Backgrounder

U.S. Gun Policy: Global Comparisons

Amid the COVID-19 pandemic, 2021 is on track to be the United States’ deadliest year for gun violence in two decades. How do other countries regulate firearms and respond to mass shootings?
A gun enthusiast looks at a rifle scope during a 2019 National Rifle Association annual convention.
A gun enthusiast looks at a rifle scope during a 2019 National Rifle Association annual convention. Scott Olson/Getty Images
Summary
  • The debate over U.S. gun laws has raged for decades, often reigniting after a high-profile mass shooting. Gun violence has surged in 2020 and 2021 amid the COVID-19 pandemic.
  • Gun ownership and gun homicide rates are high in the United States in comparison to rates in other advanced democracies.
  • Mass shootings in Australia, Canada, and the United Kingdom prompted those governments to tighten gun laws.

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. In particular, the killing of twenty schoolchildren in Newtown, Connecticut, in 2012 reignited a national discussion about gun laws. However, legislation that would have banned semiautomatic weapons was defeated in the Senate despite extensive public support.

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Recent years have seen some of the worst gun violence in U.S. history. In 2020, nearly twenty thousand Americans lost their lives to guns, the highest toll in more than two decades; and the trend looks likely to continue through 2021. 

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Australia

Many gun control advocates say the United States should look to the experiences of its 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 a 2018 report by the Switzerland-based Small Arms Survey. 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. But many gun rights proponents say these statistics do not indicate a causal relationship. 

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However, the right to bear arms is not unlimited. 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 against 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.

At the same time, the U.S. Supreme Court has rolled back certain gun laws. In 2008, the court struck down a Washington, DC, law that banned handguns.

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Federal law provides the basis for firearm regulation in the United States, but states and cities can impose further restrictions. Some states, such as Alaska, Idaho, and Kansas, have passed various laws attempting to nullify federal gun legislation, but legal analysts say these are unconstitutional. 

In 2016, President Barack Obama took several actions in response to the San Bernardino shooting that were intended to decrease gun violence, including a measure requiring dealers of firearms at gun shows or online to obtain federal licenses and conduct background checks.

In 2017, President Donald Trump responded to a pair of mass shootings—in Las Vegas and Parkland, Florida—by imposing a regulatory ban on so-called bump stocks, devices that allow semiautomatic guns to fire at a rate approaching that of automatic weapons. However, a federal court put the ban on hold in March 2021, ruling that bump stocks do not qualify as machine guns under the law. But Trump also supported some measures that eased gun restrictions, including a bill that rolled back an Obama-era regulation that made it harder for people with mental illnesses to purchase guns.

As of 2021, there were no federal laws banning semiautomatic assault weapons, military-style .50 caliber rifles, handguns, or large-capacity magazines. There was a federal prohibition on assault weapons and large-capacity magazines between 1994 and 2004, but Congress allowed these restrictions to expire. 

Mass killings have surged amid the COVID-19 pandemic. As of July, more than eight thousand people were killed in shootings in 2021. That’s approximately fifty-four lives lost per day, which is fourteen more than the daily average of the previous six years.

Canada

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 driven 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 in modern history, Prime Minister Justin Trudeau announced a ban on “assault-style” firearms—a demand gun control activists had been pushing for decades. 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 everyday life. 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, 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 and a requirement to register ownership with the government. To obtain a gun license, an applicant must be an Israeli citizen or permanent resident and speak at least some Hebrew, Israel’s official language, among other qualifications. The minimum-age requirements vary: twenty-seven 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 have been precipitated by extraordinary acts of violence that sparked public outrage and, eventually, political action. 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.

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 the 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. “Those who are willing to break the laws against murder do not care about the regulation of firearms, and will get a hold of weapons whether doing so is legal or not,” wrote Charles C. W. Cooke in National Review. 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 a number of ways, including prohibiting pistols and semiautomatic weapons, but changes were not made. In 2018, the Norwegian parliament approved a ban on semiautomatic firearms, which is expected to take effect in 2021.

Japan

Gun control advocates regularly cite Japan’s highly restrictive firearm regulations in tandem with its extraordinarily low gun homicide rate, which is among the lowest in the world at just one death in 2017, the latest year for which data is available. Most guns are illegal in the country and ownership rates, which are quite small, 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.

Recommended Resources

This Backgrounder explores how U.S. policing compares with that of other advanced democracies.

The New York Times Magazine profiles the National Rifle Association, perhaps the most powerful lobby in the United States.

The Brookings Institution investigates the spike in firearm sales in the United States at the onset of the COVID-19 pandemic.

The Christian Science Monitor highlights the life-and-death stakes of living in a more heavily armed America.

This Vox interactive maps out the more than two thousand mass shootings in the United States since the Newtown massacre.

Alice Hickson and Andrew Chatzky contributed to this Backgrounder.

For media inquiries on this topic, please reach out to [email protected].
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