Case C-184/96 Commission v France (‘Foie Gras’) 
- French law laid out very restrictive requirements which needed to be satisfied before a product could be labelled and marketed as ‘foie gras’ (a French food consisting of duck or goose liver)
- Did these requirements constitute a measure having equivalent effect to a quantitative restriction on trade between Member States (in breach of Art 34 TFEU)?
- Art 34 has no de minimis exception
- Although no other Member States produced foie gras, trade in foie gras would be restricted if non-French producers were to start doing so
- Even though this was only a potential restriction, it still violated art 34
- The Court of Justice found the potential restriction to be ‘non-hypothetical’ in nature, illustrating how broadly the Court will interpret the scope of Art 34