Registrieren

Iceland has implemented Protocol 35 EEA in substance. The decisive question is not whether Article 3 of the Icelandic EEA Act reproduces an abstract primacy clause, but whether the domestic system gives implemented EEA rights foreseeable and judicial effect. Protocol 35 requires homogeneity through national procedures and a statutory rule of primacy only “if necessary”. The standard is therefore functional success, not the adoption of EU-law primacy or the Norwegian legislative model (Protocol 35, preamble and sole article).