The second-order character of past European elections is a well-established hypothesis with respect to voter turnout and voting behaviour. This paper presents a conceptual framework for testing this hypothesis on the supply side of European elections. It includes three groups of indicators allowing for the comparison of national and European election manifestos to determine the latter's second-order nature: (1) resource allocation, measured by the number of actors involved in manifesto adoption and by the manifestos' length; (2) the manifestos' content, comparing issue congruence and framing; and (3) political competition, measured by the ideological distance between manifestos. Building on this, we analyse the manifestos of all relevant German parties in the 2009 European and national elections using Comparative Manifesto Project data as well as original, self-created data on election manifestos. We find major variations between parties which can neither be explained by government participation nor satisfaction with the European Union.