Free trade agreements and patterns of risk regulation in the EU and the US: Study

Transatlantic regulatory patterns overall, and in four key sectors: food, automobiles,chemicals, and pharmaceuticals, indicate that EU risk regulation is not always orgenerally more stringent than US regulation. The reality is a complex mix of parity andparticularity. While there is overall EU-US similarity, there is also variation. In some riskmatters, across and within sectors, the European regulation is more stringent, whereasin others it is the US. Even if they are unusual, such transatlantic regulatory differencescan pose barriers to trade. Still regulatory variation can also be the basis for learning toimprove future regulatory design, both by comparing outcomes across regulations indifferent jurisdictions, and by planning adaptive regulation over time. Internationalregulatory cooperation is not limited to adopting the current standard of one side orthe other: it can also involve collaboration to review existing regulations and designnew approaches that improve outcomes for all.