Differing regulations and standards between countries usually makes no sense and just harms the consumer.
How is a Volvo made for the Swedish market unsafe on Canadian roads? EU and Canada recently signed a trade agreement so that they won't tariff eachothers' cars, but consumers still can't buy a car from a European dealer and have it shipped over.
Or vaccines. Why isn't there a global approval system?
Yeah yeah, everyone can point to an example where their regulatory agency's anxieties/delays/negligence prevented some issue, but fail to consider the impacts of all of their other delays/rejections.
Which is why we probably won't see much progress in harmonizing bigger regulations. Whose regulation gets to win? This has been a five-year fight over the color of a piece of plastic. Everyone even wants to agree - the automotive industry would love a worldwide standard to reduce specialized part count, rulemakers would love to agree in order to increase the shared market size (so everyone gets the same cars), but the actual standard to be put into place calls into conflict the exact safety versus cost thresholds each government has set. Imagine if there's actual conflict.
It isn't even about the colour (which is trivial to control with software and 8 extra cents in LEDs), but about the colour of the plastic.
That's the dumb thing that proves it's about protectionism. Same with DRL: it's controllable in software.
Meanwhile, Canada lets you import any >17 year old hunk of junk from anywhere and that's somehow safe and okay (because it doesn't harm new car sales so directly, yet still much more fatal to occupants).
There are far more important reasons to do this than protectionism and it's disingenuous to skip them and jump straight to protectionism.
Banning old cars would harm the parts of the population which can't afford brand new cars (that's a huge chunk) and guarantees that every time regulation demands something new everyone has to buy a new car.
On the other hand not mandating new safety tech harms everyone in general and guarantees that cars new and old will forever be much worse than they need to be since manufacturers won't be in a hurry to spend more money on tech. Keep in mind that a car with DRL and ABS will be an "old car" a few years from now. 10+ year old cars have ABS today because at some point it was mandated on all new cars.
It's a reasonable compromise to let people buy and use the old cars as they are (or anything that uses old, outdated tech - lead based solder in electronics?) but demand that new ones constantly integrate new tech.
I'm font on retro/rust-mods where they're updated with modern engines, controls, etc... others prefer completely stock/original as possible. In the end, it's not so different from being able to maintain a listed building in England or other heritage or historical works, other than it rolls down the roads.
> "The colour of the turn signals on vehicles in Europe is legislated to be amber," says Thomas Tetzlaff, spokesman for Volkswagen Canada. "In North America, there is no such legislation, but there are different regulations about the minimal surface area of the blinkers."
> North American regulations say rear signal lights can be either red or amber. Canada and the U.S. specify a minimum size for turn signal lights, but regulations in the rest if the world do not, Transport Canada says.
> Often, the easiest way for companies to get their turn signals big enough, without building brand new rear lights specifically for North America, is to also use the brake light as a turn signal, Tetzlaff says.
* https://www.theglobeandmail.com/globe-drive/culture/commutin...
I think it's super dumb that it's not a requirement any more, and I don't see any reason for the change.
If your car does not have those weak daytime lights (small lamps that basically dont do anything) then you are supposed to use the low/dipped beam. And most drivers use low beam all the time.
There is one more difference between DRL in EU and NA: in EU, the parking lights must be off, while DRL is on. This is a problem with some older cars, which technically do have DRL, but keep the parking lights on (i.e. pre-F series BMW; the angel eyes are parking light). This is non compliant in EU.
In the EU the turn signals is mandated to be amber. In the US/CA, the turn signal can be either amber or red, but must be of a certain area. Other jurisdictions do not have an area regulation.
So OEMs simply make brake lights double as turn signals when they import vehicles.
If the non-US OEMs 'just' made bigger turn signals they wouldn't have to do this.
America has a longstanding tradition of food fortification. Niacin is also used to supplement US diets featuring a corn staple -- corn's niacin is not bioavailable without additional processing traditional to Mesoamerican cultures. Probably more recognized today is iodized salt, which is responsible for perhaps a decade's worth of the Flynn effect in the US.
In the case of flour, Europe is lagging behind: https://www.ffinetwork.org/europe. Apparently Denmark went the extra step of banning enriched / fortified foods. You could probably argue that regional diets will naturally vary and that something like iodine supplements aren't required for Italians when they have ready access to seafood that Oklahomans don't. But since I'm pretty sure these enrichments aren't harmful to those who do have access, I imagine some of the divide is simply protectionism -- protecting your local markets and local manufacturers from cheaper American brands.
Niacin Toxicity
Symptoms of toxicity include: Flushing of the skin, primarily on the face, arms, and chest *This side effect may occur at doses as low as 30 mg/day. Itching. Nausea. Vomiting.
3 oz (85 grams) of "Chicken breast, meat only, grilled" contains 10.3 grams of the stuff[1], and average adults get about 30mg/day. Best I can tell this is about nicotinic acid specifically, and might be IV rather than ingestion, which is very much an apples and oranges situation.
1: https://ods.od.nih.gov/factsheets/Niacin-HealthProfessional/Fact is though, that here in Europe there is no need or value in adding this supplement, and generally the EU is wary of any adulterated foods without reason.
That's off by a factor of 1000x -- it says 10.3 milligrams.
In some cases these arguments are made in good faith.
In even rarer cases these arguments are true.
But initially it's wise to take them with a grain of salt.
"Iron deficiency isn't an issue, probably because there's lots of enriched foods, so let's stop enriching food!"
I think regulatory analysis requires a little more thought than that.
Furthermore, in many European nations the pasta is enriched, mainly with fiber although plenty of other nutrients are added depending on the brand and market. European countries just don't have regulations regarding "enriched macaroni" labeling like the US, which is an interesting historical quirk but irrelevant to what's actually in the pasta. Popular brands like Barilla are almost certainly enriched with something - depending on the size of the market it might have been enriched to American standards just to minimize manufacturing fragmentation (i.e. Italy, a huge consumer of pasta and origin of many of the brands will have formulas dedicated to that market, while Norway will receive whatever other formula is closest to their requirements).
Rather, it is (or was, originally) about protecting the brand of pasta noodles vs. ramen noodles, at a time when the difference was not as readily apparently to consumers.
It's the type of regulation that determines what is a "HD" tv, for example.
We don't need to wonder! They explain it right in the article: protectionism. It's not really that surprising that a lot of regulations have nothing to do with protecting the consumer and are all about protecting the parties that really matter to governments: big domestic industries.
> Around World War II, Carl explained, the established noodle industry (henceforth referred to as Big Pasta) was “upset” by the introduction of Nissin’s ramen noodles into the country, which were “completely out of spec” with what the United States then recognized as noodles — specifically because the ramen was being sold for a lower price and with what Carl called “lower standards” of nutrition. “They were really pressed,” said Carl. That’s when the “standards of identity” were created: Big Pasta made sure that all noodles had to meet certain specifications to be considered “enriched macaroni products” and sold in the United States.
In this case, the pasta industry did not want their product confused with the new noodles coming from Nissin; this was back in the days when many Americans may not have readily known the difference between pasta noodles and ramen noodles, and wondered why they were paying more for pasta than they could for ramen.
Now those rules might be perverted to suit protectionist goals, but that’s the whole art of effective hopefully minimalist regulation: it’s very hard to do.
Alternatively, it might be the fact that the pasta company in question was selling buccatini at a lower price, a competitor did an analysis, and they found that this company was saving money by skirting regulation that everyone else is complying with. And they did the right thing by forcing the FDA to apply the rules evenly to all companies.
Agreed. I'm not saying there's no rational underpinning to regulation, just that it's frequently gamed by bad actors, almost to the point that the original intent is forgotten.
Regulatory harmonisation is controversial though, especially here in UK. No matter that its usually boring stuff like agreeing fire retardant coatings on soft furnishings, the newspapers insisted this was a breach of sovereignty. Expect a new British safety standard (identical but with a different logo) to join the pack.
But then this one https://support.ce-check.eu/hc/en-us/articles/360008642600-H... says it's real, I'm confused.
Edit: I'm going to go through every single device/cable I have at home and examine the font and the arrangement of the two letters now, the C and the E need to be on two circles that overlap by exactly the width of the lines.
Also if you sell the "cheap crap" to some country outside of EU, you can still slap the nice CE logo there.
And since when shady Chinese companies care about copyrights anyway.
Maybe it's a lie that they tell themselves so they can sleep better at night. It's not unlike how "sovereign citizens" believe in various flawed legal arguments to justify how they don't have to pay taxes.
For example, Katsuobushi is the core part of Japanese food but it seems that exporting to Europe is difficult due to EU regulation. Another example in Japan would be K-car.
As a Japanese, I never want to give up Katuobushi for improving health. I suspect that maybe oppositely, European people also has food or culture that banned from other country .
This also means that the European variants don't have to meet the kei-car regulations regarding size, engine capacity or power output, so some of them are a bit bigger or have more powerful engines.
Can we trust states with major pharmaceutical industries to regulate pharmaceuticals? Major car production centres to regulate emissions? Major chemicals companies to regulate chemicals?
I'd be a little suspicious, living next to such a country, if they insist on my adopting the regulations they wrote, which of course their industries all successfully meet to the letter.
It's true that they don't make much sense and that they often harm the consumer, but I vote in my regional politicians and in theory can vote them out if they impose standards I don't like.
One of the problems with Europe was the perceived lack of democratic control coupled with the dishonesty from anti_EU campaigners about things like straight bananas.
I don’t care for this, but I understand it. Rarely do we hear about the lives that were saved thanks to the regulatory body doing its job.
Even ignoring protectionism there are a billion different ways to make reasonable regulations and many of them will be incompatible in some ways.
Countries working together on regulations is a thing, but it also does slow down things and takes a lot of effort.
>Or vaccines. Why isn't there a global approval system?
I don't see any way how that could work out any better than the current situation.
Global systems are inherently more fragile, no? More eyes on something is always a good thing, less likely to be corrupted by corporate interests, etc...
Both USA and UK markets take steps to avoid salmonella. The method the USA requires the eggs to be refrigerated, the method the UK uses effectively requires that they are not (at least not until you get them home, once you start you can’t stop).
https://www.npr.org/sections/thesalt/2014/09/11/336330502/wh...
You get objections to GMO food in Europe while in the US this doesn't even have to be labelled.
Chocolate standards that mean most US chocolate cannot legally be called chocolate in Europe as it doesn't contain enough cocoa.
Chicken has to be chlorine washed in the US before sale, a practice that is prohibited in Europe.
Eggs in the US are washed before sale which makes it necessary to keep them in the fridge afterwards while in Europe eggs are nornally sold unwashed (in some countries (all EU?) It's even prohibited to wash them).
Let's not even talk standards for wine and raw milk cheese, use of corn syrup, regional denominations, slaughter and animal welfare rules, ...
Not easy to find a simple resolution to such strong differences in some sectors. Opposition to trade deals among Europeans usually stem from (1) fears of lower food standards (incl. animal welfare), (2) worries about slavery and labour exploitation and (3) worries about low environmental standars. I'm sure the US has similar recurring themes popping up.