Abstract

Global food trade exposes sharp differences in food safety regulation, especially between the EU and the US. The EU follows a precautionary, hazard-based model, allowing intervention under scientific uncertainty to protect consumers, maintain public trust, and avoid long-term risks. The US applies a science-based, proof-of-harm approach, requiring clearer evidence of risk before limiting market access, supporting innovation and regulatory efficiency. These contrasting philosophies create trade tensions and non-tariff barriers, as seen in disputes over hormone-treated beef, genetically modified organisms, and chlorine-washed poultry. Beyond the transatlantic context, countries adopt precautionary, science-based, or hybrid systems depending on domestic priorities, institutional capacity, and trade commitments. Hybrid models in India, China, and parts of Africa combine precautionary safeguards with evidence-based risk assessment to balance consumer protection and market access. International bodies such as Codex Alimentarius, the WHO, and the WTO help manage regulatory divergence through standards, guidance, and dispute resolution, while recognising precaution under uncertainty. Recent EU agreements with Mercosur and India show pragmatic cooperation through transparency, safeguards, and sanitary and phytosanitary commitments. Overall, effective global food governance depends on hybrid, coordinated, and adaptive approaches that reconcile health protection, trade facilitation, and innovation.

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