THE preparations for a truly European common market are creating a pile of problems over how Europe's governments should help their exporters. ``The philosophy is that exporters should enjoy the same possibilities in all member countries,'' said a European Community official in Brussels.
But the EC governments are showing little enthusiasm for reaching a common policy on export credits and guarantees, especially as West European companies seem to be speeding up the formation of joint ventures with Soviet enterprises. Right now, the easiest and cheapest way for a company to finance its export deals is to apply for a credit insurance policy from a state agency set up for this reason.
Out of concern that the agencies may be outbidding each other to do business with the Soviets, Jacques Delors, the EC president, suggested last November that member governments rationalize their policies. This in turn sprouted suggestions to establish a pan-European superagency, sparking howls about threatened sovereignty.
``There'll be no superagency - none of us get on well enough for that to be an option,'' says Derek Smith of London-based Jardine Credit Insurance Ltd. ``A French company will always want to do business with a French agency, a German one with a German agency, and the complications of English law will not go out of the window tomorrow.''
And that's the rub. Any attempt to harmonize government export supports conflicts head-on with differing legal systems.
``You need to have the same insurance laws. It is actually much easier for France and Germany to harmonize than either country with the United Kingdom, because the basis of legal systems is in written Roman law, while the British system is based on case law,'' says Jan Rapacki of Coface, the French state export credit agency.
The agencies differ among themselves as well. Britain's Export Credits Guarantee Department (ECGD) is really a government department, part of the Department of Trade and Industry. France's Coface is an autonomous state-owned company, while Spain's Cespe is part state, part private owned, but headed by an official from the Ministry of Economy and Finance. German export credit policy is run from a department of Hermes, a private sector insurer which receives a management fee for its trouble.
Furthermore, these agencies compete against rather than cooperate with the private market. And while the private market rarely covers exports deals for longer than one year, state agencies are the ones that provide guarantees for things like 10- to 15-year construction projects. As a result, they have been hit badly by third-world debt reschedulings.
Lately, all of them have been undergoing some sort of internal review of operations, coinciding with the fierce debate over their future after 1992.
Meanwhile, the agencies have been gearing up to compete further with the private market, which itself has been expanding as big-name insurance companies such as Sun Alliance move into the export credit business.
``There is a lot more competition now than three or four years ago. This is good news for exporters,'' says Mr. Smith of Jardine.
In Britain, there is speculation that a part of ECGD's operation, that covering short-term (up to one year) business, which has been completely revamped and is now profitable, will be privatized.
A report on the future of ECGD is expected to be completed this month, but already the agency is looking to find new business. ``We are trying to win business with US multinationals if they have UK subsidiaries,'' the ECGD spokesman said.
While the contest heats up in the marketplace, Brussels is eager not to be seen to wield a big stick.
``We will need a practical harmonization but not a global system where premiums are equal,'' the EC official says.
The EC expects to produce a first draft of proposals soon which will be discussed by ministers toward the end of the year.