Green by choice? Cross-national variations in firms' responses to EMS-based environmental regimes

Firm-level EMS adoption patterns in the United Kingdom, Germany, and the Un ited States vary, thereby suggesting that national contexts influence firms ' responses to them. In Germany and the U.K. a significant number of sites have become either ISO 14001 or EMAS certified, while the take-up of ISO 14 001 in the U.S. (EMAS is available only to European sites) has been less en thusiastic. This article begins with the hypothesis that firms in countries with advers arial economies- where regulators and business are on less than friendly te rms-are less likely to adopt EMS-based programs. This hypothesis explains w hy Iso 14001 take-up has been relatively high in the U.K. and relatively lo w in the U.S. However, it cannot explain (1) the high rate of take-up of bo th Iso 14001 and EMAS in Germany, where the stringency of environmental leg islation has been a contentious issue between the government and industry a nd (2) why EMAS has been more popular in Germany than in the U.K. This arti cle argues that the original hypothesis, while largely correct, is underspe cified. To better explain the cross-national differences in EMS adoption, o ne must take into account the type of adversarial economy (adversarial lega lism versus prescriptive Interventionism) and the nature of the policy regi me (procedural versus substantive).