The article discusses how comparative advertising is regulated in the United Kingdom and Germany. In the UK, it is mainly self-regulated, while in Germany, it is governed by the S1 UWG law. The Directive 97/55/EC sets out rules for comparative advertising, aiming to ensure it helps consumers make informed choices without misleading them. The implementation of the Directive is crucial for both countries. The researchers suggest that a common approach is needed to move forward in regulating comparative advertising effectively.