The United States has proposed a peer review mechanism for competition policies in various countries, even as the European Union is pushing for a multilateral agreement on competition.

The US has said a multilateral framework is "neither feasible nor desirable".

"It will result in convergence towards recognised principles of sound competition policy, which will be beneficial both for agencies and for the conduct of cross-border business," the US proposal circulated at a meeting of the World Trade Organisation's working group on interaction between trade and competition policy last week said.

The divergence of views between the two largest trading blocks can help countries like India, who are opposed to the inclusion of competition policy under WTO's negotiating mandate. India, however, does not subscribe totally to the US point of view.

The US has argued that though around 100 countries with competition laws have tailored their rules according to their needs, there are common principles which have resulted in a high degree of commonality in provisions.

The US has suggested a choice between a self-assessment mechanism by countries and a setup similar to the trade policy review undertaken by the WTO.

It has proposed that some countries be reviewed more often than others.

"The review can be limited to specific issues, or can extend to all aspects of a competition regime. It can consider how a competition agency handled particular matters, or be limited to policy and institutional issues," the proposal said.

The US has also proposed that the fifth ministerial meeting scheduled to be held in Cancun in September this year can establish the mechanism for the peer review process.

The EU has recommended that the agreement on competition provides the basic principles and provisions to help WTO members in preparing the basic design of their competition regime.

The EU has also cautioned against harmonising competition laws.

The proposal does not call for a complete multilateral definition of the substantive scope of a domestic competition regime.

"The only substantive provision that we envisage will be an obligation for WTO members to enact in their domestic competition law a ban on hardcore cartels," the EU said.

It has proposed a minimum set of multilateral provisions to influence and guide WTO members in setting up a domestic competition regime, including mechanisms that will make it "self-correcting" through obligatory measures like judicial review.

The proposal calls for transparency, non-discrimination and procedural fairness in dealing with competition matters.