In the 1990s, Central and East European countries (CEECs) adopted competition laws as part of legal reforms accompanying the transition from a planned to a market economy. For a significant number of these jurisdictions, the transition was influenced by the process of EU rapprochement, concluding in 2004 (the Czech Republic, Estonia, Hungary, Latvia, Lithuania, Poland, Slovakia, and Slovenia), 2007 (Bulgaria and Romania), and 2013 (Croatia) when these countries joined the EU.

The democratic and economic transition of the CEECs involved a substantial import of legal rules from the Western legal tradition, including the prohibition of cartel conduct in the market. Legal borrowings were a vital component of the process of 'transnationalising market values,' and transplanting cartel prohibition implied embracing an economic worldview conflicting with the earlier socialist order. The time is now ripe to examine whether these transplants are effective.

Our national studies on Croatia revealed that, (un)surprisingly, significant obstacles exist to the efficient enforcement of cartel prohibition. These include national cultural features adverse to the development of a competitive system, 'excessive formalism' in judicial interpretation, and an incomplete 'semantic alignment' with EU competition rules (Pecotic Kaufman and Šimic Banovic 2021; Pecotic Kaufman 2022; 2023).

Developing a competition culture in post-socialist jurisdictions is a challenging process. We argue that the value foundations of cartel prohibition cannot be automatically transplanted. It is crucial to determine whether our national findings also apply to the wider region of Central and Eastern Europe. Some recent attempts at comparing selected CEECs in the context of trade associations seem to confirm our suspicion of an existing 'collusion culture' in the region (Pecotic Kaufman and Bernatt 2024).