A report, authored by the Swedish National Board of Trade, analyzes the differences in regulations and regulatory processes between different sectors between the European Union and the United States, and argues that these regulations should be converged where possible and made more coherent generally on a sectoral basis.
Preface of the report
A central question in the current trade negotiations between the U.S. and the EU is that of the regulations and requirements that exist for various products to ensure that they will be safe to use or to protect the environment or human health. The U.S. and the EU have about the same levels of protection, but their regulatory systems have been designed in completely different ways which result in that some regulations create unnecessary barriers to trade between the U.S and the EU. Since both regulatory systems have developed over a long period and are well established, regulatory coherence aspects related to legitimate obejctives, such as health and safety, will become one of the more difficult issues to agree on.
At the same time, TTIP offers a special opportunity to reduce the differences in regulations that form a disruptive barrier to world trade. The size and influence of the U.S and the EU mean that reached agreements can influence the regulations of other countries, and thereby reducing the negative effect that differences in regulatory frameworks have on international trade.
In the present report, we analyse the differences in regulations for a number of sectors in more detail. We may conclude that the differences are quite varied in nature and should therefore be tackled in multiple ways. We also see that differences in society’s horizontal regulations affect various sectors in different ways.
The work was led by Heidi Lund, who prepared the report together with Emanuel Badehi Kullander, Anna Folkesson, Cedric Housset, Åsa Pleiner and Beatrice Tander Gellerbrant. We are grateful for the assistance received from a number of Swedish stakeholders. It is our hope that the analysis will be of use in the negotiations. We also hope that our work may contribute to greater insight about the significance of regulatory issues in a modern economy, where production is divided in supply chains, where parts of the production are taking place at different locations, often in different countries. Production is thus becoming more and more dependent on trade functioning smoothly.
Last, but not least, we hope that our work might increase understanding of what the differences between the EU and the U.S. mean in practice. As mentioned above, the requirement levels are similar. The differences lie in the method of regulation.
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