Whether the European Union has the legal power to create a European civil code has also been an issue. Article 95 of the EC Treaty is considered the means through which a code would be created. However, many people believe that the EU lacks the constitutional competence to enact a comprehensive code. Others argue that this does not defeat the idea of a European civil code and is merely a political issue. If a general consensus were to be reached in favour of a European civil code, it might be politically possible to expand the constitutional competence of the European Union or create an international treaty giving effect to the code. According to professor Christian von Bar "it fully depends on a political decision of the European Commission, the Council and the European Parliament if in the end, the "Common Frame of Reference" will be adopted as an EU instrument."