"In their efforts to establish a common European market the Community institutions became aware of wide range of non-tariff barriers to trade which stem from national product safety legislation. “Deregulation” is no realistic option in that field in view of the strength of public concerns with product safety. In order to prepare the grounds for Community action comparative research seems indispensable. Comparative analyses which would include the regulatory philosophies of pertinent legislation and the methods of its implementation are so far simply unavailable. The four studies on France, Britain, Germany and the United States in this chapter have to fill a gap. They identify the specifics of these systems and extend heir analyses to the role of standard setting and certification. The United States are included because their Consumer Product Safety Act and its implementation through a regulatory agency provide a particularly sophisticated, albeit controversial, example which the Community needs to be aware of when designing its own policies."

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