The Shifting Roles of the EU, the US and California
Edited by David Vogel and Johan Swinnen
Chapter 9: How to Get Out of the Transatlantic Regulatory Deadlock Over Genetically Modified Organisms?
Alberto Alemanno INTRODUCTION Taking on Robert Kagan’s famous dictum, one may say that the US is from Mars and Europe is from Venus when it comes to the regulation of genetically modified organisms (GMOs), notably genetically modified (GM) food and crops (Kagan, 2003). Although the spread of GM food and crops has been posing common regulatory challenges to the EU and US, they have developed two very different approaches vis-à-vis agricultural technology (Shaffer and Pollack, 2007). While the US boasts a welcoming regulatory framework, the EU has implemented a strict and scientifically demanding regulatory regime based on a pre-market approval system, which is largely inspired by the highly controversial precautionary principle. Moreover, unlike the American regime, the EU regulatory system also provides mandatory rules for the traceability and labelling of GM products. As a result, and as noted in the chapter in this volume by Gal Hochman et al., the US biotech industry is flourishing while its European counterpart is struggling. This outcome cannot entirely be ascribed to these different regulatory approaches, but rather to a multitude of factors related to consumer preferences, cultural configurations and different risk perceptions. Most of the attempts made at explaining the reasons for these distinctive regulatory approaches tend to stress deep cultural (notably, social and philosophical)1 and institutional differences2 existing between the two sides of the Atlantic vis-à-vis new technologies,3 as well as recent changes in the politics of risk regulation in Europe (Lynch and Vogel, 2001). Whatever their causes,...
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