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How does the European Commission make its own policies? Research on EU policy-making has generated many indirect, informed answers to this question. However, a focus upon the Commission’s internal practices remains under-theorized and under-specified. Drawing upon constructivist, institutionalist and sociological policy analysis, this article instead mobilizes a generic approach to policy-making as ‘political work’ entailing three overlapping processes: problematization, instrumentation and legitimation. This conceptual framework is then applied to a comparison of Commission policy-making as regards the wine and pharmaceuticals industries. The principal finding is that there are three scope conditions for Commission policy-making which seeks deep institutional change: problematization must be precise rather than vague; instrumentation needs to be programmatic rather than dispersed; and commissioners and senior Commission officials must commit to sustained strategies of legitimation. Overall, this theory-driven approach to policy-making provides a means of shedding new light upon both the Commission and its role within European integration.
