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Ships passing in the night: GMOs and the politics of risk regulation in Europe and the United States

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This paper seeks to place the divergent approaches of the European Union and United States toward the introduction and marketing of genetically modified foods and seeds in a broader context. It argues that an important key to understanding why Europe and the US have chosen to regulate identical technologies in such a dissimilar fashion has to do with recent changes in politics of risk regulation in Europe. From the 1960s through the mid 1980s, the regulation of health, safety and environmental risks was generally stricter in the US than in Europe. Since the mid 1980s, the observe has often been the case: a wide array of European consumer and environmental regulations, including those governing GMOs, are now more restrictive than in the US. In a number of important respects, European regulatory politics and policies aver the last 15 years resemble those of the United States between the late 1960s and the mid 1980s. They are often politicized, highly contentious and characterized by a suspicion of science and a mistrust of both government and industry. By contrast, the US rregulation of GMOs resembles the European regulatory style of the 1970s: regulators have worked cooperatively with industry and been supportive of technological innovation, while non-governmental organizations (NGOs) have enjoyed little access to the policy process. This paper begins by reviewing comparative studies of health, safety and environmental regulation in Europe and the US in order to place contemporary cross-atlantic regulatory differences in an historical context. It then summarizes the evolution of American and European policies governing GMOs. The third section of the paper reviews a number of explanations for hte differences in European and American regulatory policies toward this new agricultural technology, and the final section advances an explanation rooted in the emergence of a new European approach toward risk regulation in general, and food safety in particular.

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