In the U.S., “the manufacturer simply puts its vehicle in the market and declares that it is compliant with all the relevant U.S. regulations,” said Dudley Curtis, communications director with the European Transport Safety Council.
Cars in the EU, however, must be submitted to a national type approval body in one of the member countries that is responsible for certifying the car and alerting other capitals should a recall be needed.
“It’s a long and complex process,” Curtis said.
American cars do make it onto European roads, but they have to be approved on a case-by-case basis. A broader exemption would allow for much larger — and quicker — exports.
Adding to the regulatory difference is the United Nations Economic Commission for Europe, which sets global car standards — something the EU abides by but the U.S. does not.
Because the U.S. does not adhere to the U.N. regulations, “the EU cannot simply start recognizing them without undertaking legal changes — for example, by amending existing regulations or adding new ones,” Lawrence Freeman, an automotive-focused lawyer at Bird & Bird, said in an email.
