Despite the general similarity of the two agreements there is a major difference in the domain of standards. While the exact rules are rather complex and detailed and also differ for different types of NTMs, the main difference is that in CETA the standards of the importer country will prevail, while TTIP strives for mutual recognition of standards. Irrespective of the comprehensive tariff reduction and elimination, generally CETA does not eliminate the differences in standards. Imports still need to comply with the rules and regulations that the product in question needs to satisfy on the respective import market (technical, sanitary or phytosanitary rules for the security and the protection of the consumer, the user or the environment, including notably food safety and labelling requirements). There are several procedural improvements (e.g. regarding ‘Technical Barriers to Trade’, TBTs) making it easier for an EU exporter to obtain the required certification for the Canadian market (and vice versa) that obviously lower trade costs but Canadians standards have to be obeyed (and vice versa). Hence, many of the sensitive issues debated in TTIP remain untouched by CETA.
The situation regarding standards is entirely different in TTIP as the US insists on ‘regulatory cooperation’ which may mean harmonisation of standards or mutual recognition of standards. Mutual recognition of standards means that a product admitted to the US market may also be sold anywhere in the EU (and vice versa) or a body needs to decide on the applied standards. While harmonisation or mutual recognition of standards will entail the largest trade effects, it is therefore here where most risks, be it environmental or health-related) for consumers may arise.
