The problem is they're both doing it wrong. The way you protect consumers is with a competitive market and a low rate of fraud. So the government is primarily responsible for preventing market consolidation and prosecuting fraud.
The problem in the US is that they don't do either of those things well and then you get consolidated markets that are insulated from competition or competitive markets where fraud is rampant, and the latter tend to become the former because a high rate of fraud causes people to turn to major brands to protect themselves until the market consolidates.
The problem in Europe is that they not only don't prevent market consolidation, they pass rules that make it worse. You don't need to micromanage how stuff is made or how people interact with each other as long as you have competitive markets and informed consumers, because then people just don't patronize abusive businesses because they both have alternatives and know about them. But if you do micromanage everything then compliance costs go up, which are fixed costs that increase barriers to entry into the market, which reduces competition and then you're screwed again. The best case there is cost disease where everything costs an order of magnitude more than it should because everyone is paying for an army of bureaucrats to check boxes, but even more common is that you get that and abusive cartels that take advantage of consumers in every way that hasn't already been regulated. Which becomes a vicious cycle where more abuses lead to more regulations which lead to higher costs and even more market consolidation.
The problem in the US is that they don't do either of those things well and then you get consolidated markets that are insulated from competition or competitive markets where fraud is rampant, and the latter tend to become the former because a high rate of fraud causes people to turn to major brands to protect themselves until the market consolidates.
The problem in Europe is that they not only don't prevent market consolidation, they pass rules that make it worse. You don't need to micromanage how stuff is made or how people interact with each other as long as you have competitive markets and informed consumers, because then people just don't patronize abusive businesses because they both have alternatives and know about them. But if you do micromanage everything then compliance costs go up, which are fixed costs that increase barriers to entry into the market, which reduces competition and then you're screwed again. The best case there is cost disease where everything costs an order of magnitude more than it should because everyone is paying for an army of bureaucrats to check boxes, but even more common is that you get that and abusive cartels that take advantage of consumers in every way that hasn't already been regulated. Which becomes a vicious cycle where more abuses lead to more regulations which lead to higher costs and even more market consolidation.