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In the Meca Medina and Piau cases, the European Court of First Instance had to deal for the first time with the application of EC Treaty provisions to sports bodies’ rules. The first of these two cases concerned anti-doping rules adopted by the IOC and the second one concerned FIFA regulations on players’ agents. According to case-law of the European Court of Justice, rules ‘of purely sporting interest’ do not fall within the scope of the EC Treaty. However, an overview of the relevant judgments shows that the test adopted since Walrave to assess the ‘purely sporting’ nature of such rules is not fully clear and has not always been applied in a consistent way, in particular after Bosman. The Meca Medina case, in which the European Court of First Instance has applied the test in a slightly different manner, opens the door to substantial simplification of future case-law. On the other hand, the European Court of First Instance has also taken the view that the test, which had only been applied up to now by the European Court of Justice to EC Treaty rules on free movement of workers and free provision of services, extends also to the rules on competition. Piau, delivered by the European Court of First Instance some months later, has confirmed the confusion that may derive from traditional case-law and has shown the risks that may derive from the adoption of divergent decisions within the European judicial system.

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The Application of EC Treaty Rules to Sport: the Approach of the European Court of First Instance in the &lt;i&gt;Meca Medina&lt;/i&gt; and &lt;i&gt;Piau&lt;/i&gt; cases