/the_eurasian_economic_union/.

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by the EU grew beyond the immediate neighborhood and candidate countries, scholars started to call for a consideration of these processes through a lens of policy diffusion, a strand of research in political science and international relations focusing on explaining adoption of similar policies and institutions in different states, without the coercive element of accession negotiations5_.

However, so far the similarities between the EU and the EEU have been treated by scholars as idiosyncratic or altogether bearing little relevance. The ECU and the EEU as a case of policy diffusion do not seem to be covered in the existing literature. This represents a clear gap in modern scholarship, and Eurasian integration studies could without a doubt benefit from a consistent assessment of diffusion processes behind this integration. This argument is further supported by the fact that similar cases of regional organizations as EU institutions and integration policy borrowers have been uncovered and discussed by researchers6_.

This thesis will, therefore, argue that Eurasian integration is indeed a case of policy diffusion, namely, a case of emulation of the EU institutional set-up and integration paradigm, and will consider the ways in which policy diffusion perspective can be applied to this subject. First, it will cover the developments in post-Soviet integration and consider the EEU and its structure in more detail to familiarize the reader with the object of research and its history. Signs of policy diffusion between the EU and the EEU will be discussed. Second, it will introduce various approaches to policy diffusion and review the scholarship on diffusion of EU-style integration. Third, the policy diffusion perspective will be applied to the Eurasian case, and the implications of diffusion studies for analyzing the EEU will be dwelt upon.

5 Tanja A. Börzel and Thomas Risse, “From Europeanisation to Diffusion: Introduction,” West

European Politics 35, no. 1 (January 1, 2012): 1–19.

6 See, for example: Karen J. Alter, “The Global Spread of European Style International Courts,” West

European Politics 35, no. 1 (January 2012): 135–54; Anja Jetschke and Philomena Murray,

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The consideration of relevant literature allows to formulate the following hypothesis concerning Eurasian integration as a case of policy diffusion:

The EEU can be considered an emulation of the EU, that can in turn be inscribed into World Society theory put forward by Meyer, Boli, Thomas and Ramirez7_.

If this hypothesis is correct, two elements should be observed: 1) the EEU will be discursively constructed along the script of a modern, rule-based integration regime, referring to the EU; 2) decoupling between discursive constructions, and practices and legislation will take place. To test this hypothesis, 25 interviews of Eurasian Economic Commission officials are analyzed employing thematic analysis methodology. It is then considered whether or not the EEU is conforming to the world cultural script, and possible signs of decoupling are considered. The approach to sampling, as well as the theoretical and methodological grounds for analysis are outlined in chapter 4 of the thesis, followed by the account of analysis results and their discussion.

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1. Integration in the Post-Soviet Space: Overview of Past and Recent

Developments

To appreciate the significance of current processes in Eurasian integration, it is first necessary to situate them in a historical context, and briefly review post-Soviet integration attempts up to the creation of the ECU in 2010. The institutional structure of the newest integrated polity – the Eurasian Economic Union – is then discussed to better understand the subject of this research and to pave the way for considering the EEU as a case of policy diffusion.

First, a terminology disclaimer is required. In the literature, both the terms “Eurasian” and “post-Soviet” integration are encountered. It would appear that the term “Eurasian integration” should be employed when talking about the most recent developments in the region, that usually bear the word “Eurasian” in their name (such as the Eurasian Economic Communities, the ECU and the EEU), while the term “post-Soviet integration” covers a wider number of phenomena in the post-“post-Soviet space (such as the Commonwealth of Independent States and others). It should also be mentioned that even though the literature uses the terms Common Economic Space [CES]1_and

Single Economic Space [SES]2_{to talk about the step preceding the creation of the EEU,}

in this thesis the latter is preferred, since the official discourse of the EEU refers to it as single, and not common, economic space.

1.1 A Brief Overview of Post-Soviet Integration

Integration (or re-integration) in the region has been ongoing since the collapse of the USSR in 1991, and represents a complex system of various organizations and

1 Steven Blockmans, Hrant Kostanyan, and Ievgen Vorobiov, “Towards a Eurasian Economic Union: The Challenge of Integration and Unity,” CEPS Special Report (Brussels: Center for European Policy Studies, December 2012), https://www.ceps.eu/publications/towards-eurasian-economic-union-challenge-integration-and-unity; Laure Delcour et al., “The Implications of Eurasian Integration for the EU’s Relations with the Countries in the Post-Soviet Space,” Studia Diplomatica 68, no. 1 (October 2015): 5–33.

2 Rilka Dragneva and Kataryna Wolczuk, “Eurasian Economic Integration: Insitutions, Promises and Faultlines,” The Geopolitics of Eurasian Economic Integration, LSE IDEAS, IDEAS Reports, June 2014; Aleksandr M. Libman and Evgenij Vinokurov, Holding-Together Regionalism: Twenty Years of

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arrangements, sometimes mutually contradicting3_{. This thesis is definitely not capable}

of covering the processes of this (re-)integration in detail. However, it appears important to briefly outline the history of post-Soviet integration before thoroughly discussing the peculiarities of one of the latest attempts in this area. The timeline of post-Soviet integration is available in Appendix 14_.

While Libman and Vinokurov make a case for the negotiations of a new Union Treaty in 1990 to be regarded as the first post-Soviet regional integration attempt5_{, most}

authors cited in this chapter concur that the creation of the Commonwealth of Independent States [CIS] simultaneously with the dissolution of the USSR marks the first step in the post-Soviet integration. The CIS, created by Belarus, Russia and Ukraine in 1991, counted all the former Soviet republics except the three Baltic states as members by 1993. The ex-Soviet states demonstrated a high degree of interest in preserving the existing economic ties on the one hand, and on alleviating possible shocks of dismantling the institutions of the USSR, on the other6_{. The objective of}

gradually deconstructing the institutional ties that bound the countries together within the USSR is often referred to as “a civilized divorce”, and the CIS is largely also regarded as an instrument to carry it out7_.

At the same time, CIS treaties are found to contain very ambitious provisions for future integration, spelling out plans for creation of a customs union, a payment union and a free trade area8_{. It is suggested that even back then, the European Union was}

regarded by the CIS countries as a “shining example” of successful regional

3 Libman and Vinokurov, Holding-Together Regionalism.

4 The timeline is adopted from the work by Libman and Vinokurov. The reader is encouraged to consult their work (see note 2 on the previous page) for a detailed overview of post-Soviet integration history.

5 Libman and Vinokurov, Holding-Together Regionalism, 37-38.

6 Julian Cooper, “The Development of Eurasian Economic Integration,” in Eurasian Economic

Integration: Law, Policy and Politics (Cheltenham, UK: Edward Elgar Pub, 2013), 15-16.

7 Julian Cooper, “Russia and the Eurasian Customs Union,” in Eurasian Economic Integration: Law,

Policy and Politics (Cheltenham, UK: Edward Elgar Pub, 2013), 82; Libman and Vinokurov, Holding-Together Regionalism, 39; Carol R. Saivetz, “The Ties That Bind? Russia’s Evolving

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integration9_{. In 1994, the President of Kazakhstan Nursultan Nazarbaev went as far as to}

suggest creating a “fully fledged Eurasian Union of States, an Eastern equivalent of the European Union” run by supranational institutions and covering a broad range of policies, not restricted to economics10_{. These ideas, however, did not receive support}

from the heads of the CIS states, and it soon became clear that it was perhaps too daring to formulate such objectives (even though brought up already back in 1994 they would eventually impact the most recent developments in post-Soviet integration). The ambitious agreements on economic integration aiming at establishing a payment union and a free trade area were not ratified by Russia11_.

If one looks closely at the framework of the CIS integration, it would appear that there were no instruments envisaged to ensure implementation of the far-reaching plans mentioned above. The CIS until today remains an under-institutionalized integration project, with a multitude of bilateral and multilateral treaties as its legal base which does not provide any mechanisms for enforcing implementation, while offering abundant possibilities for opt-outs or reservations for members who do not want to restrict their newly gained sovereignty in any way12_{. Even though certain authors call for recognition}

of the CIS as a socialization platform that arguably contributed to developing cooperation in such spheres as culture and education13_{, many still perceive it largely as}

“ink-on-paper integration” and a mere “forum of post-Soviet leaders without any clear agenda or binding powers”14_{. In other words, while numerous agreements have been}

signed between (varying) member states, little has been achieved in terms of actual economic integration.

If anything, the CIS managed the dismantling of remaining Soviet institutions, such as the ruble zone and the common defense, rather than the creation of new ones. What is more, due to its flexible membership and non-binding bilateral agreements as

9 Ibid., 41.

10 Cooper, “The Development of Eurasian Economic Integration”, 17. 11 Ibid., 17-18.

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its legal base, the CIS represented a regional grouping integrating at various speeds15_.

The countries belonging to the CIS also created their own integration projects, such as Central Asian Cooperation Organization between Kazakhstan, Kyrgystan, Uzbekistan and Tajikistan or GUAM (a union between Georgia, Ukraine, Azerbaijan and Moldova)16_{. Russia and Belarus negotiated first a Commonwealth, and then a Union}

State of Russia and Belarus, with ambitious plans to create a federation with a common citizenship, a single currency and a common foreign policy. However, this integration exercise is deemed to have been mostly rhetorical17_.

Among other integration initiatives that were happening simultaneously within the CIS but did not include all the CIS members, one should also mention the Collective Security Treaty Organization [CSTO] and the Shanghai Cooperation Organization [SCO]. Both organization have security and defense-related objectives. The CSO stands out in the post-Soviet integration initiatives, as it counts China among its members – a country that was never part of the USSR18_{. While these two organizations are of}

undisputed relevance for the geopolitics of the region, this thesis aims to focus on economic and political integration, namely, the Eurasian Customs and Economic Unions. That is why it is more important to cover the integrational attempts preceding the establishment of the EEU.

Since some of the CIS member states recognized the shortcomings of the existing institutional framework and the necessity of better coordination, further steps in deepening integration were to be taken. In 2000, Belarus, Kazakhstan, Kyrgyzstan, Russia and Tajikistan signed a treaty establishing the Eurasian Economic Communities

15 Ibid., 39-40.

16 Cooper, “The Development of Eurasian Economic Integration,” 18. GUAM is largely regarded as aimed at articulating the member states' preference of integrating with the European Union, rather than taking part in the Russia-led integration projects.

17 Libman and Vinokurov, Holding-Together Regionalism, 43.

18 Saivetz, “The Ties That Bind? Russia’s Evolving Relations with Its Neighbors”, 403-405. Interestingly, India and Pakistan are expected to join in 2017 (see “India, Pakistan Edge Closer to Joining SCO Security Bloc,” The Express Tribune, June 24, 2016,

http://tribune.com.pk/story/1129533/india-pakistan-edge-closer-joining-sco-security-bloc/.), which would make the block even less “post-Soviet”. For more information on the CSO, see Weiqing Song, “Interests, Power and China’s Difficult Game in the Shanghai Cooperation Organization (SCO),”

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[EurAsEC]19_{. As its goal, the EurAsEC had the establishment of a customs union and a}

single economic space, and it was governed by an inter-state council with consensus decision-making, as well as an integration committee with a weighted voting system and representation on the level of deputy ministers. While numerous agreements pertaining to different spheres of integration (agriculture, transport, energy, etc.) were adopted between the years 2004 and 2007, it was only after 2007 that any real progress in integration was made, as the above-mentioned agreements remained on the level of intentions20_{. Assessing the significance and the impact of the EurAsEC for the Eurasian}

integration remains outside the scope of this thesis. It is nevertheless worth noting that ultimately, it was within the EurAsEC that the ECU and the SES between Russia, Belarus and Kazakhstan were conceived. The preparations for these two bodies were decided upon in 200621_.

It is stressed in the literature that the ECU was a pattern-breaking development in post-Soviet integration. Generally, previous attempts at integration, as demonstrated above, were lacking commitment to implement the multilateral or bilateral treaties, had weak institutions and were further weakened through the absence of comprehensive legislation. The creation of the ECU was perceived as a qualitatively new stage in the post-Soviet integration, as this union boasted comprehensive treaties, supranational institutions formally endowed with regulation and dispute-settling authority, a legal personality, etc.22_{The EEU largely inherited the institutions of the Customs Union,}

having been conceived as the step following the establishment of a customs union and a single economic space23_{. This calls for a more careful consideration of these three steps}

in Eurasian integration, and an overview of the institutional structure of the EEU and its novelties.

19 It is often referred to by its Russian acronym, EvrAzES.

20 Cooper, “The Development of Eurasian Economic Integration”, 18-20. 21 Ibid.

22 Dragneva, Rilka, and Kataryna Wolczuk, eds. Eurasian Economic Integration: Law, Policy and

Politics. Edward Elgar Pub, 2013, chapter 1.

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1.2 The Eurasian Customs and Economic Unions: New Stages in Integration

The tripartite treaty establishing the Eurasian Customs Union was signed in 2007, and is described as “the only truly functioning integration institution in the FSU [Former Soviet Union]” and “one of the first post-Soviet initiatives exhibiting the attributes of a

truly supranational political institution”24_{. Further, Rilka Dragneva notes that the ECU}

represents an improved legal regime, that “claims to operate in transparent ways” and “is presented as a modern, rule-based common regime”, the creation of which was necessary to ensure the credibility and stability expected from an economic union25_{. The}

ECU institutional framework included a supranational commission and a court, as well as a high council and an intergovernmental council. These institutions and their functions were inherited by the EEU, and will be considered further in this section26_.

The ECU proved to be a rather efficient and rapid organization in terms of (at least formal) implementation, as on its entry into force already in 2010, it introduced a common external tariff and a customs code. With the creation of the Customs Union came the plans of deepening integration even further, via creation of a Single Economic Space [SES] and a fully-fledged Union – as it will be discussed further, some member states wanted the Union to ultimately become a political one, while others restricted it to the economic domain already at the planning stage. The introduction of the SES was supposed to abolish non-tariff barriers to trade and introduce the “four freedoms” of movement within the block. The project took off in 2009 within the ECU framework and the SES was formally declared in 2012, even though several provisions were not yet implemented27_.

The Eurasian Union, the next step of integration, is considered to have been

24 Libman and Vinokurov, Holding-Together Regionalism, 49. Emphasis in the original.

25 Rilka Dragneva, “The Legal and Institutional Dimensions of the Eurasian Customs Union,” in

Eurasian Economic Integration: Law, Policy and Politics (Cheltenham, UK: Edward Elgar Pub,

2013).

26 Blockmans, Kostanyan, and Vorobiov, “Towards a Eurasian Economic Union: The Challenge of Integration and Unity”; Dragneva, “The Legal and Institutional Dimensions of the Eurasian Customs Union.”

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launched by Putin in an article published in Izvestiya newspaper in 201128_{, although the}

idea (dating back to Nazarbaev's speech of 1994) first had resurfaced previously in 2010 in a declaration by EurAsEC Interstate Council at the presidential level29_{. It was Russian}

leadership that would most energetically advocate for the new project, and that would regard it as a (potentially) deeply integrated entity with a political dimension. While the two partner countries, especially Kazakhstan, were skeptical of such high-aiming plans, they expressed a desire to create a properly functioning SES and to do away with the declarative integration attempts of the past30_{. With this motivation in mind, the Eurasian}

Union treaty was signed in 2014, to enter into force on January 1st_{2015. The founding}

member states of the Union were the participants of the ECU: Russia, Kazakhstan and Belarus, Armenia and Kyrgyzstan joined in January and August 2015, respectively. While the implications of this development are discussed in the third chapter of this thesis, here the institutional structure will be introduced in order to underscore the scale of institutionalization of the EEU (and the ECU) and connect it to the possible diffusion processes behind Eurasian integration.

As stipulated in the Treaty on the Eurasian Economic Union, the structure of the Union consists of a Supreme Council, an Intergovernmental Council, a Commission and a Court31_{. The Supreme Council, consisting of heads of state of the member states, is the}

highest institution of the Union, meeting for a session at least once a year, with consensus decision-making32_{. In a way, its functions resemble those of the European}

Council of the EU, as the Supreme Council is in charge of elaborating the general strategies and directions of integration, and deciding on the principal questions of EEU activities. These agenda-setting powers are quite important in themselves, but the

28 Nicu Popescu, “Eurasian Union: The Real, the Imaginary and the Likely” (European Union Institute for Security Studies, September 2014), 7.

29 Cooper, “The Development of Eurasian Economic Integration,” 27. 30 Ibid., 29.

31 “Dogovor o Evrasijskom Ekonomichesko Soyuze [Treaty on Eurasian Economic Union],”, 2014, accessed June 29, 2016, http://www.eaeunion.org/files/history/2014/2014_2. pdf.

The Treaty is only available in the official languages of EEU member states. The Russian version of the treaty was considered by the author, and the translation into English was also carried out by the author. One could consult several sources in English on the institutional structure of the EEU: Delcour et al., Blockmans et al. and Dragneva (the two latter authors discuss the ECU, but the framework remained unchanged).

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competences of the Supreme Council reach even further, quite strongly regulating the work of other EEU institutions. It appoints the Chairman and approves the members of the Board of the Commission, one of the two institutions of the Union that are actually supranational (the second being the Court). It also approves the Statute of the Commission and the budget of the EEU, determining the contributions of member states as well. The judges of the Court are also appointed by the Supreme Council, after candidates are presented by member states. The Supreme Council rules on the questions on which consensus was not reached neither in the Commission, nor in the Intergovernmental Council. What is more, the Supreme Council holds the powers to negotiate and sign treaties with third countries (though in certain cases it may transfer those powers to the Commission) and to determine the mechanism of admitting new members into the Union 33_.

The Intergovernmental Council of the Union consists of heads of governments of the member states, convening at least twice a year and adopting decisions via consensus. The agendas of the sessions are compiled by the Commission on the suggestion of the member states34_{. The responsibilities of the Intergovernmental Council}

include ensuring implementation of the EEU legislation (that in its turn consists of the Treaty, the international agreements within the Union and the decisions of EEU institutions). The issues on which the Commission does not reach consensus are considered by the Intergovernmental Council. This Council is in charge of approving the draft budget (compiled by the Commission) and of introducing the candidates for Commission Board and Council to the Supreme Council for approval. It also decides on suspension of the Commission decisions35_.

The Eurasian Economic Commission is a permanent regulatory body of the EEU, consisting of the Council and the Board. It adopts decisions, orders and recommendations based on consensus (in the Council of the Commission) and on qualified majority (in the Board, with the exception of several sensitive issues –

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determined by the Supreme Council – on which decisions are adopted by consensus)36_.

The Commission enjoys regulating competences in quite a wide range of spheres, such as tariff and non-tariff trade regulation, phytosanitary and technical standards, macroeconomic and competition policy, energy, transport, public procurement, intellectual property, financial markets, industry and agriculture subsidizing, labor migration, and others37_.

The breakthrough development introduced first in the ECU and then inherited by the EEU is the binding character of Commission's decisions, and their direct applicability38_{. Its orders are of organizational nature and recommendations are, as}

follows from the name, non-binding. The Council of the Commission is composed of representatives of member states on the level of deputy minister in respective fields, and is supposed to propose general directions of integration to the Supreme Council39_{. The}

Board of the Commission is its executive body, its members are independent of their respective member states and cannot receive any directives from their governments. This resembles the EU Commission, whose members are supposed to be independent technocrats pursuing a common European agenda. The competences of the Eurasian Economic Commission include, among others, making proposals on integration direction and registering member states' proposals; adopting decisions, orders and recommendations; monitoring and controlling implementation of Union legislation, notifying member states of the necessity to implement; compiling a project of the Union budget and reporting on its implementation. The Commission Board consists of different sectoral departments, which are determined by the Supreme Council40_.

Another permanent institution of the Union is the Court of the EEU. Its main objective is to ensure uniform implementation of the Union legislation in all member

36 Ibid., art. 18.

37 Dogovor o Evrasijskom Ekonomichesko Soyuze [Treaty on Eurasian Economic Union], “Polozhenije o Evrazijskoj Ekonomicheskoj Kommissii [Statute on the Eurasian Economic Commission],” 2014, chapter 1.

38 Ibid.

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states41_{. The Court consists of 2 judges per member state, presented by the member}

states and appointed by the Supreme Council42_{. The Court handles disputes pertaining to}

the implementation of the Treaty on the Eurasian Economic Union and other Union legislation. Another development that is regarded as particularly innovative for post-Soviet integration within the ECU and the EEU is the empowerment of economic entities (enterprises and individual entrepreneurs) to bring disputes related to the Union legislation to the Court. Thus, the Court considers disputes addressed to it either by a member state or by an economic entity. The Commission may not sue a Member State for compliance, however, only possessing the power to point out a case of non-compliance. The Court rules on the compatibility among different pieces of the Union legislation, including Commission's decisions; on compliance of member states with the Union legislation; on challenging Commission's action or inaction. In case of economic entities, this applies to cases when the rights or legal interests of an entity are breached. The Court handles disputes after they have been addressed to the member state or the Commission and could not be settled on that level. The Court also clarifies the provisions of the Union legislation upon request from member states or Union institutions. The decisions of the Court are binding to the parties43_.

Thus, having analyzed the institutional framework of the EEU, one can confirm the opinions of researchers who regard the ECU and its successor as significantly new developments in post-Soviet integration. At the same time, one can observe that the institutional framework of the EEU is to a certain extent similar to that of the EU, with intergovernmental Councils deciding on the directions of integration, a partly supranational Commission regulating and monitoring the integration, and a Court clarifying the legislation provisions as well as settling disputes between the stakeholders. Even the terminological resemblance itself is rather remarkable. The overall direction of integration seems to be following the European pattern as well, from a customs union through single economic space to an economic union (that some

41 Dogovor o Evrasijskom Ekonomichesko Soyuze [Treaty on Eurasian Economic Union], “Polozhenije o Sude Evrazijskogo Ekonomicheskogo Soyuza [Statute on the Court of the Eurasian Economic Union],” 2014, chapter 1.

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member states might prefer to evolve into a political one), while some plans to establish a common currency resurfacing once in a while44_{. True, there is a marked preference for}

intergovernmental consensus-based decision-making, with most powers ultimately concentrated at the level of heads of states, while the EU has a much more pronounced supranational dimension. But considering the young age of this integration project, institutionalization and sovereignty transfer levels are indeed quite high.

Therefore, questions arise as to what motivated this deepening of integration and enhancement of institutionalization, and what implications can these developments have for the post-Soviet integration as well as for the EU relations with the countries in the region. As demonstrated in chapter 3, these questions were addressed by many scholars, and their research provides an important context for this thesis. At the same time, considering rather different historic, political and economic realities of the EEU when compared to the EU, one could wonder why the choice was made in favor of this particular framework, resembling the EU to such an extent. It will be argued that policy diffusion approach can be applied to analyzing this integration project, since the similarities mentioned are an outcome of policy diffusion, and could be a relevant factor for a better understanding of the integration processes in the post-Soviet space.

1.3 The EEU and the EU: Signs of Policy Diffusion

The resemblance between the EU's and the EEU's institutional frameworks has led many authors to suggest that EU's activities in the neighborhood not only inspired the creation of a competitive integration project, emerging in reaction to the normative influences of the EU in the region, but also served as a template for regional integration45_{. If one follows the definition by Elkins and Simmons, policy diffusion}

boils down to uncoordinated interdependence between two actors, where the adoption of a policy or a trait by one actor entails adoption by the other46_{. Thus, if the EU was an}

44 For example, see an overview by Dmitry Kondratov, “Problemy Sozdaniya Valjutnoj Zony v Evrazijskom Ekonomicheskom Soyuze [The Problems of Creating a Monetary Union in the EEU],”

Eurasian Economic Integration, no. 3 (28) (August 2015),

http://www.eabr.org/general/upload/no._3_28_2015.pdf.

45 David Cadier, “Eurasian Economic Union and Eastern Partnership: The End of the EU-Russia Entredeux,” The Geopolitics of Eurasian Economic Integration, LSE IDEAS, IDEAS Reports, June 2014, 62.

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inspiration of the ECU and the EEU, and the adoption of this particular institutional framework was motivated by European integration, one could talk of Eurasian integration as a case of policy diffusion. The signs of such a diffusion process are considered in this section.

In a broad sense, the EU's influence is noticeable in the focus switch of integration to the economic domain, with emphasis on harmonization of standards and regulations47_{. Popescu concurs that the EEU institutional framework, if only partly, was}

modeled after the EU. He also directly compares the development of the two integration projects, thereby suggesting that they can be considered as equivalent48_{. Delcour agrees}

that Russia has been using EU's norms, though selectively, rather than developing its own institutional framework for integration49_{. This inscribes in the general paradigm of}

scholarship on Eurasian integration that seeks not only to explain the processes and predict further development of integration, but also provides recommendations on how this integration should proceed. Many authors believe that the Eurasian Economic Union should actively learn from the EU's experience and follow its steps when it comes to deepening integration50_{. In this way, even if not explicitly talking about policy}

diffusion from the EU to the EEU, these authors presuppose that it has indeed taken place and even encourage it to continue if the EEU is to be successful.

When stating that the EU has served as a model for Eurasian integration project, many researchers refer to Vladimir Putin's article published in October 2011, during his campaign for a third presidential term51_{. In this text, Putin announced the plans for}

Annals of the American Academy of Political and Social Science 598 (2005), 35.

47 Cadier, “Eurasian Economic Union and Eastern Partnership: The End of the EU-Russia Entredeux,” 62.

48 Popescu, “Eurasian Union: The Real, the Imaginary and the Likely,” 9, 13.

49 Laure Delcour, “Between the Eastern Partnership and Eurasian Integration: Explaining Post-Soviet Countries’ Engagement in (Competing) Region-Building Projects,” Problems of Post-Communism 62, no. 6 (November 2, 2015): 318.

50 Blockmans, Kostanyan, and Vorobiov, “Towards a Eurasian Economic Union: The Challenge of Integration and Unity”; Christopher A. Hartwell, “A Eurasian (or a Soviet) Union? Consequences of Further Economic Integration in the Commonwealth of Independent States,” Business Horizons 56, no. 4 (July 2013): 411–20; Karina Ponomareva, “Tax Law of the Eurasian Economic Union: Substance and Ways of Using of the European Experience,” EC Tax Review 25, no. 2 (April 2016): 94–108.

51 Carolina Vendil Pallin, “Future Approaches to the Shared Nighbourhood,” Russian Futures: Horizon

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further development of the Customs Union into the Eurasian Economic Union, and affirms that the EU served as a template as well as a “gold standard” for integration52_.

With this in mind, Roberts and colleagues explain the teleology of many studies of the EEU, as they assume that much like the European space, the post-Soviet space is destined for ever closer integration53_.

In this respect, the Center for European Political Studies special report on Eurasian integration stands out among the numerous works on the subject. The report explicitly compares the EEU and the European Economic Communities [EEC] (as of 1957) according to three types of conditions: background, formation and process. Various geographic, economic, and institutional factors are also taken into account, while the conclusion contains recommendations on improvement of the institutional framework and the implementation of the ambitious integration programs completely relying on the EU experience in this respect, as if the Eurasian integration project will inevitably repeat the life cycle of its European counterpart and, perhaps, competitor54_.

Vinokurov follows the general trend when he suggests that the Eurasian Union should learn from the EU also when it comes to its relations with the third countries, and introduce a program similar to European Neighborhood55_{. This supports the opinion that}

the normative attraction of the EU played an important role when the institutional and legal frameworks of the ECU and the EEU were being designed56_.

It should be mentioned that Libman and Vinokurov even trace the influence of the EU experience on post-Soviet integration back to 1994-2002, saying that already in the early nineties the “shining example” of European integration became the beacon for

ex-Pattern of Post-Soviet Integration?”

52 Vladimir Putin, “Novyi Integratsionnyi Projekt dlya Evrazii: Budutchee, Kotoroe Rozhdaetsya Segodnya [A New Integration Project for Eurasia: the Future Being Born Today],” Izvestiya, October 3, 2011, http://izvestia.ru/news/502761.

53 Roberts et al., “The Eurasian Economic Union: Breaking the Pattern of Post-Soviet Integration?,” 5. 54 Blockmans, Kostanyan, and Vorobiov, “Towards a Eurasian Economic Union: The Challenge of

Integration and Unity.”

55 Evgenij Vinokurov, “Pragmaticheskoye Evrazijstvo [Pragmatic Eurasianism],” Rossija v Global’noj

Politike [Russia in Global Politics], no. 2 (2013),

http://www.globalaffairs.ru/number/Pragmaticheskoe-evraziistvo-15950. Many articles in the 56 Igor Gretskiy, Evgeny Treshchenkov, and Konstantin Golubev, “Russia’s Perceptions and

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Soviet states in their re-integration attempts. However, the ambition to follow the European path to integration seems to have been mostly declarative back then and did not entail any direct institutional borrowing57_{. In connection to this, Dragneva cites the}

1999 Treaty on the Customs Union and the Single Economic Space to underline its terminological similarities with the EU treaties, but ultimately states that the emulation ended on the lexicon level, as the Treaty failed to create an efficient institutionalized regime and the integration rolled back58_{. The ECU of 2010, in contrast, is perceived as a}

“break-from-the-past” in terms of introducing the legally-binding, normative, market liberalization and harmonization dimensions to the previously inefficient post-Soviet integration. Dragneva and Wolczuk posit that the ECU's design reflects the institutional learning that has occurred, as well as an aim to follow the example of the EU, that is often imitated within the Eurasian project as the most successful and at the same time the normatively attractive integration regime59_{. Thus, one could suppose that policy}

diffusion has been happening already while setting up the ECU, although explicit references to it (as in Putin's article) emerged when the EEU creation was announced.

Therefore, two important preliminary conclusions can be drawn. First, the institutional dimension of the EEU is very similar to the EU, with supranational delegation, a dispute settlement mechanism with potential influence on integration, intergovernmental councils, a supranational executive with weighted voting, as well as general objectives and the foreseen path of integration. Direct references to the experience of the EU and its importance are made by the leaders of the member states60

and is acknowledged by the quoted researchers of post-Soviet integration and international relations, referring to the EU as the template for the ECU and the EEU. Second, several members of the academic community seem to perceive the EEU as a

57 Libman and Vinokurov, Holding-Together Regionalism, 41.

58 Dragneva, “The Legal and Institutional Dimensions of the Eurasian Customs Union,” 48.

59 Rilka Dragneva and Kataryna Wolczuk, “Commitment, Asymmetry and Flexibility: Making Sense of Eurasian Economic Integration,” in Eurasian Economic Integration: Law, Policy and Politics (Edward Elgar Pub, 2013), 218.

60 Alexandr Lukashenko, “O Sud’bakh Nashej Integracii [On the Destiny of Our Integration],”

Izvestiya, October 17, 2011, http://izvestia.ru/news/504081; Nursultan Nazarbaev, “Evrazijskij Soyuz:

Ot Idei K Istorii Budutschego [The Eurasian Union: From an Idea to the History of the Future],”

Izvestiya, November 25, 2011, http://izvestia.ru/news/504908; Putin, “Novyi Integratsionnyi Projekt

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direct borrower of policies from the EU, and insist on the applicability of the EU experience to the Eurasian case, which results in analyses and recommendations of how the EEU should learn from its successful Western neighbor. Thereby they implicitly acknowledge that certain policy borrowing is taking place. These two conclusions would lead one to believe that policy diffusion has indeed been taking place between the two polities, and that the institutional resemblance can at least partly be attributed to it. However, this feature never became the main focus of analysis, while it appears to be quite an important one for a better understanding of the integration processes in the post-Soviet space.

The fact that no studies seem to explicitly apply policy diffusion perspective to the case of Eurasian integration could be attributed to the relative novelty of the phenomenon: it is indeed rather young and has not been developing long enough to be studied in detail. However, it should be mentioned that there exist studies of policy transfer to Russia, pertaining to various policy fields, such as nature preservation, pension reform, tax law, etc61_{. But even when researchers consider norm transfer from}

the EU to the EEU in such fields as tax harmonization, they do not inscribe these studies into the theoretical framework of policy diffusion, concentrating instead on the similarities or differences in policies and possible improvements. Nevertheless, there exist prerequisites that would allow to treat the Eurasian case as an instance of policy diffusion, as demonstrated in this section. First and foremost, it is needed to address policy diffusion research and see what instruments it offers for analyzing the case of Eurasian integration.

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2. Policy Diffusion and Diffusion of Regional Integration Models

Since it is relevant to consider the Eurasian integration processes from the point of view of policy diffusion, it is necessary to briefly review the existing approaches to diffusion studies, and then discuss research on diffusion of European integration models and diffusion of regionalism in more detail. It is expected that the insights of policy diffusion theory will help gain a better understanding of why the particular institutional framework similar to the EU was adopted in the case of Eurasian integration.

2.1 Policy Diffusion Approach: Overview

Policy diffusion approach seeks to interpret institutional similarities, as well as spatially and/or temporally clustered policy adoption in the world of a great economic and political diversity. In other words, policy diffusion scholars stress the fact that at times policies are adopted in different countries and regions within short periods of times, creating a wave-like effect, while domestic conditions of adopters are often quite different. Therefore, policy diffusion approach would state that functional demands of policy change are not necessarily sufficient to explain this or that policy choice, and decisions of policy-makers across different countries are ultimately interdependent: adoption of a certain policy in one place might trigger its adoption in another and so on1_.

Policy diffusion, then, could on the one hand explain the institutional similarities between the two polities, the EU and the EEU, and on the other hand, can be drawn upon since so many commentators and researchers noticed the interdependence of these two actors: the EU's presence in the Eastern neighborhood is supposed to have influenced Russian geopolitical choices and ultimately contributed to the development of the Eurasian project2_.

The scope of diffusion research is quite well summarized by Dolowitz and Marsh, who dissect the process of policy diffusion and consider its following aspects: the motivation for diffusion (varying from voluntary desire to learn to imposition of

1 Erin R. Graham, Charles R. Shipan, and Craig Volden, “The Diffusion of Policy Diffusion Research in Political Science,” British Journal of Political Science 43, no. 03 (July 2013): 673–701.

2 See, for example, Rilka Dragneva and Kataryna Wolczuk, eds., Eurasian Economic Integration: Law,

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policies), actors involved in transferring policies, subjects of transfer (policies, goals, instruments, etc.), degrees of transfer and constraints to it, reasons for failure of diffused policies3_{. Thus, policy diffusion scholars try to explain which factors contribute to the}

diffusion and which forms it might take.

Policy diffusion, being a very fruitful field of studies, is still far from being a unified one. In their account of the “diffusion of diffusion studies” Graham, Shipan and Volden provide over a hundred different terms used as synonyms to policy diffusion in different studies4_{. Consequently, no universally applied definition of diffusion exists,}

and quite often the definition is not even provided in research, but rather an intuitive understanding of what policy diffusion is is implied by the respective author. Since there is no unified definition, understanding of what constitutes diffusion varies from one work to another. For example, whether or not to regard coercion and coordination as a mechanism of policy diffusion depends on which authors one chooses to follow5_.

Generally, diffusion scholars would sub-divide different types of diffusion into such categories as coercion, coordination, competition, learning and emulation, consider different types of rationality used in the policy choice, as well as different motivations behind the choice.

The numerous diffusion studies inspired scholarship that concerns itself with diffusion of European integration models and institutions, as well as with the spread of regionalism. This scholarship is also relying on the general diffusion paradigms, but appears to bear even more relevant implications to the study of the Eurasian case.

2.2 Diffusion of the EU Integration Models and Diffusion of Regionalism

Works on policy diffusion from the European Union, particularly those concerned with the institutional framework of the EU, are of special interest to this thesis. In fact, the

3 David P. Dolowitz and David Marsh, “Learning from Abroad: The Role of Policy Transfer in Contemporary Policy-Making,” Governance 13, no. 1 (January 2000): 9.

4 Graham, Shipan, and Volden, “The Diffusion of Policy Diffusion Research in Political Science.” 5 Compare, for example: Frank Dobbin, Beth Simmons, and Geoffrey Garrett, “The Global Diffusion

of Public Policies: Social Construction, Coercion, Competition, or Learning?,” Annual Review of

Sociology 33 (2007): 449–72; and Zachary Elkins and Beth Simmons, “On Waves, Clusters, and

Diffusion: A Conceptual Framework,” Annals of the American Academy of Political and Social

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study of policy diffusion has gained a new momentum in the 1990-s, along with deeper European integration and the EU enlargement, although research in this field has been mostly carried out in the terms of Europeanization. The European Union has been studied as one of the major “diffuser” of norms, institutions and policies to its accession states and to the countries in the European neighborhood, even though the process of norms and institutions transfer was not referred to as “diffusion”, and research was not integrated in the field of policy diffusion studies6_.

This approach was challenged in 2012, when a special issue of West European

Politics was dedicated to the studies of Europeanization and diffusion. In this special

issue, Börzel and Risse argue that policy diffusion perspectives can and should be applied to Europeanization studies. According to the researchers, this would allow to consider the spread of EU policies to third countries that are not EU accession candidates, and to add agency to otherwise passive “recipients” of European policies and integration models. The authors subdivide diffusion into direct and indirect, pointing out that direct diffusion is present when the EU is actively promoting its policies and regulations, while indirect diffusion does not necessitate active involvement of the EU. Within the first type of diffusion Börzel and Risse name manipulating utility calculations through positive and negative incentives, providing an authoritative model (socialization) and promoting ideas as legitimate or true (persuasion). According to the authors, outside of the accession and neighborhood states circle, indirect mechanisms of diffusion will prevail. These mechanisms include functional emulation (competition or lesson-drawing; aimed at solving a particular functional problem) and normative emulation (aimed at legitimizing the “borrower” on the world stage)7_.

For the present thesis, it is particularly important to consider European Union influences (both intentional and not) on integration projects in other regions of the world. While such integration projects as Association of South-East Asian Nations [ASEAN], Southern Common Market, or Mercado Común del Sur [Mercosur] and

6 See, for example, Sandra Lavenex and Frank Schimmelfennig, “EU Democracy Promotion in the Neighbourhood: From Leverage to Governance?,” Democratization 18, no. 4 (August 2011): 885– 909.

7 Tanja A. Börzel and Thomas Risse, “From Europeanisation to Diffusion: Introduction,” West

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Southern African Development Community [SADC] have been studied within the regionalist school of thought, describing these and other regional blocks and the influence the EU exercises on them8_{, they had not been addressed explicitly as cases of}

policy diffusion before 20099_{. Several articles in the aforementioned special issue}

address these regional integration projects10_{. It is clear that this new approach could}

benefit our understanding of regional integration processes, and the results of these studies should be taken into account while analyzing the EEU.

To begin with, researchers remark that the spread of EU integration policies has become an important part of its foreign policy. Börzel and Risse note that “[t]he promotion of regional integration has become part of the governance package the EU seeks to export (…) [It has] developed into one of the foundations of its foreign policy”11_{This opinion is shared by the scholars of regionalism, who posit that the EU}

actively seeks to export its model to the outside world, and according to the findings of regionalists, has at least partly succeeded in doing so12_{. Lenz, on the other hand, takes a}

slightly different perspective on the matter, stressing the indirect mechanisms and unintentional diffusion, as he argues that the spread of regionalism has become an integral part of Europe's normative power, resting on its ability to diffuse its norms and experience of regionalism through socialization and emulation13_{. From both}

perspectives, the EU has been proven to be the “diffuser” of its regional integration policies and regionalism in general.

The EU, whether intentionally or not, has become an example to be followed by

8 Philippe de Lombaerde and Michael Schulz, eds., The EU and World Regionalism: The Makability of

Regions in the 21st Century, The International Political Economy of New Regionalisms Series

(Farnham, England ; Burlington, VT: Ashgate, 2009).

9 Tanja A. Börzel and Thomas Risse, “Diffusing (Inter-) Regionalism: The EU as a Model of Regional Integration,” KFG Working Paper Series, Freie Universität Berlin, KFG “The Transformative Power of Europe,” no. 7 (September 2009),

http://userpage.fu-berlin.de/kfgeu/kfgwp/wpseries/WorkingPaperKFG_7.pdf.

10 For example, Karen J. Alter, “The Global Spread of European Style International Courts,”; Anja Jetschke and Philomena Murray, “Diffusing Regional Integration: The EU and Southeast Asia,”; Lenz, “Spurred Emulation.”

11 Börzel and Risse, “Diffusing (Inter-) Regionalism: The EU as a Model of Regional Integration,” 10. 12 Lombaerde and Schulz, The EU and World Regionalism, 287–288.

13 T. Lenz, “EU Normative Power and Regionalism: Ideational Diffusion and Its Limits,” Cooperation

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other regional integration projects by being a showcase of very successful regional integration. Even in times of crisis, the EU possesses a very powerful narrative, that remains highly attractive to other countries pursuing regional integration14_{. After}

reviewing several studies on the spread of EU integration policies abroad, Börzel and Risse conclude that the prevalence of the EU model (at least at the starting point of the integration attempts) can only be explained by the symbolic stance that the EU holds – it is the example of economic integration that everybody turns to15_.

However, while the EU remains the “gold standard” of integration, its policies are not known to be completely “downloaded” by other regional organizations. In other words, “blind mimicry” of the EU does not seem to occur. It is thus concluded that diffusion “requires agency” in the sense that the borrower needs to decide to adopt the policy (especially when one considers countries with little or no membership perspective and therefore with which the EU does not have much leverage), and on the other hand the borrower needs to adjust the policy or the institutional framework to its particular domestic situation with all the structural limitations, political considerations, norms and so on16_.

Therefore, the adoption of EU integration model or institutional framework is not expected to result in a proliferation of EU copies. The adoption of EU policies generally tends to be selective rather than comprehensive, ASEAN, Mercosur and SADC have demonstrated17_{. Domestic structural conditions tend to stand in the way of complete}

copying of integration policies. Among such conditions are physical and institutional resources, as well as local norms and causal beliefs that might serve as a limit to EU diffusion. An important value in this respect is that of sovereignty: as the example of ASEAN countries illustrates, the borrowers of EU policies are not always eager to adopt supranational institutions because they are regarded as breaching on sovereignty.

14 Ibid., 215.

15 Tanja A. Börzel and Thomas Risse, “When Europeanisation Meets Diffusion: Exploring New Territory,” West European Politics 35, no. 1 (January 2012): 192–207.

16 Ibid., 197.

17 Anja Jetschke and Philomena Murray, “Diffusing Regional Integration: The EU and Southeast Asia,”

West European Politics 35, no. 1 (January 2012): 175–176; Tobias Lenz, “Spurred Emulation: The

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Another scope condition of particular importance, for ASEAN among other borrowers, is institutional: the institutional capacity of the ASEAN states in insufficient to perform comprehensive borrowing of EU institutions18_{. Even though the EU norms are not}

completely rejected, they might be altered, which in turn leads to a change in institutional practices19_{. Thus, diffusion of institutional framework of the EU is usually}

selective and not comprehensive, the outcome being strongly influenced by domestic factors and actors, who adjust the borrowed policies.

When it comes to the mechanisms of diffusion at work in non-accession states and regions, they seem to be mostly indirect. Such direct mechanisms of diffusion as coercion or conditionality are considered to be irrelevant for the cases where there are no strong material incentives connected to policy adoption20_{. Lenz distinguishes this}

particular type of diffusion as “ideational”, i.e. not employing material means. This diffusion happens, in this way, without the EU actively changing the recipients utility calculations, but rather through changing their behavior and identity21_{Importantly, Lenz}

demonstrates that ideational diffusion processes do not need to be directly stimulated by the EU, and even if certain influence of the EU on region-building is present, as in the case of Mercosur, the eventual adoption of EU-like institutions and norms takes place due to the activities of local actors, rather than because the EU is “meddling in”22_{. The}

same trend is remarked by scholars of regionalism, who concur that the EU model spreads around the world even when there are no direct efforts to promote it23_{. Policy}

diffusion approach is supposed to offer more explanatory potential for exactly such cases where the hierarchical pressure from the EU, or even the direct relationship between two polities, is absent24_.

Interestingly, it is stressed that the EU might promote its norms not only in the culturally proximate polities, but also in non-liberal countries. When it comes to

18 Jetschke and Murray, “Diffusing Regional Integration,” 186–187. 19 Lenz, “EU Normative Power and Regionalism,” 219.

20 Jetschke and Murray, “Diffusing Regional Integration,” 178–179. 21 Lenz, “EU Normative Power and Regionalism,” 212–214. 22 Ibid., 216–217.

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authoritarian regimes and democratizing countries, the EU would not generally engage in too much of active policy diffusion – partly because the “limited statehood” characteristics of these countries impose some structural limitations on the possibilities of borrowing, partly out of a risk of destabilizing the regimes25_{. Besides, Jetschke and}

Lenz expect regional integration policies to “trickle down” form more developed or democratic countries to less developed and democratizing countries26_.

This brings about another important conclusion of regionalism diffusion studies (in particular, those concerned with the spread of the EU integration model): diffusion also happens in “unexpected” or “unlikely” cases, between polities that have very little in common, and despite the skepticism of the commentators. Certainly, it does not end up in completely same institutions, but nevertheless can lead to quite considerable changes, as in the cases of Mercosur and ASEAN27_{. This goes contrary to the accounts}

that see diffusion likely only given the similarities between the “diffuser” and the “borrower”, or the need for normative complementarity for the external norms to become “empowered” at home28_.

What are precisely these indirect mechanisms of diffusion that are at work? According to the majority of researchers, empirically mostly lesson-learning and emulation are encountered. To differentiate between emulation and lesson-drawing, Lenz suggests to concentrate on the process of choosing an institutional or policy solution. When there is clear deliberation between several options in a situation of a functional demand for institutional change, lesson-drawing occurs. When means-ends relationships are uncertain and the goals of adopting a policy are ambiguous, emulation is likely to be encountered29_{. Comparing the cases of ECJ model adoption in Mercosur}

and SADC Lenz remarks, that in the first case the diffusion was likely happening in the

25 Börzel and Risse, “When Europeanisation Meets Diffusion,” 198–201.

26 Anja Jetschke and Tobias Lenz, “Does Regionalism Diffuse? A New Research Agenda for the Study of Regional Organizations,” Journal of European Public Policy 20, no. 4 (April 2013): 632.

27 Lenz, “EU Normative Power and Regionalism,” 215.

28 Jeffrey T. Checkel, “Norms, Institutions, and National Identity in Contemporary Europe,”

International Studies Quarterly 43, no. 1 (March 1999): 83; Martha Finnemore and Kathryn Sikkink,

“International Norm Dynamics and Political Change,” International Organization 52, no. 4 (1998): 887–917.

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spirit of lesson-learning, inspired by a functional need, while in the second it was triggered by a need to ensure the legitimacy and credibility of the organization, and the actual functionality of the court was circumscribed30_.

While discussing possible mechanisms of policy diffusion, it is necessary to consider the motivations of the borrower as well. The existing scholarship demonstrates that the motives of policy adopters are rather complex, stemming from different types rationalities and, therefore, entailing different methods of diffusion. Mostly the authors mention direct functional needs that lead to policy change, or symbolic needs, usually connected with enhancing legitimacy of regional organizations or their member states31_.

For example, in their account of EU policy diffusion to ASEAN, Jetschke and Murray demonstrate that the motives for adoption of new policies and the preferences for the EU model in particular resulted from a complex interplay of various functional (adjusting the organization to the altered conditions in the global economy) and symbolic (recognition on the world stage) needs32_.

At the same time, some authors claim that regional organizations are often created even when there are no functional needs for them. The fact that countries create regional integration projects without necessarily having functional demands or economic prerequisites for integration calls the functionalist integration perspective, that has been dominant in the field, into question. In this connection, the cases of “non-performing” organizations are also outliers in the functionalist approach to integration33_{. This}

prompted scholars to further promote policy diffusion approaches to the study of regional organizations, namely, within the World Society paradigm.

To explain the surge in numbers of regional organizations and their “otherwise puzzling […] ineffectiveness”, Jupille, Joliff and Wojcik suggest that the recent spread of regional trade agreements [RTA's] can be inscribed into John Meyer's World Society theory [WST]34_{. The ideas of WST that Jupille and colleagues are testing in their work}

30 Ibid., 167–168.

31 Börzel and Risse, “When Europeanisation Meets Diffusion,” 201. 32 Jetschke and Murray, “Diffusing Regional Integration,” 181–184. 33 Jetschke and Lenz, “Does Regionalism Diffuse?,” 631-633.

Master of Arts Thesis Euroculture