Different Experiments, Similar Lessons: How the US and EU Have Converged on Environmental Norms

Several analysts consider that environmental protection might become a major stumbling block for TTIP negotiations. Their argument is that EU and US environmental standards are so different, rooted in principles that are so fundamentally incompatible, that it would be nearly impossible to bridge them. This paper argues that the prospect for successful TTIP negotiation on environmental norms is brighter than what is commonly assumed. Stronger forces bring the US and the EU together on the trade and environment nexus than pull them apart. While they initially sought different objectives by introducing environmental provisions in their respective trade agreements, they came to draw similar lessons, learn from each other, and gradually converge on a set of environmental norms. Recent US trade agreements have become more European-like, and EU agreements are getting more Americanized. While it is important not to overlook residual differences in US and EU models, a myopic view might lead to overstate their differences, and consequently underestimate the likelihood of successful negotiations on environmental provisions.