ADVERTISING LAW IN THE UNITED-STATES AND EUROPEAN-UNION

Nearly 40% of the more than $270 billion spent on advertising througho ut the world occurs in the United States and more than 25% more is spe nt in Europe (Adler 1996). Both the United States and European Union ( EU) have a central government that is the source of marketwide law, as well as numerous states, each with its own individual laws. Although the EU drew on U.S. law when drafting its 1984 Directive on Misleading Advertising, many of its member states have legal traditions predatin g those of the United States, and they are reluctant to change. The au thor examines advertising law in both the United States and EU, specif ically exploring the law of misleading, comparison, and unfair adverti sing. Differences between states in each market, the states and centra l government, and the United States and EU are analyzed to develop imp lications for both marketers and policy makers.