Regulatory Divergence in Autonomous Vehicle Deployment A Comparative Study of the US, EU, and China

Autonomous vehicle (AV) regulatory frameworks vary significantly across global regions, with the United States, European Union (EU), and China exemplifying distinct approaches. The US adopts a decentralized model, allowing state-level regulation with federal guidance, fostering testing and commercial deployment of Level 4 automation. The EU enforces a harmonized, safety-focused framework under legislation like Regulation (EU) 2019/2144 and (EU) 2022/1426, emphasizing structured validation within defined operational domains. China employs a centralized regulatory hierarchy, integrating national standards with localized pilot programs and connected infrastructure. While the US leads in commercial deployment and China advances through coordinated efforts, the EU’s cautious framework is often perceived as a barrier to rapid AV adoption. This paper critically analyzes these regulatory models, emphasizing the need for a robust, harmonized framework that ensures safety and public trust without imposing unnecessary barriers by evaluating the current landscape and future perspectives for effective AV adoption.