Environmental Engineering Reference
In-Depth Information
erences in interests and poli-
cies of individual EU countries and US states, and their implications for variation of poli-
cies at the EU and US level. Hence the second perspective views EU and US GMO
policies as outcomes of interactions between political sub-units (member states in the EU,
states in the USA) within a larger (federal) political system where these sub-units can to
varying degrees act autonomously. It concentrates on whether political sub-units within
the larger political system can, by unilaterally installing stricter or laxer regulation of
GMOs, push the stringency of system-wide regulations up or down. The analysis of
GMO policy-making in the EU and the USA shows that in the EU we observe a sub-
stantial 'ratcheting-up' e
The interest group explanation does not account for di
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ect, whereas 'centralized laxity' has prevailed in the USA. EU
countries are bound by supranational rules that guarantee the free
ff
ow of agricultural
goods within the EU's internal market. But they maintain considerable national
autonomy in closely related policy areas, such as environment, health and safety regula-
tion. For example, in many areas they have safeguarded the right to establish regula-
tion that is stricter than minimum standards set by the EU or that deviates from the
principle of mutual recognition. These conditions apply to agri-biotechnology as well.
When the forces described and explained by the interest group perspective began to
drive up the stringency of regulation in more GMO-adverse EU countries, the more
GMO-friendly nations as well as the EU Commission faced a dilemma: how to satisfy
demands, in some countries, for stricter GMO regulation and, at the same time, safe-
guard the EU's internal market for agricultural products. Variation across countries in
approval and labeling standards for GM products threatened to disrupt agricultural
trade in the EU. In view of strong public support for strict GMO regulation in around
half of the EU's member countries, downward harmonization to levels acceptable to pro-
GMO countries was impossible. Pro-GMO countries in the EU have thus regularly caved
in to the demands of GMO-adverse countries. They have done so because, in their view,
the costs of market disruptions are higher than the costs of restrictive GMO regulation.
In this 'ratcheting-up' process GMO-adverse countries have, step by step, moved toward
more stringent regulations and have dragged EU-wide regulations upward in this
process.
GMO policy is more centralized in the USA than in the EU, in terms of both political
levels and institutions involved. It is largely in the hands of two independent federal agen-
cies and one federal ministry (FDA, EPA, USDA). What might appear like a paradox in
the EU case - that fragmentation of decision-making authority produces upward har-
monization and not simply paralysis - does not come into play in the USA to the extent
that it does in the EU. Bottom-up pressure for stricter regulation has in some cases led to
diverging policy preferences among US states. But due to institutional and legal con-
straints, US states' options for stricter unilateral regulation of GMOs are much more
limited than the options of individual EU countries. Even if public pressure for stricter
GMO regulation grew in some US states, and if these states imposed some restrictions
that were upheld by the courts, a 'ratcheting-up' trend would emerge much more slowly
in the USA than in the EU. In other words, relatively positive public attitudes toward
GMOs and weak NGO campaigns are primarily responsible for lax GMO regulation in
the USA; and federal processes in the USA constitute an additional barrier to stricter reg-
ulation should bottom-up pressure increase in future.
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