Inside US Trade spells out the different approaches by the EU and U.S. to dealing with regulatory trade barriers in the T-TIP. The EU:
The emphasis of the European Commission is on an approach that would entail mutual recognition and other commitments on existing regulations affecting specific industry sectors like automobiles and chemicals, in addition to horizontal obligations for regulators to discuss future rules, according to an EU official.
Separately, a private-sector source said the U.S. is clearly placing more emphasis on negotiating rules that would be horizontal, and specifically is interested in improving the transparency of the EU rule-making procedure. Sealing a deal on transparency would be considerably easier politically than committing independent U.S. regulators to increased international cooperation, this source noted, although he argued that these approaches are complementary.
U.S. officials have complained that the European Commission does not follow the same procedures as the U.S. in developing new regulations -- such as issuing proposed rules for public comment -- and that the process overall is less transparent. The commission seeks public input before it begins working on a regulation by issuing concept papers, but does not offer further opportunity for comment once it has drafted a regulation, the private-sector source said.
These are very different visions. If I'm reading this correctly, the EU is more interested in outcomes, in the sense of aligning regulations across the U.S. and EU; whereas the U.S. is more interested in making changes to the EU regulatory system. Can these differences in approach be reconciled?