US/EU Business Groups Letter on Regulatory Cooperation Issues

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October 23, 2012

Ambassador Miriam Sapiro
Deputy U.S. Trade Representative
Office of the United States Trade Representative
600 17th Street NW
Washington, DC 20508
USA

Director General Jean-Luc Demarty
DG Trade
Policy Coordination Unit - Trade 01
European Commission
B-1049 Brussels, Belgium

Re: US-EU Regulatory Compatibility

We, the undersigned associations, write to strongly encourage the U.S.-EU High Level Working Group on Jobs and Growth (Working Group) to endorse ambitious and well-developed regulatory cooperation provisions as part of any recommended negotiation that seeks a highstandard transatlantic trade and investment agreement. Strengthening economic ties and enhancing transatlantic regulatory cooperation through an agreement that would include both goods and services, including financial services, are essential to eliminating unnecessary regulatory divergence that may act as a drag on economic growth and job creation.

U.S. and EU regulators already cooperate extensively with one another, both directly and in the context of broader formal arrangements such as the G-20 dialogue, the Transatlantic Economic Council (TEC), the U.S.-EU High Level Regulatory Cooperation Forum (HLRCF), and the U.S.- EU Financial Markets Regulatory Dialogue. However, these arrangements can be made much more effective and should include enhanced opportunities for dialogue with stakeholders. Any agreement should enhance current efforts and develop the regulatory cooperation mechanisms needed to unlock the true potential of an agreement.

Such provisions should comprehensively and ambitiously address traditional technical barriers to trade and sanitary/phyto-sanitary issues. These provisions should also expressly encourage regulators to work together to reduce and eliminate duplicative and inconsistent measures in existing regulations and where appropriate utilize recognition arrangements. In addition, the agreement should work to limit future unwanted regulatory divergence by promoting a better understanding of the impact significant regulations may have on the transatlantic market and facilitate information sharing, which will ensure regulatory decisions when appropriate, reflect the marketplace, are fact based, grounded in sound science, and undergo thorough regulatory and cost-benefit analysis.

We thank you for your consideration and look forward to the opportunity to assist the Working Group in developing and implementing regulatory cooperation provisions that maximize benefits to stakeholders, the government and the public.

Advanced Medical Technology Association

American Automotive Policy Council

American Chemistry Council

American Council of Life Insurers

Association of British Insurers

Association for Financial Markets in Europe

Biotechnology Industry Organization

BUSINESSEUROPE

Business Roundtable

Coalition of Service Industries

The Council of Insurance Agents and Brokers

Emergency Committee for American Trade

European-American Business Council

European Federation of Pharmaceutical Industries and Associations

European Chemical Industry Council

Financial Services Roundtable

Insurance Europe

Medical Imaging Technology Alliance

National Association of Manufacturers

National Foreign Trade Council

National Electrical Manufacturers Association

Personal Care Products Council

Pharmaceutical Research and Manufacturers of America

Securities Industry and Financial Markets Association

TheCityUK

The TransAtlantic Business Dialogue

Transatlantic Coalition on Financial Regulation

U.S. Chamber of Commerce

United States Council for International Business

Business Roundtable

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