Pubblico Ministero v Ratti

Mr Tullio Ratti claimed that he should not have to comply with a stricter Italian law that required him to label his solvents, on the ground that it conflicted with two Directives.

Mr Ratti sold solvents and varnishes, some of which were imported from Germany that complied with two Directives.

Mr Ratti complied with the Directives, but an Italian law of 1963 was stricter in some respects.

Advocate General Reischl gave an opinion, speaking against the possibility of horizontal direct effect.

[1] The ECJ held that Mr Ratti was not bound by Italian law that was meant to be changed by Directive 73/173, but he was still bound by Italian law, which would later have to be changed under Directive 77/728 because its deadline for being implemented had not yet passed.