A brief historical premise and contextualisation of the class actions origins and development in the US and common law world is pivotal in order to understand the rationale of such a peculiar enforcement model, and how it was crafted as a ‘vehicle of mobilizing capability’ for civil rights groups (especially in the desegregation context post Brown v. Board of Education and especially via the injunctive tool). Then, a critical description of the European regulatory framework is given, discussing the radical shift of attitude, from the infamous ‘toxic cocktail’ description of the model in question until Directive (EU) 2020/1828 (‘RAD’) on consumer representative actions. The most challenging provisions of the latter are herein addressed under a constitutional perspective, in particular the fact that it is a Directive and its mere focus is on consumer issues. Finally, the two continental approaches are bridged, highlighting the main lessons EU actors should learn from the previous common law experience with such a model.