U.S. Gun Policy: Global Comparisons

Introduction

The debate over gun control in the United States has waxed and waned over the years, stirred by frequent mass shootings in civilian settings. Gun violence is the leading cause of death for children and young adults in the United States. In particular, the ready availability of assault weapons and ammunition has provoked national discussion after multiple mass shootings of school children, most recently in Uvalde, Texas. However, Congress has repeatedly been unable to pass meaningful gun legislation in the wake of these tragedies despite broad public support for new restrictions.

Recent years have seen some of the worst gun violence in U.S. history. In 2021, guns killed more than forty-five thousand Americans, the highest toll in decades; and the upward trend is on track to continue.

Many gun control advocates say the United States should look to the experiences of wealthy democratic peers that have instituted tighter restrictions to curb gun violence.

United States

Gun ownership in the United States is rooted in the Second Amendment of the Constitution: “A well-regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.”

The United States, with less than 5 percent of the world’s population, has 46 percent of the world’s civilian-owned guns, according to the most recent report by the Switzerland-based Small Arms Survey (2018). It ranks number one in firearms per capita. The United States also has the highest homicide-by-firearm rate of the world’s most-developed nations. Many gun rights proponents say these statistics do not indicate a causal relationship.

However, the right to bear arms is not unlimited. The U.S. Congress and state legislatures have authority to enact controlling legislation, and the U.S. Supreme Court has upheld some firearms restrictions, such as bans on concealed weapons and on the possession of certain types of weapons, as well as prohibitions on the sale of guns to certain categories of people. The Gun Control Act of 1968 prohibits individuals under eighteen years of age, convicted criminals, the mentally disabled, dishonorably discharged military personnel, and others from purchasing firearms. In 1993, the Brady Handgun Violence Prevention Act mandated background checks for all unlicensed individuals purchasing a firearm from a federally authorized dealer.

But some gun laws have not survived judicial review. For instance, in 2008, the Supreme Court struck down a Washington, DC, law that banned handguns, the court’s first ruling on the Second Amendment in nearly seventy years.

Federal law provides the basis for firearms regulation in the United States, but states and cities can impose further restrictions. Some studies have indicated that states with more restrictive gun laws, such as California or Hawaii, have lower incidences of gun deaths, although researchers say more analysis is needed.

In recent years, Congress has debated changes to existing gun laws, typically in the immediate aftermath of a high-profile mass shooting, such as that in Las Vegas in 2017 (sixty people killed), or in Parkland, Florida, in 2018 (seventeen killed). But in almost every instance, legislation has failed to garner enough support. Ill-fated bills have proposed measures including an assault weapons ban, expanded background checks, and a prohibition on firearm sales to people on federal terrorism watch lists.

As of mid-2022, there were no federal laws banning semiautomatic assault weapons, military-style .50 caliber rifles, handguns, or large-capacity magazines. There was also no federal requirement for those purchasing a gun to have any firearm safety training. There was a federal prohibition on assault weapons and on large-capacity magazines between 1994 and 2004, but Congress allowed these restrictions to expire.

Meanwhile, gun violence has surged amid the COVID-19 pandemic. As of June 2022, guns have killed some nineteen thousand people in the United States this year. The majority of those were in acts of suicide. Mass shootings—those with at least four victims—were occurring at a rate of at least one per day.

Canada

Gun ownership is also relatively high in Canada, at about thirty-five firearms per hundred residents (ranking fifth globally), but the country does not struggle with a similar level of gun violence. As in the United States, Canada’s national government sets gun restrictions that the provinces, territories, and municipalities can supplement. And like its southern neighbor, Canada’s gun laws have often been prompted by gun violence. In 1989, a student armed with a semiautomatic rifle killed fourteen students and injured more than a dozen others at a Montreal engineering school. The incident is widely credited with driving major gun reforms that imposed a twenty-eight-day waiting period for purchases; mandatory safety training courses; more detailed background checks; bans on large-capacity magazines; and bans or greater restrictions on military-style firearms and ammunition.

Firearms in Canada are divided into three classes: nonrestricted weapons, such as ordinary rifles and shotguns; restricted, such as handguns and semiautomatic rifles or shotguns; and prohibited, such as automatic weapons. It is illegal to own a fully automatic weapon unless it was registered before 1978.

Changes to the law in 1995 required individuals to obtain a license to buy guns and ammunition, as well as register all firearms. However, in 2012, the requirement to register nonrestricted guns was dropped, and related public records were expunged. Following another mass shooting, at a Quebec City mosque in 2017, the government passed a bill to again require nonrestricted firearms to be registered and allow background checks to consider events from more than five years in the past. In 2020, after a gunman killed twenty-two people in Canada’s deadliest mass shooting, Prime Minister Justin Trudeau announced a ban on “assault-style” firearms.. The legislation also required those who owned now-prohibited firearms to either participate in a buyback program or comply with a strict storage regime.

Australia

The inflection point for modern gun control in Australia was the Port Arthur massacre of 1996, when a young man killed thirty-five people and wounded nearly two dozen others. The rampage, perpetrated with a semiautomatic rifle, was the worst mass shooting in the nation’s history. Less than two weeks later, the conservative-led national government pushed through fundamental changes to the country’s gun laws in cooperation with the various states and territories, which regulate firearms.

The National Agreement on Firearms [PDF] all but prohibited automatic and semiautomatic assault rifles, mandated licensing and registration, and instituted a temporary gun buyback program that took some 650,000 assault weapons (about one-sixth of the national stock) out of public circulation. Among other things, the law also required licensees to demonstrate a “genuine need” for a particular type of gun and take a firearm safety course. After another high-profile shooting, in Melbourne in 2002, Australia’s handgun laws were tightened as well. Many analysts said these measures were highly effective, citing declines in gun-death rates and gun-related mass killings.

Following an uptick in gun sales in 2017, however, Australian gun control advocates warned against the easing of gun laws in some states and territories. The gun safety discussion was also influenced by the suspected murder-suicide of a family of seven in Western Australia, the country’s worst mass shooting in two decades. Today, Australia has more guns in circulation than before the Port Arthur massacre, although the number of people who own them has fallen over the same period.

Israel

Military service is compulsory in Israel, and guns are a part of many Israelis’ daily lives. Much of the population has indirect access to an assault weapon by either being a soldier or a reservist or a relative of one. By law, most eighteen-year-olds are drafted into the military, psychologically screened, and provided at least some weapons training after high school. After serving typically two or three years in the armed forces, however, most Israelis are discharged and subject to civilian gun laws.

The country has relatively strict gun regulations, including an assault-weapons ban, a requirement to register ownership with the government, and a limit of one gun per owner. To obtain a gun license, an applicant must be an Israeli citizen or permanent resident; speak at least some Hebrew, Israel’s official language; and pass a health screening. The minimum-age requirements vary: twenty-seven years old for citizens with no military or national-service experience, twenty-one for those who have served, and forty-five for permanent residents who are not citizens. Applicants must also show genuine cause to carry a firearm, such as self-defense or hunting.

United Kingdom

Modern gun control efforts in the United Kingdom (UK) have also been precipitated by extraordinary acts of violence that sparked public outrage. In 1987, a lone gunman armed with two semiautomatic rifles and a handgun went on a six-hour shooting spree roughly seventy miles west of London, killing more than a dozen people and then himself. In the wake of the incident, known as the Hungerford massacre, Britain introduced the Firearms (Amendment) Act, which expanded the list of banned weapons, including certain semiautomatic rifles, and increased registration requirements for other weapons.

A gun-related tragedy in the Scottish town of Dunblane in 1996 prompted Britain’s strictest gun laws yet. A man armed with four handguns shot and killed sixteen schoolchildren and one adult before committing suicide in the country’s worst mass shooting to date. The incident sparked a public campaign known as the Snowdrop Petition, which helped drive legislation banning handguns, with few exceptions. The government also instituted a temporary gun buyback program, which many credit with taking tens of thousands of illegal or unwanted guns out of supply. 

A large majority of police officers in the UK do not carry firearms, setting them apart from counterparts in the United States and other countries. Guns are limited to specially trained police units that respond to particular emergencies or deploy for certain types of operations. Supporters of the policy say the unarmed officer symbolizes policing of the public by consent as opposed to by force.

Norway

Gun control had rarely been much of a political issue in Norway—where gun laws are viewed as tough, but ownership rates are high—until a right-wing extremist killed seventy-seven people in attacks in Oslo and at an island summer camp in 2011. Though Norway ranks fourteenth worldwide in gun ownership, according to Small Arms Survey, it placed near the bottom in gun homicide rates. (The U.S. rate is roughly forty-four times higher.) Most Norwegian police, like the British, do not carry firearms.

In the wake of the tragedy, some analysts in the United States cited the rampage as proof that strict gun laws—which in Norway include requiring applicants to be at least eighteen years of age, specify a “valid reason” for gun ownership, and obtain a government license—are ineffective. Other gun control critics have argued that had other Norwegians, including the police, been armed, the gunman might have been stopped earlier and killed fewer victims. 

After the massacre, an independent commission recommended tightening Norway’s gun restrictions in various ways, including by prohibiting pistols and semiautomatic weapons, but changes were not made. In 2018, the Norwegian parliament approved a ban on semiautomatic firearms, which took effect in 2021.

Japan

Gun control advocates regularly cite Japan’s highly restrictive firearm regulations in tandem with its extraordinarily low gun death rate. Most years, fewer than one hundred Japanese die from gun violence in a country of 125 million people. Most guns are illegal in the country and ownership rates, which are quite low, reflect this.

Under Japan’s firearm and sword law [PDF], the only guns permitted are shotguns, air guns, guns with specific research or industrial purposes, or those used for competitions. However, before access to these specialty weapons is granted, one must obtain formal instruction and pass a battery of written, mental, and drug tests and a rigorous background check. Furthermore, owners must inform the authorities of how their weapons and ammunition are stored and provide their firearms for annual inspection.

Some analysts link Japan’s aversion to firearms with its demilitarization in the aftermath of World War II. Others say that because the overall crime rate in the country is so low, most Japanese see no need for firearms.