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Comment by Scoundreller | Hacker News Reader

It's a good point though. Why/how is something unsafe for an American, but safe for an Italian or Spaniard?

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.

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> It's a good point though. Why/how is something unsafe for an American, but safe for an Italian or Spaniard?

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.

I've no idea how much Niacin is added in America, but you can have too much. Since we don't eat much corn here in Europe, packing food unnecessarily full of this supplement could be dangerous to health:

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.

I'm really not sure where that citation is coming from. It's a Google web answer but the source has no citation. Wikipedia lists a textbook, rather than anything from NCBI, and I'm too lazy to dig further. A corn torilla or slice of bread in the US typically has 1-2 mg of niacin, and a daily recommendation of around 16mg.

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/

Agree, I didn't dig - was the first result I found.

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.

And for good reason.

> "Chicken breast, meat only, grilled" contains 10.3 grams of [niacin]

That's off by a factor of 1000x -- it says 10.3 milligrams.

Apologies for the typo

Domestic producers of [all products] in [all countries] have a longstanding tradition of using the apparatus of government to protect their business from competition. These arguments typically take the form of national security, consumer safety and unfair competitive practices.

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.

But make sure that salt is made from a source that complies with your countries regulations on salt manufacturing and labeling...

Iodine in salt is also normal in Europe. I think mandatory in at least a few countries, possibly the whole EU.

There are various regulatory trade-offs between safety and cost of compliance. For instance: Cars sold as new in Canada require daytime running lights and yellow rear turn signals, due to extended periods of low visibility. While the running lights are a requirement in Sweden, they aren't in Poland or many other European countries. There's been some effort on standardizing between US and Canada since 2016, which would allow for a North American market car to solely use yellow turn signals, but progress is slow.

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.

> over the color of a piece of plastic

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).

> Meanwhile, Canada lets you import

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.

From what I’ve seen, the >17yr old imports aren’t to save money, but your chance to finally drive something exotic that wasn’t (or wouldn’t) be approved for sale here. E.g. RHD, Kei cars, Nissan Skylines

As someone passively enthusiast about cars, I think that's in general a good thing. People buying classic/old cars generally know it's not going to have current safety regulations, but may still appreciate it and take the risks.

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.

For those who haven't been to the US, I was blown away that some cars use brake lights as the turn indicator - good video on the set up (and issues): https://youtu.be/O1lZ9n2bxWA

I was confused the first time I saw this in the US. Thanks for sharing the video, but nonetheless I’m still surprised that something as common sense as amber vs red lights for different functions is still something US-bound models fail to adopt. As the video explains cost saving must not longer be an issue, so I guess it is regulatory inertia.

Slightly different regulations between EU and US/CA:

> "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...

All new EU models have daytime running lights and yellow turn lights. What ever is a requirement in Sweden is basically an EU one as well. Thanks to standardized EU certifications. Which is a good thing, mostly!

It’s true that EU regulation on this topic was harmonized in 2011. However, the harmonization actually loosened the Swedish requirements in several ways, particularly with regard to rear lights, which previously were required to be always on.

Which would make sense in general, wouldn't it? The thing with the rear lights being on.

Depends. Might make sense in countries with polar nights, not so much in the Mediterranean where it just sucks up energy, especially with EVs.

It does seem that the updated regulation allowed new cars to be less safe in the Nordics. It’s an interesting precedent.

I wouldn't imagine the power draw from always-on rear lights to be especially high compared to, you know, actually moving the vehicle, especially if those lights are LEDs. And the studies I'm finding measuring this exact concern don't seem to show particularly significant impacts on fuel efficiency / emissions for ICE vehicles (a couple percent, tops, and that's assuming small cars w/ tiny engines and some pretty comically inefficient DRL implementations - hardly relevant for creating a new standard that can mandate e.g. dedicated LED-based DRL systems).

I bought a car (Citroën) a few years ago, and told the dealer I wanted it so the rear lights would always be on. They configured whatever doohickey is responsible for that, and made sure to charge me for it. But now the rear lights are always on, like they're supposed to, and I feel a little safer.

I think it's super dumb that it's not a requirement any more, and I don't see any reason for the change.

That's what we have California for. They're like america's exhausted mother, constantly swooping in to prevent us putting bad things in our mouths or being jerks to other kids.

Your comment is cancer (in the State of California).

Daytime lights are obligatory in Poland since it joined EU - so for like 15 years. The standard is the same for whole EU.

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.

Using DRL during the day (i.e. normal visibility) is not mandatory in Austria. You may use them, or dipped beam, if you choose so.

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.

> This has been a five-year fight over the color of a piece of plastic.

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.

Different product, but eggs make an interesting example of why:

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...

That's the importance of regulatory harmonisation. Eg your laptop charger is probably covered in 20 different indecipherable logos showing compliance with every countries regulators, all of whom have standards at least 99.9% identical. The EU has harmonised regulations internally in order to make completely free trade work, so a single 'CE' logo is enough to show compliance for the entire EU.

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.

I’m really looking forward to a pile of reduced-safety standards from the people who gave us the Grenfell disaster...

Note that there is the CE symbol (confirmation of Europan standards) and there is also a very simila CE symbol that means "China Export". The second one does not have anything to do with European standards. It is deceptively similar.. guess why

Wikipedia says the European Commission says this is an urban legend https://en.wikipedia.org/wiki/CE_marking#China_Export I mean I don't know anything about it, just wanted to point that out.

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.

Isn't it trademark infringement either way? If you tried this with the apple logo and your business was us based you'd be sued out of existence.

I speculate that this logo is mostly used for "cheap crap" where they stamp any random logo you want.

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.

I think part of the puzzle is why they would cheat by stamping a logo that is almost right but not quite. Is it that their level of honesty such that they wouldn't cheat regulations but would cheat a trademark? Maybe they themselves can't tell which logo is the correct one so they just stamp anything?

>I think part of the puzzle is why they would cheat by stamping a logo that is almost right but not quite. Is it that their level of honesty such that they wouldn't cheat regulations but would cheat a trademark?

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.

Do you know if there’s an accurate master list of these labels anywhere? I’m sure the customs and border people must have at least a reference copy floating around.

In this particular case it's not even a matter of safety: pasta with <13 mg/lb of iron is no more or less safe than pasta with >13 mg/lb, and as far as I can tell (read: Wikipedia) iron deficiency does not appear to be a serious health problem for most Americans (or Europeans). If anything, mandatory enrichment seems like an arbitrary trade barrier imposed on the US side to protect what the article calls "Big Pasta" from foreign interlopers.

> as far as I can tell (read: Wikipedia) iron deficiency does not appear to be a serious health problem for most Americans (or Europeans)

"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.

The fact that European pasta isn't enriched and we don't have iron deficiency issues gives a good hint, so.

Different regions have diets made up of different ingredients, which have different levels of various minerals. Humans don't all eat the exact same thing and they don't all exist in the same exact climate so regulations tend to be curated to their local constituents.

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).

I'm not even opposed to iron enrichment for the basic flour used to make Wonderbread-type cheap staples, but mandating it for fancy imported bucatini seems more than a little ridiculous.

"Standards of Identification" are not about safety, but rather marketplace regulation against deception. After all, if it was about safety, then ramen noodles wouldn't be sold at all.

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.

The article literally describes this.

Regulation isn't made just by health/safety perspective, but includes cultural, social and others.

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 .

https://www.nippon.com/en/views/b01723/

The article you linked makes it rather clear that the reason for banning imports has nothing to do with culture but with the carcinogens in the product. The Spanish factory uses a safer smoking process.

I think Germany and the Netherlands have some similar vehicles to the K-car, but not sure they are the same from a regulation point of view

Some Kei-cars were and are sold in Europe, but they are regulated the same as any other car, rather than having specific tax and regulatory advantages like they do in Japan.

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.

Wasabi is impossible to get in the USA, my understanding was that this was because of Japan's rules rather than those if the USA. We just have horseradish with green food coloring in the USA.

It's not impossible, it's just expensive to import and difficult to store. Higher end sushi places would usually have it. Now there are at least two farms in the US producing it that I know of, one in Washington state, and another in Half Moon Bay, near San Francisco, and there's even some retail distribution now in SF.

That is very exciting! My old karate instructor owned a sushi restaurant and I got the strong impression that the mob looked poorly on attempts to export. He may have been exaggerating.

I work for an automotive manufacturer that has a model that couldn’t be sold in the United States due to its lack of a steering column airbag (probably along with other items). It has led to an aggressive destruction of imported vehicles by customs officials and seizing of legal vehicles due to mistaken identity.

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.

> It's a good point though. Why/how is something unsafe for an American, but safe for an Italian or Spaniard?

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.

“Standards of Identity” are not in and of themselves a bad thing. If a product comes to market claiming to be one thing but it is not, it may damage the market for all other products. Imagine a tv manufacturer claiming to sell a HD tv that is not HD, for example.

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.

> 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.

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.

Cars of the same model made for different markets have varying safety features. US destination Japanese cars have better crash protection than those made for their domestic market.

> Differing regulations and standards between countries usually makes no sense and just harms the consumer.

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.

The problem is that unless the bad regulation is hurting everyone a lot the regulations will be around for 10-50yr after you vote them out.

It seems that regulations are often a little more lax on products produced domestically.

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.

Different doesn't mean one is better or worse.

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.

Sometimes who gets to make the rules is far more important than what the rules are.

This is profound.

Because we don't have a world government so every government can do what they want.

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.

Aerospace goy pretty close, with EASA and the FAA accepting each others certification. Until the FAA blew the 737 MAX and everyone had to show how tough they are. And because the FAA did screw up.

And in Brazil the certification caught the problem... Not accepting each other certification with blind eyes can be a good thing.

Couldn't agree more! Even just conducting double checks on others certification would do a lot of good.

I wonder how many Embraers pass Brazil certification but fail FAA/EASA.

As mentioned later in the article, the offending requirement likely isn’t a safety thing, but a 1940s era protectionist thing.

How is Boeing Max safe for Americans but it crashes elsewhere?

This was just luck. An aircraft with a special randomly-initiate-death-plunge function will crash somewhere first and somewhere else second. If the public is stupid enough to keep flying in it, eventually it will crash all over the place. In this case, the flying public decided that two horrible crashes was enough.

Look up the blancolirio channel on YouTube, specifically the Max episodes and you'll how close we came to crashing them here.

> Or vaccines. Why isn't there a global approval system?

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...

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