“…European integration can take place in areas where no direct legislative competence has been attributed to the EU, including areas that may, upon various definitions, be considered core state powers such as ‘coercive, fiscal or administrative’ powers, as per Genschel and Jachtenfuchs (), policy areas of high salience, following Moravcsik (), such as health, education, social security, taxation and law and order, areas that the Treaty itself states are ‘reserved’ or ‘retained’ by the member states (Azoulai, , de Witte, ), that is, where no competence has been conferred on the Union (Article 4(1) TEU), and that the Treaty considers ‘essential State functions’, such as ‘ensuring the territorial integrity of the State, maintaining law and order and safeguarding national security’ (Article 4(2) TEU). Such ‘competence creep’ (Weatherill, ), has been said to take place particularly through (1) the adoption of indirect legislation on legal bases in the Treaty relating to other policy areas; (2) the disapplication of national provisions that the CJEU finds incompatible with EU treaties, such as, notably, in the internal market, (3) the limitation of national regulatory autonomy through obligations under international trade agreements concluded by the EU; (4) the limitation of national regulatory autonomy through EU policy coordination, such as the European Semester; and (5) parallel action on the borders of the EU framework (Garben, ).…”