Abstract: Proposals for international action on competition policy respond to four problems: increasing transnational anti-competitive activity outside control of any single nation, enforcement conflicts, market access problems, and unnecessary costs of compliance with multiple national regimes. All four are real, but limited, problems, though transnational anti-competitive activity could be very significant in the future. A competition code in the WTO would process competition problems principally as market access problems. The resulting arrangement would address market access problems imperfectly, and the other three problems not at all. International initiatives in this area must facilitate cooperation among competition authorities. The best approach is to pursue a mix of bilateral, OECD, and WTO initiatives which places protection of consumers from anti-competitive activities at the center of international efforts.