Organic regulation across the Atlantic: emergence, divergence, convergence

Battles over the labelling of genetically modified organisms, the use of hormones in livestock production, and geographic indicators reveal persistent differences between the EU and US within the regulatory domains of environment, agriculture and food safety. Comparative studies have shown that culturally specific accountings of risk have fuelled different approaches to regulatory problems across the two jurisdictions. An analysis of organic regulation suggests that these characterisations remain useful, but should not be oversold. Differences in regulatory culture, as well as differences in explicit goals and mechanisms, set organic food regulation on different paths in the EU and US. However, whereas such differences have led to polarisation in other domains of food regulation, there has been relative convergence with respect to organic standards. Drawing on theories of regulatory convergence, this paper argues that polarisation was averted due to the ability, ultimately, of social movements working within and across borders to influence both sets of regulations, albeit through different channels.