THE rapid commercialization of European television - combined with its heady expectations for 1992, when continental trade barriers are expected to start coming down - is bringing with it the prospect of a head-on collision between European and American interests. The Europeans, charging United States television with dominating Europe while closing its doors to European programs, are talking about quotas against the US. And they are looking at the potential advantage of a unified market which, including the Soviets, could embrace as many as 700 million viewers.
There is a great deal of serious talk, particularly on the part of the French, about ``preserving national culture'' in the face of a flood of American programs, an argument which US TV executives call invalid.
During the past year, American TV has reaped huge profits from sales to the new European network, cable, and satellite services. But the US exhibits an almost obsessive fear about any European move, regardless how limited, to restrict the number of American programs on stations on the continent. In this they are vocally supported by Europe's new commercial TV entrepreneurs, who share American broadcasting's reliance on ratings and want to show any program that compels audiences to tune in.
This clash of views, often voiced with much bitterness on either side, became very evident here during two recent events - FIPA, the international television festival whose president is Michel Mitrani, the French director, and MIPCOM, Europe's most prominent television market.
MIPCOM, which concluded in mid-October, attracted 28.6 percent more sellers and buyers than last year, a total of 1,580 companies, the majority from France, the United Kingdom, and the United States.
There were 1,046 program-buying executives in attendance, which accurately reflects the ascendancy of the new commercial stations in Spain, Greece, France, Holland, and other countries and their bottomless appetite for attractive programming.
Xavier Roy, the chief executive of the Midem Organization, which stages MIPCOM, credits it all to the ``internationalization '' of the business.
While discussions of quality dominated FIPA, which is a competitive TV Festival and sales talks pervaded MIPCOM, the hottest topic among the executives was the European TV relationship with the US, and the potential of coproduction among the various European countries, often with the Americans involved.
In fact, coproduction is on everyone's lips. The Europeans seek it because it eases their financial burdens. The Americans go for it because it can be a good investment and, equally important, because it would allow them to get around potential quotas.
Just before FIPA and MIPCOM, the 12 Common Market members adopted a significant directive, designed to delineate their ``Television Without Frontiers'' concept. Instead of voting for French-proposed 50 percent quotas, which would have fed the flames of American resentment and were opposed by a number of key European countries, they reached a compromise.
The EEC members are advised to devote a majority of their programs to shows originating in the Common Market countries. However, none of this is legally binding on the EEC members, which cuts two ways: Countries that don't want quotes don't have to have them. Those that do want them, or already have them, can restrict their networks accordingly.
In addition, the directive proposes the raising of funds to help stimulate European production, a move designed to pacify those Europeans, like Michel Mitrani, who argue that the flood of American programs available at much lower prices than European-made shows has ruined European TV production.
The US House of Representatives has already denounced the directive, calling it ``trade restrictive'' and voting 342 to 0 to urge the President to take steps to maintain US access to the EEC broadcast market.
Meanwhile Americans, individually and through Jack Valenti, president of the Motion Picture Association of America, vocally opposed any European move that even smacks of quotas.
Carla Hills, the US Trade Representative, has threatened American retaliation, saying the European move to restrict American TV imports violates the GATT agreement.
Jack Lang, the French culture minister, visiting MIPCOM, argued that the shoe should be on the other foot. ``It is we who should complain to GATT,'' he told the assembled press. ``The Americans don't have a 70 percent quota, or an 80 percent quota. They have a 100 percent quota against us.''
European proponents of some sort of restrictions on US TV shows maintain that such moves would not hurt the United States at all, since hardly any network programs more than 42 percent American shows.
But European bitterness really explodes when it comes to the reluctance of American stations to program European material. ``It's an outrage,'' says Albert Barilly, the president of Procidis, a French production company.
The Americans reply that US audiences simply don't accept programs dubbed into English, which is the only realistic way European shows can make the transfer to American TV.
Catherine Tasca, the French minister in direct charge of films and television, charges ill will on the part of the Americans. ``It's not a question of can't,'' she maintains. ``It is a question of won't. It's just not good enough.''
When Mr. Lang toured MIPCOM, he had a number of exchanges with American TV executives over the perceived US barriers against European programs, though it is acknowledged that the expansion of cable networks in the US has brought about an improvement, since cable sometimes buys European shows.
This fact flies in the face of the American network argument that if only the Europeans would produce programs to American tastes their entry in the US market would be assured.
Lang, visiting the booth of Viacom, a major American syndicator, complained that the American market was closed to French programs. ``Our dubbing now has reached a high state of perfection,'' he told Raoul Lefcovich, the top Viacom executive.
Mr. Lefcovich smiled and shook his head. ``You are missing the point, Mr. Lang,'' he replied. ``The quality of dubbing has nothing to do with it. Our audiences simply won't accept a dubbed program, regardless of how well it is done.''
Lang and his entourage did not seem convinced. In fact, the barrier between Europeans advocating some restrictions and the Americans battling for free access to the Common Market seems higher than ever, perhaps precisely because the importance of American programs, both as entertainment and as cultural communication, is fully appreciated.
The American TV industry, aware of European divisions over the issue, nevertheless has nightmares about being kept out of ``Fortress Europe.''
The Europeans, though protesting that they do not wish to restrict American access to their TV screens, nevertheless appear to be hoping that the envisioned larger European market can and will stimulate greater native TV production, though few question the difficulties of getting the various nations to work together.