Different TBT Approaches
Technical barriers to trade vary widely across countries, not only in scope but also in the way they are implemented. While some economies emphasize domestic safety or consumer protection as justifications, others use TBTs to advance strategic interests or protect key sectors. These measures can include country-specific testing protocols, opaque approval processes, or restrictive labelling and localization requirements—particularly in sectors such as telecommunications, medical devices, and digital services.
The United States generally adopts a more flexible and decentralized approach to technical regulations. It tends to promote voluntary standards, often developed by private-sector bodies, with an emphasis on innovation, market competitiveness, and responsiveness to technological change. This model contrasts with more prescriptive and centralized frameworks seen in other major economies and is designed to minimize regulatory burdens while safeguarding consumer interests and national security.
China, by contrast, employs technical standards as an important tool of industrial policy. The Chinese government actively uses TBTs to support national champions, control access to its market and influence global norms. These barriers include mandatory national standards, complex product certification schemes, data localization requirements, and selective enforcement of environmental or safety regulations. While often presented as neutral or technical, such measures frequently serve strategic objectives, creating significant challenges for foreign exporters.
The European Union, meanwhile, presents itself as a leader in “normative globalization,” aiming to export its regulatory model through what has been described as normative power. However, it faces significant challenges, including regulatory slowness, complexity, and frequent misalignment among Member States. The proliferation of technical barriers within the EU could represent a significant obstacle for goods and services produced in the United States.
As tensions rise and supply chains become more fragmented, the battle over who sets the rules is becoming more strategic than ever.
U.S. Tariff Strategy as a Countermeasure
The U.S. National Trade Estimate Report on Foreign Trade barriers (2025), detailed in a 397-page document the tariff and non-tariff barriers that, according to Washington, hinder U.S.–EU trade. In this context, tariffs have often served as a U.S. response to what it perceives as an unbalanced trade relationship — partly driven by the EU’s technical barriers. Non-tariff technical barriers — such as strict regulations on genetically modified crops, pesticide residues, recycled content requirements, and chemical safety standards — create significant challenges for U.S. exporters.
In the Report the imbalance between attention given to technical barriers and tariffs is striking. For China, the report dedicates five pages to Technical Barriers to Trade and only two pages to tariffs. For the European Union, the contrast is even more pronounced: seventeen pages address technical barriers, compared to just two pages on tariffs. This distribution clearly highlights how non-tariff measures, particularly technical barriers, have become a central issue in global trade, with tariffs representing only a part of the broader picture. This detailed report lists the tariff and non-tariff barriers that, according to Washington, hinder trade with commercial partners and impede market access. Among the highlighted non-tariff barriers are food safety regulations, recycled content requirements, and renewable energy standards, which are considered significant obstacles for U.S. exports. To address these non-tariff barriers, the Trump administration proposed imposing reciprocal tariffs on certain products. These tariffs aimed to match the highest tariffs applied by other countries to those U.S. goods, effectively offsetting the disadvantage caused by the EU’s technical barriers. This tariff strategy was intended as a countermeasure to restore a more balanced trade relationship by compensating for the restrictive non-tariff measures imposed by other countries.
By reducing these non-tariff barriers, the EU and China could, in return, face fewer tariffs from the United States, as such measures would address the underlying imbalances that prompted the U.S. countermeasures in the first place.
Concrete TBT Examples One emblematic case is the export of U.S. beef to the European Union, which faces technical barriers strongly contested by Washington. The primary obstacle is the EU ban on beef treated with growth hormones. American producers can only export beef to the EU if they demonstrate — through a lengthy and complex certification process — that the meat is free of such substances.
China, similarly, imposes technical barriers on U.S. exports, particularly in the technology sector. U.S. companies selling network equipment or cybersecurity software must comply with local Chinese standards and undergo extensive testing, often duplicating international certifications. For instance, they must meet requirements such as the China Compulsory Certification (CCC) and pass cybersecurity reviews. These regulatory demands delay market access and introduce strategic uncertainty for American firms, especially in sensitive sectors like cloud computing and telecommunications.
Current Global Strategic Standards Contest and China 2035
Apart from global Standards Developing Organizations (SDOs)*, various national and regional bodies handle technical standards:
Europe has bodies like the European Telecommunications Standards Institute (ETSI), European Committee for Standardization (CEN), and European Committee for Electrotechnical Standardization (CENELEC).
The U.S. has the National Institute of Standards and Technology (NIST), focused on maintaining competitiveness in technology industries.
In China, the process is a collaborative effort between the state and private industry, with the party-state involved at every step. China officially launched the ‘China Standards 2035’ strategy in 2018, aiming to set global standards for emerging technologies such as 5G, IoT, and AI. This initiative highlights China’s intent to use technical standards as a geopolitical tool to advance its long-term development and global influence.
*A standards development organization (SDO) is an organization focused on developing, publishing, or disseminating technical standards to meet the needs of an industry or field.
The WTO’s Role
The World Trade Organization plays a key role in reducing technical barriers, mainly through the TBT Agreement, which encourages transparency and promotes mutual recognition of standards among members. However, rising geopolitical tensions challenge the WTO’s influence, with bilateral and regional strategies gaining prominence.
To strengthen its effectiveness, the WTO could enhance its dispute resolution mechanisms specifically for technical barriers to trade, ensuring faster and more enforceable rulings. Additionally, the organization could promote greater harmonization of standards by facilitating more inclusive and transparent negotiations that involve not only governments but also industry stakeholders and standard-setting bodies. Increasing support for capacity-building programs in developing countries would also help reduce asymmetries and foster more consistent application of technical regulations globally.
By evolving its approach to adapt to the current geopolitical landscape, the WTO can reclaim its central role in setting fair and balanced rules that minimize non-tariff barriers and foster smoother global trade flows.
Only by evolving beyond declarations and into real enforcement mechanisms can the WTO remain relevant in a world where standards shape power.
Conclusion
Technical barriers to trade have evolved from simple safety or quality checks into powerful instruments of strategic influence. Today, competition over values, technologies, and supply chains is intensifying, and standards are no longer neutral. As the world splits into competing blocs, the contest over technical standards will likely shape not only trade flows but also the future balance of global economic power.
Despite internal challenges, the EU seeks to assert itself as a regulatory superpower—not through tariffs, but by setting the rules others follow. Given that the United States and the EU share the world’s largest economic relationship, the European Union could ease technical barriers—especially those unrelated to security or health and thus open to negotiation. This would help reduce U.S. tariffs by placing these issues at the center of trade negotiations. At the same time, the United States should also pursue the reduction of both tariff and non-tariff barriers within multilateral forums such as the World Trade Organization, rather than resorting to increased tariffs. Such an approach would promote a more balanced and rules-based global trading system.
Technical standards could be the key to both lowering tariffs and transforming the global economy of tomorrow.
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