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Comparative Policy Process-Final Essay
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POLICY TOWARDS GENETICALLY MODIFIED FOOD: THE EU VS. THE U.S
INTRODUCTION
Similar Trade Positions and Demands
The two major western economies, the EU and the U.S are similar in their key positions
in international market. According to WTO trade database, the EU’s trade in merchandises and
services ranked at the second and the first place in the world trade respectively in 2015.1 The
database also shows that the U.S ranked the first and the second place for world trade in
merchandise and services in the same year. One of the most defining feature of current global
economy is the intensive trade between the EU and the U.S which account for 30% of worldwide
transactions in goods and 40% in services (Delegation of the EU to the U.S). According to
Eurostat, these two economies together form the largest bilateral trade relationship in the world.2
Nonetheless, the similarities don’t imply a tension-free EU-US trade relation. One of the
most long-lasting debate is about their divergent stances and policies towards trading genetically
modified organisms (GMOs). This paper will add on previous research papers to explore the
reasons why these two economies differ in trade policies on GMOs given their similarities in
demand for trade and global economic power through a policy process making lens.
Understanding why EU and U.S have such a different level of tolerance of GMOs from policy
making perspective would help trade policy makers to better identify what factors would drive or
block trades between two similar entities.
Different Approaches to GMOs
The top layer of differences in GMOs treatments is that the EU employs a precautionary
principle while the U.S utilizes a substantial equivalence rule over GMOs. For example, unlike
the U.S, the EU focuses on the process of GMO production instead of the final GM goods.
Therefore, in the EU, all GM products are regulated and required to be labelled (Lau, 2015).
Under this umbrella regulatory difference comes a divisive view in how to incorporate GMOs in
their trade partnership: U.S urgently wants to export GMOs to EU but EU did not approve their
entry until recently, and with stringent requirements and a shift in power to individual states to
ban the entry. This confrontation reached to a multilateral level in September 2003 when the U.S,
Canada and Argentine established a WTO dispute panel to test the legitimacy of the EU’s bans
on GMO imports (Anderson and Jackson, 2003). In fact, the difference in treatment of GMOs
overwrites the similarities in trade volume and global power, and it is rooted in multiple factors
including policy making inertia, political institutions, public opinion and interest groups.
These four factors also intertwine with each other and further contribute to the differences in
trade policy on GMOs.
DIFFERENT CONTEXTS
EU Perspectives
Policy Making Inertia. The EU countries have no previous experiences with neither
cultivating nor circulating GMOs, so the GMO regulation was framed as an environmental
concern at first (Watjen, 2015; Weimer, 2014). However, after the general director of the EU
Environment Department began co-chairing the Biotechnology Regulation Interservice
1 http://stat.wto.org/CountryProfile/WSDBCountryPFView.aspx?Language=E&Country=E28
2 http://ec.europa.eu/eurostat/statistics-explained/index.php/USA-EU_international_trade_and_investment_statistics

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Comparative Policy Process-Final Essay
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Committee, control over GMOs shifted to technical considerations (Anderson & Jackson, 2003).
Howlett and Laycock confirm that EU has a history of strictly averting potentially serious harm
under scientific uncertainty, especially on biotechnical issues (2012). They also point out that
this precautionary principle was reinforced during the mid- 1980s when the EU broke from the
U.S in terms of outlook on biotechnologies. The persistence of such defensive rule reflects
general European skepticism regarding the manipulation of living organisms.
Political Institution. The EU exercises a centralized regulation over trading goods but
allows individual member states to deny GMO imports. More specifically, the EU holds an
exclusive power over trade policies but the Council of Ministers serve as the gate keepers by
reviewing decisions drafted by the European Commission based on the European Food Safety
Authority’s evaluations (See Appendix figure 1). If a product is not considered “safe” by most
ministers – which is the case in the EU- it can be neither produced in nor imported to the EU.
This has made the GMOs structurally harder to circulate in the EU market.
Public Opinion. Now that the EU has given each member state greater power in banning
GMOs even when the EU permits GMOs entry, public opinion matters in policy making process.
Most citizens of EU member states, except France, doubt the benefits of GMOs and largely
refuse the cultivation and trade. A Eurobarometer opinion poll (2010) found that 59% of
Europeans believe that GM food is not safe from health perspective. 70% insist that GM foods
“fundamentally unnatural”, and 61% “feel uneasy” about GMOs (See Appendix figure 3). Thus,
even though the EU or individual states approve GMO imports, GMOs would hardly gain
popularity or profits from the consumer side in the EU areas. The EU’s regulatory framework for
GMOs is thus an attempt to respond to consumer resistance (Vellata, 2010).
Interest Groups. The lack of interest group leaders supporting GMOs echoes public
opinion favoring non-GM goods. For the EU farmers, tough labeling laws and low unintentional
GM tolerance levels require them to put an expensive segregation and identity preservation
system in place if and when GM varieties are approved (Executive Order, 2010). Therefore, the
potential productivity gains would be more than offset by the management costs of buffer zones.
Hence, Ceteris paribus, one would expect a greater proportion of farmers from the EU than the
US farmers preferring produce non-GM crops.
US Perspectives
Policy Making Inertia. The U.S approved GMOs in 1994 and it is the world’s largest
producer of GMOs. According to Foster, Berry and Hogan, GM feedgrains and oilseeds account
for 18% of the gross value of the agricultural outputs in the U.S (2003). It thus has experiences in
dealing with this biotechnological product. In addition, a substantial equivalence principle was
adopted by the George Bush Sr. Administration during his deregulation years in order to keep the
U.S at the forefront of the biotech industry (Meenus, 2015). This has provided a political
institution framework for GMOs regulation.
Political Institutions. The regulatory process for GMOs in the U.S is more straight
forward: the degree of regulation depends on scientific evidence about product composition and
health risks. The main regulatory bodies in the U.S are the Food and Drug Administration (FDA),
the Environmental Protection Agency, and the US Department of Agriculture. FDA regulation,
particularly, substitutes for equivalent labelling procedures in the EU, by reviewing information
and analysis submitted by a company to make a judgment concerning whether the GM food is as
safe as its non-GM counterpart (See Appendix figure 1).3
3 http://www.globalization101.org/the-us-and-eu-different-approaches/

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Public Opinion. Although U.S citizens also feel skeptic about GMOs, they have trust in
food safety authorities and access to information about GM food (IFIC, 2001). According to Pew
Research Center, in 2015, 57% of the general public say that GM foods are generally unsafe to
eat, while 37% say such foods are safe; however, 88% of AAAS scientists say GM foods are
generally safe (See Appendix figure 3). Scientists’ opinion allows GMOs to exist in the U.S
market with limited regulation because of the U.S substantial equivalence principle: unless there
is scientific evidence pointing out harms and risks of GMOs, it is okay to produce and sell
GMOs.
Interest Groups. Unlike the EU, the anti-GMO-labelling interest groups are distinct.
Companies like Coca-Cola, PepsiCo, Kellogg’s, Kraft Heinz Co., Land O’Lakes and General
Mills reported $20.6 million in expenditures on lobbying to fight GMO labeling. Monsanto, one
of the four giant biotechnical agricultural companies, spent 5.1 million in lobbying in averting
GMO labelling in 2015 (See Apendix figure 4). Although interest groups from consumer side
including environmental activists exist, they do not have much power influencing policy making.
This is because the U.S politicians favor resourceful supply side interest groups such as
agribusiness associoation and farmers unions for electoral benefits. A recent outcome of interest
group pressure is the U.S House passing voluntary labelling bill which would prevent states and
localities from passing their own mandatory GMO labeling laws (Brodey, 2015).
DISCUSSION AND CONCLUSION
The EU and the U.S differ in policy on GMO trade for multiple reasons and they relate to
one another. Along with differences in regulatory procedures and institutions, the EU and the
U.S have divergent historical experiences in dealing with GMOs, which differentiate their GMO
policies. Economically speaking, lobbying capacity and cunning vary from interest group to
interest group. In the U.S, the biotech companies have more says in promoting the production of
GMOs and thus they get more of a hearing from the government and policy makers. In contrast,
European farmers and labor are involved in anti-GMOs movements and campaigns more
frequently and have larger impacts in the EU. The lack of leaders from interest groups supporting
GMOs in the EU further restrains GMOs entry from being approved. Another discrepancy lies in
public opinion: citizens in the EU member states are reluctant to accept GMOs without strict
labelling, while the U.S public, especially scientists, generally hold a positive view towards GM
goods.
Given current trend in international trade, the EU and the U.S may still remain in
divergence in terms of trade policy on GMOs, even though there is increasing pressure from
North American business groups through WTO dispute panels. These partners urge the EU and
individual EU states to open their borders to GMO imports as part of the proposed Transatlantic
Trade and Investment Partnership (TTIP). The EU adopted a new legislation in 2015 to allow
individual countries greater freedom in approving GM foods in response to the pressure.
Specifically, the countries’ approval decisions can be based on factors beyond health risks such
as socioeconomic considerations and land use customs (European Commission, 2015).
Nonetheless, EU-US trade in GMOs is likely to remain difficult. More in-depth studies on other
factors, such as external forces and individual policy entrepreneurs, are called for to develop a
more exhaustive approach to better facilitate the bilateral trade relation in the future.