... concerning the discrimination of goods, as well as distinctly and indistinctly applicable measures. This essay will outline the development of Article 28, and examine the acceptance of the ECJ's decisions by Member States in order to achieve an integrated Community. It will then go on to examine the courts approach to Article 30 in order to achieve harmonization and examine the relationship between positive and negative harmonization and the principle of mutual recognition, as well as the response to these measures. The Geddo case5 first defined a quantitative restriction broadly as a 'measure, which amounted to a total or partial restraint of according to the circumstances, imports, exports or goods in transit', which is part of Article 286. However the ECJ found more difficulty defining all measures having equivalent effect (MEQR), which was attempted in the case of Dassonville7, where it said ' all trading rules enacted by Member States ...

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