Abstract
Students of comparative politics have highlighted different styles of regulation in the U.S. and Europe. These differences also apply to consumer policy and its different models of governance. The paper holds that governance is a key variable but adds aspects of issue framing. Two examples of consumer policy are analysed: regulation of genetically modified organisms and tobacco control. The case studies show that features of governance such as adversarial legalism or the precautionary principle are not necessarily linked to distinctive styles of regulation. Instead they vary across policy fields. Only a mix of governance elements and framing opportunities for interest groups can explain output and new directions of consumer policy. Dilemmas of collective action appear to be shrinking for consumers because framing trumps mobilization of members.
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