Why do the USA and the European Union treat GMOs so differently?

Question

According to the sources cited within this paragraph, there is a scientific consensus that "currently available food derived from GM crops poses no greater risk to human health than conventional food, but that each GM food needs to be tested on a case-by-case basis before introduction."

However, United States and European Union seem to have very different policies regarding GM food:

USA - according to this source,

The United States does not have any federal legislation that is specific to genetically modified organisms (GMOs). Rather, GMOs are regulated pursuant to health, safety, and environmental legislation governing conventional products.

and

GMOs are not restricted categorically from the US food supply. As discussed above, the FDA treats foods derived from GMOs like those derived from conventionally bred plants, and therefore most foods derived from GM plants are classified as presumptively “generally recognized as safe.

European Union - according to this paragraph (Approach)

uses the precautionary principle demanding a pre-market authorisation for any GMO to enter the market and a post-market environmental monitoring.

As a result, GMO crops are banned or very small in most EU countries. Also, there is no EU country within the top 10 of countries of genetically modified (GM) crops, as indicated here.

Question: Why is policy regarding GM food so different between USA and EU?

Answer 1

TLDR: because Europe prefer to be cautious, and it's worked nicely thus far.

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why is policy regarding GM food so different between USA and EU?

Because history tells a story. Europe is stricter in what they want to be consumed and produced.

The development of GMO foods in Europe played out at the same time as the initial steps toward integration of national food safety systems into the European Food Safety Authority (EFSA) were taking place. It was politically contentious because national constituencies were losing some of their influence over home-based regulation. (How we got to now: why the US and Europe went different ways on GMOs)

Kym Anderson and Lee Ann Jackson over at AgBioForum wrote a great piece from the perspective of ratifying the difference between both sides with the results they produce:

Results indicate that changes in real income of producers can help explain differing GM policies in these two regions.

Specifically the introduction explains:

Over the past decade, the United States (US) and the European Union (EU) have implemented widely divergent regulatory systems to govern the production and consumption of genetically modified (GM) agricultural crops. In the United States, many products have been tested and commercially produced and marketed, while in the EU, few products have been approved and a de facto moratorium has limited the production, import, and domestic sale of most GM crops. These divergent approaches have led to conflict over the implications for international trade in genetically modified products, to the point where in September 2003 the United States, Canada, and Argentina succeeded in establishing a World Trade Organization dispute panel to begin to test the legality of European policy towards imports of GM foods.

This article indicates that farm interest groups hold a larger say on policy in both regions, they also indicate it's down to how long the process of accepting GM related foods in each region takes:

In the United States, three different agencies are responsible for various aspects of GM crops. The Food and Drug Administration makes market approval decisions, the Environmental Protection Agency monitors the use of crops that produce their own pesticides or herbicides, and the US Department of Agriculture regulates the introduction of new crops into the environment during field testing.

whereas,

In the EU, prior to the initiation of the production moratorium, the approval process entailed a long iterative process among EU and state-level regulatory agencies, with the final step being evaluation by the EU Council of Ministers. If the product was not deemed safe at this stage, it could be neither produced in nor imported into the EU.

But it just doesn't boil down to simply how they process the same products differently. History will tell you another story in why opinions differ:

A slightly more complete history would point to a number of other incidents that have led to the sharp division of opinion that exists today. The Flavr Savr tomato in 1994 was the first genetically modified crop to be commercialized. Designed to stay ripe and firm longer, the product failed to meet the needs of the US tomato industry. But there is also ice-nucleating or “Frostban” bacteria; StarLink corn; the Pusztzai incident; African rejection of US food aid – the list continues.

The Bottom Line

During GMOs early days in Europe, a series of food safety debacles undercut Europeans’ confidence in the food and agricultural industry. Mad cow disease and the radioactive contamination of European fields after Chernobyl led Europeans to be leery of bad scientific decisions made elsewhere (How we got to now: why the US and Europe went different ways on GMOs).

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Further Reading:

1. The Regulation of GMOs in Europe and the United States: A Case-Study of Contemporary European Regulatory Politics
2. Differing U.S. and European Perspectives on GMOs: Political, Economic and Cultural Issues
3. The U.S. and EU: Different Approaches

Answer 2

One other reason to consider is protectionism.

Food is one of the most strategic of resources. A country can run short of a lot of things, but food is not one of them. Run low on food, and your country is in serious trouble... hungry people are desperate people, especially if they are not accustomed to being hungry. In unusual times, if foreign food shipments are cut off, the country could be left in a precarious position.

That is a primary reason countries like to foster agriculture within their borders, partially by discouraging lower cost imports that could put their farms out of business. Naturally, this conflicts with free trade agreements and invites retaliatory tariffs on the part of the foreign nation. Such a situation brewed up into the 'chicken war' between the US and several European nations in the 1960's:

The Chicken war

And Europe faces stiff competition in agriculture from the US - one of the few nations that produces more food than it consumes. A good deal of the reason the US can do so, at a much lower cost, is just available farm land. The US has a lot more than all of Europe put together.

Thus, the GMO restrictions serve as a clever way to protect local agriculture from competition, without directly inviting trade retaliation. We'd love to buy your food, but it's not up to our standards. Gosh darn it all.

The New York Times covers this subject in detail:

NYT on GMO objections and protectionism

Answer 3

One thought is to consider is their political history.

Europe has been moving from monarchy in the distant past to more individual freedom throughout history. I imagine this leaves a greater trust in or tolerance of government regulation in their culture today.

Meanwhile the United States was founded by people trying to get away from monarchs. Individual choice was valued very highly, so today people would still have a tendency to trust more in individual choice more than trusting government regulation.

There are more factors to consider, but I feel their history gives some insight to the general culture of the two regions today.

Answer 4

Question: why is policy regarding GM food so different between USA and EU?

Competitive positions in agriculture science and approach to risk taking.

The US is far more advanced than Europe in terms of industrial agriculture, thus productivity, in large part due to agriculture science. If Europe were to open up to GMO food, its farmers would stand no chance off competing vs. the US counterparts or imports.

Both approaches are reasonable responses to potential risks, with the US approach being more aggressive. The European approach essentially says that science is always advancing and what's understood to be safe today can be proven to be unsafe in the future. So let's take a more cautious approach.

The US approach is more like "it is safe unless it is proven unsafe." That approach encourages more innovation and risk taking, but obviously it can be and is riskier.

Answer 5

Because the USA is much more amenable to corporate lobbying and the US judicial system essentially hands power to corporations over individual freedom. Monsanto's behavior to family farm businesses should make this abundantly clear.

In contrast, Europe prefers individual privacy and freedom over corporate dominance, relatively. Some call this leftism, but that is part of the corporate dogma.

In essence I think it boils down to the USA being a corporate-state system, where Europe is a federation of nation states, each with huge legacies of history and tradition.

Answer 6

I think a lot of Americans seem too indulgent in romanticism concerning "liberal" Europe. The deep crux of the matter here is over party politics and the power of the far-left.

Europe has a diverse political culture that allows a variety of political parties to thrive at various levels of government; a citizen frequently votes for a different party at local, sub-national, national, and supra-national level.

The Greens have historically been against genetically modified products due to concerns about commercial abuse and harm towards the environment - the pro-GM lobby is often equated with the pro-nuclear lobby, and so GM is a "liberal cause" rather than a "green cause".

There aren't substantial differences in the number of people in either Europe or the United States that dislike GM, but rather it's far more likely that the far-left can influence politics as they get elected in at lower levels of government.

Answer 7

From an anecdotal standpoint I would say it's due to a lack of lobbying in Europe on the part of agro business companies. For example, I have a friend that lives in Netherlands. He says the only American cereals available are corn flakes. Just plain non high fructose corn syrup based corn flakes.