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Case C-194/94 CIA Security v Signalson [1996]


  • Belgium adopted a national law setting out requirements which alarm units must satisfy before being sold
  • This adoption was in breach of EU law, namely directive 83/189/EC, which required such technical laws to be approved by the Commission
  • There was no attempt to obtain approval
  • Alarm systems were sold internationally in compliance with the Belgian law, but in breach of EU law (due to the non-compliance with the directive)


  • Were the sale contracts binding?


  • No


  • Technical directives, such as directive 83/189/EC are required to ensure the free movement of goods
  • They must therefore be interpreted as having horizontal direct effect
  • Individuals can therefore rely on them
  • As the contracts were not valid under (supreme) EU law, they were not enforceable
  • This narrow concept of direct effectiveness has become known as incidental effect
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