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CHA PTER S EVEN
                                   believed that the process of economic convergence and reliance on
                                   multilateral negotiations to overcome problems of policy, structural,
                                   and behavioral differences work much too slowly. Many reason that
                                   the United States and its more open and competitive economy suffer
                                   from efforts to pursue goals in this fashion. Thus, Americans have
                                   supported a policy of enforced harmonization, and where this tactic
                                   has failed, of protectionism. As has already been mentioned, the most
                                   notable or infamous example of this approach was the prolonged and
                                   acrimonious Structural Impediments Initiative (SII) negotiations be-
                                   tween Japan and the United States. These negotiations, in which the
                                   United States sought to transform important aspects of the Japanese
                                   economy, achieved little and left a bitter residue in Japan.

                                   Mutual Recognition
                                   The most simple approach to the problem of national differences is
                                   mutual recognition. According to this principle, every nation should
                                   accept the legitimacy of the rules by which other nations manage their
                                   economies. For example, a multinational firm establishing a subsid-
                                   iary in another economy should be free to behave as it does in its
                                   own economy. This approach has been adopted by the European
                                   Union. Except in a few basic areas such as health and national stan-
                                   dards, the members of the Union have agreed to permit businesses to
                                   operate throughout Western Europe in accordance with the laws and
                                   regulations of their home country. Thus, the subsidiary of a German
                                   corporation doing business in France would be governed principally
                                   by German law; nevertheless, more and more business regulations are
                                   being formulated in Brussels.
                                     The fundamental question, of course, is whether or not the princi-
                                   ple of mutual recognition is applicable to other parts of the world.
                                   The principle is particularly well suited to Western Europe for a num-
                                   ber of reasons. Continental Europe inherited the Roman and Napole-
                                   onic legal and administrative traditions, and, as Peter Katzenstein has
                                   pointed out, the nations of continental Europe share a concept of the
                                   limited state; that is, the state is regarded as an impartial and indepen-
                                   dent entity separate from society but responsible for creating a favor-
                                   able and impartial environment for private business. Economic and
                                   cultural differences among the European nations are minor when
                                   compared to those in any other regions of the globe. Also, during the
                                   postwar era the processes of deregulation, privatization, and liberal-
                                   ization have reduced the role of the state in the economy and harmo-
                                   nized to a considerable degree the economic structures and business
                                   practices across the Continent. Both the historic traditions and other
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