Transatlantic Convergence of PTAs’ Environmental Clauses

24 Pages Posted: 13 Oct 2017

See all articles by Jean-Frederic Morin

Jean-Frederic Morin

Université Laval - Departement de Science Politique

Myriam Rochette


Date Written: October 12, 2017


The United States (US) and the European Union (EU) include several environmental clauses in their respective preferential trade agreements (PTAs). Building on an exhaustive and fine-grained dataset of PTAs environmental clauses, this article makes two contributions. First, it show that the US and the EU have initially favored different approaches to environmental protection in their PTAs. US concerns over regulatory sovereignty and level playing field have conducted to a legalistic and adversarial approach, while EU concerns for policy coherence have led to a more procedural and cooperative approach. Second, this article provides evidence that European and American trade negotiators have gradually converged on a shared set of environmental norms. Although the US and the EU initially pursued different objectives, they learned from each other and drew similar lessons. As a result, recent American agreements have become more European-like, and European agreements have become more Americanized. This article concludes that US and EU approaches, far from being incompatible, can usefully be combined and reinforce each other.

Suggested Citation

Morin, Jean-Frederic and Rochette, Myriam, Transatlantic Convergence of PTAs’ Environmental Clauses (October 12, 2017). Available at SSRN: or

Jean-Frederic Morin (Contact Author)

Université Laval - Departement de Science Politique ( email )

Ste-Foy, Quebec G1K 7P4

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Myriam Rochette


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