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Beyond National Styles of Regulation - Genetically Modified Food in Germany and in the United States

Astrid Epp
Bielefeld University
Email: epp@iwt.uni-bielefeld.de|

Date: 25 November 2003
: 1:00pm - 2:30pm
: CARR Seminar Room, H615


The so-called transatlantic divide on biotechnology cannot only be observed in the amount of public uproar over the introduction of GM Food but also in the regulatory approaches to the issue. At first sight, and very general, the legal regulations in the United States seem to be less strict than on this side of the Atlantic.

National differences in the legal regulation of a seemingly identical issue are predominantly 'explained' by referring to the particular regulatory style of a given country. But instead of explaining why different objects of regulation are characterised by different styles, the national styles approach simply seems to state that there are differences. Thus, instead of revealing what the observable differences between two countries are about, the national style approach itself seems to be in need of an explanation. This paper therefore will present a comparison of the different regulatory approaches to GM Food in Germany and in the United States beyond the 'national styles approach'.

Instead it will be argued that by focusing on the interorganisational networks, which emerge around a given issue, a more appropriate understanding of the regulatory process itself can be achieved. As 'regulation' can then be conceptualised as a complex interplay of a legal rule, its addressees (organisations) and the given issue, the differences that occur at the surface can finally be traced back to differences in this very interplay. This hinted organisational-based concept of regulation at least aims to overcome the territorial trap in comparative research on regulation.