Case C-456/98 Centrosteel v. Adipol [2000] ECR I-6007

Key point

  • Indirect effect applies to the case law of member states


  • Centrosteel acted as agent for Adipol and sought to recover unpaid commission from Adipol
  • Adipol argued that the contract was void because of Centrosteel had not been entered onto the register of commercial agents as required under Italian law
  • In Bellone v Yokohama, the ECJ held that a national rule which makes validity of an agency contract conditional upon registration of the agent is contrary to the Self Employed Agents Directive
  • The Italian court thought that the Bellone case and Directive should not apply to this case since directives do not have horizontal direct effect


  • Result in favour of Centrosteel


  • National courts must not only interpret national legislation in conformity with a directive but also change its established case law if necessary
  • To that effect the Italian Supreme Court of Cassation already held that under national law unregistered agency contract is not void