Articles

A Comparative Overview of EU and US Legislative and Regulatory Systems: Implications for Domestic Governance & the Transatlantic Trade and Investment Partnership

A. ALEMANNO, R. W. PARKER

Columbia Journal of European Law

2016, vol. 22, n°1

Departments: Tax & Law, GREGHEC (CNRS)

Keywords: TTIP, Regulatory Cooperation, Convergence, Divergence, Mutual Recognition, Equivalence, MRA, US-EU, race to the bottom, direct effect, implementation

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2721038


The aim of this report is to inform the EU-US Transatlantic Trade and Investment negotiations on enhanced regulatory coherence and cooperation, by providing negotiators, stakeholders and the public with a comparative overview of the US and EU legislative and regulatory processes in their current form, highlighting differences and similarities