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06/12/2016

US and EU standards broadly similar, new research claims

Science & Policymaking

US and EU standards broadly similar, new research claims

TTIP protesters in Berlin. [Stop TTIP/Flickr]

European opponents of TTIP fear reduced social, health and environmental standards. But new research claims that levels of protection in various domains are broadly similar on both sides of the Atlantic. EurActiv France reports.

Resistance to the Transatlantic Trade and Investment Partnership (TTIP) has largely centred on chlorine-washed chicken, hormone-enhanced beef and GMOs.

More broadly, opponents contend the treaty poses a wider threat to European standards.

>> Read: Nothing wrong with chlorine-washed chicken, say German backers of TTIP

This view is picked apart by several economists in a book entitled The Reality of Precaution: Comparing Risk Regulation in the United States and Europe.

The book’s authors – two Americans and two Europeans – argue that the level of protection offered by European legislation is not necessarily any higher than in the United States. The essence of this argument appears in a synthesis published by the think tank Notre Europe.

“There is a general perception in public opinions that Europe is more precautionary, more regulatory, more environmentalist and more risk adverse than the United States,” the authors write.

Europeans consider Americans to be “individualistic, risk-taking and confident that technology and the power of the market will solve every problem,” they continue.

However, neither side can claim to enforce stricter precautions against health and environmental risks than the other, the authors write. Regulations are different on both sides of the Atlantic, but not necessarily stricter overall in the Old World.

Protection on different levels

In fact, the application of the precautionary principle is selective and subject to variations on both sides of the Atlantic, the study found.

Since the 1990s, Europe has adopted strict protection rules in certain areas like GMOs, hormones in beef, toxic chemicals and climate change. European opposition to TTIP has crystallised around these points.

For their part, the US has concentrated its prevention efforts in the domains of fine particle air pollution, mad cow disease, tobacco, information systems, embryonic stem-cell research, youth violence, and terrorism.

However, the United States often takes a preventive approach without formally endorsing it as a precautionary measure, while Europeans formally approve the precautionary principle without applying it consistently across all risk factors. In the end, the authors observed little difference between the two.

Notable transatlantic divergences include measures adopted to combat climate change and the disappearance of the ozone layer.

The US cted earlier and more aggressively to halt the retreat of the ozone layer, while Europe has taken a stronger stance on climate change. Similarly, the US has introduced stronger measures against pollutants like lead, fine particles and nitrogen oxide, while Europe is stricter on regulating greenhouse gas emissions.

“Hybridisation” of regulatory systems

In the context of globalisation, the authors of the study believe TTIP should not be seen as “a dividing line for transatlantic discord” but rather as an aid to the interconnectivity and growth of international networks.

We are playing witness to an “exchange of ideas, regulatory collaboration and borrowing of regulatory solutions to specific risks,” which the authors call the “hybridisation” of regulatory systems.

With TTIP negotiations still ongoing, the study’s authors see an opportunity to reinforce regulatory collaboration and improve the transparency of precautionary legislation.

>> Read: De Gucht rejects claims Commission misrepresented benefits of TTIP

Background

Negotiations between the US and the EU on the Transatlantic Trade and Investment Partnership (TTIP) began in July 2013.

Opposition to the free-trade agreement has intensified since the formation of the new, more eurosceptic European Parliament.

If the agreement is ratified, it will bear upon almost 40% of global GDP. The Transatlantic market is the most important in the world in terms of goods and services.

Economists have tried to determine which of the two continents has the strictest regulations.

Out 100 risks factors (food security, air pollution, climate change, nuclear power, tobacco...), selected from 2878 identified over 34 years, they have been able to show that the level of precautions taken against risks is similar in Europe and the USA: the United States took greater precautions on 36 risks, the EU on 31.

Further Reading