ABSTRACT
Coping with the risks and uncertainties that pervade our lives has become an increasingly onerous challenge for regulators (Baldwin 1997; Joerges 2001: 1). In particular, the challenge engendered by modern biotechnology has triggered numerous regulatory responses and legal developments at the national, regional and international levels (Christoforou 2004: 640; Murphy 2001: 47; R. Mackenzie 2002: 97). Yet, regulatory approaches to genetic engineering vary significantly, especially between Europe and the US (Scott 2003; Pollack and Shaffer 2001; Vogel and Teel 2000: 649). The differences have led to the already famous dispute at the WTO where the United States challenged EU policy on transgenic products, including national safeguard measures (Scott 2004). So, opposites may oppose one another, but, of course, they may also learn from each other. This is why it is constructive to scrutinise different regulatory systems on genetically modified organisms (GMOs), which operate at separate governance levels, in order to provide useful comparative insights that can help to achieve better understandings of (common) problems and to overcome shared difficulties. Moreover, it is also instructive to investigate the development and features of regimes that are new members of regional organisations – more particularly, the Polish regime within the EU – in order to examine how they fit within and adapt to the supranational framework.
