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Regulatory convergence between the EU and the US through TTIP: Comparative analysis of REACH, GDPR, TSCA and CCPA
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Hagovsky_22551900_2022.pdf
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- This master thesis is focused on the notion of regulatory convergence. It discusses the possibility and extent of regulatory convergence, specifically between the European Union and the United States of America through Trans-Atlantic Trade and Investment Partnership. The aim of this thesis is to identify possible obstacles, when it comes to regulatory convergence between the two parties. In order to do this, this research is going to compare two regulations from the European Union, more specifically the Registration, Evaluation, Authorization of Chemicals (REACH) and the General Data Protection Regulation (GDPR). These two European regulations will be compared to the two regulations in the United States, more specifically, the Toxic Substance Control Act (TSCA) and the California Consumer Protection Act (CCPA). The aim of this master thesis is to answer the research question which is: „„What are the biggest obstacles when it comes to higher regulatory convergence between the EU and the US?“ The biggest obstacles, according to the author, are the four regulations, which is the main focus of this master thesis. In order to see possible scenarios of how the regulatory convergence could happen in the future, the conclusion will offer three possible scenarios.