The U.S. was shaken by the deadliest school shooting in nearly a decade when, on May 24, an 18-year-old gunman walked into an elementary school in Uvalde, Texas, and killed 19 children and two teachers with an AR-15-style rifle.
The tragedy has reignited fervent gun control debates across the nation, particularly in relation to the availability of semi-automatic assault weapons, which have been involved in the majority of mass shootings in the U.S. in recent years.
“As a nation, we have to ask—when in God’s name are we going to stand up to the gun lobby?” U.S. President Joe Biden said in emotive remarks following the shooting.
Although mass shootings are not unique to the U.S., the country has the highest rate of gun deaths among rich countries—more than eight times higher than Canada and nearly 100 times higher than the U.K. The aftermath of each attack in the U.S. follows a similar trajectory: calls for greater gun control that are met with opposition from Republican lawmakers, and legislative inaction. But in a number of other countries—notably New Zealand and Norway—a single mass shooting has been enough to force widespread change.
Here, what mass shootings in other countries can teach the U.S. about gun control:
Christchurch, New Zealand
Just a week after a white supremacist shot dead 51 worshippers at two mosques in Christchurch, New Zealand, in March 2019, Prime Minister Jacinda Arden announced sweeping gun control reforms. Although there was approximately one firearm for every four people in the country at the time, guns were primarily viewed as tools, used by farmers and hunters. The Christchurch shooting made the risks clear. “In short, every semi-automatic weapon used in the terror attack on Friday will be banned in this country,” Arden said.
Gun owners had six months to sell their weapons back to the government under the new law, which cost over 100 million New Zealand dollars ($65 million). As a result, over 60,000 firearms and more than triple the number of components, including high-capacity magazines, were taken out of circulation.
In June 2020, the nation of 5 million people tightened gun laws further, introducing a new firearms registry to track the buying and selling of weapons, shorter licenses for first-time license holders, and a ban on a wider variety of guns. Only time will tell the true impact of the legislation—recorded firearm related offenses actually increased in 2020, but gun control advocates say this reflects the police taking gun crime more seriously.
New Zealand had previously considered tighter weapons restrictions in 1996, after a mass shooting in neighboring Australia that left 35 people dead pushed the government in Canberra to ban semi-automatic rifles. The idea was kicked into the long grass after pressure from powerful gun lobbies and reluctance among politicians.
In light of the Uvalde shooting in Texas, Arden expressed shock and sympathy for the victims. “When I watch from afar and see events such as this today, it’s not as a politician. I see them just as a mother,” Ardern said.
“When we saw something like that happen, everyone said never again, and so it was incumbent on us as politicians to respond to that,” she said of New Zealand’s response to the 2019 attack.
Read more: New Zealand Banned All Assault Weapons. Could That Work in America?
Gun laws were considered fairly strong in Norway—despite high ownership levels of rifles and shotguns for hunting—even before the two-stage terror attack in July 2011 that left 77 people dead. After detonating a car bomb in Oslo, killing eight people, the far-right extremist Anders Breivik posed as a police officer and headed to Utoya island, the site of a Labour Party summer youth camp. Breivik initially planned to target Gro Brundtland, a former Labour Party prime minister whom he blamed for allowing Muslims to settle in Norway, but her appearance at the event was canceled. Instead, he shot 69 people dead with a semi-automatic rifle and a Glock pistol, in the country’s deadliest domestic attack since World War II.
At the time, gun owners in Norway had to obtain a license, be over the age of 18, and provide a “valid” reason for ownership. The killer obtained his weapons legally via hunting licenses and membership to a pistol club. Some pro-gun advocates in the U.S. used the tragedy as proof that stricter gun laws were ineffective in preventing mass shootings. However, the homicide-by-firearm rate in the U.S. is currently nearly 12 times higher than in Norway—experts say that a mixture of gun controls, education, and culture contribute to the Nordic nation’s better record.
Unlike in New Zealand, a push for further gun control following the mass shooting was slow to yield legislative results. Although an independent commission recommended tightening gun ownership rules in 2011, it wasn’t until 2018 that the Norwegian parliament passed a ban on semi-automatic rifles, which took a further two years to implement. During that time, a gunman stormed a mosque and opened fire, injuring one person.
Legislative reform to gun laws became a nation-wide public issue when, in 1996, a gunman killed 16 school children and one adult in the Scottish town of Dunblane using a handgun. At the time, there were no specific regulations on handguns in the U.K., as firearms had mainly only been used on private land in the U.K. for recreational use.
Following pressure from bereaved families and the wider public, the U.K. government introduced a near total ban on handguns within a year, which was subsequently extended to cover all handguns.
Like in New Zealand, the British government initiated a gun buy-back program, which was credited with taking 20,000 weapons out of circulation. In the years following the law change in 1997, markedly lower gun deaths were recorded. The U.K. hasn’t experienced a mass shooting since Dunblane in 1996.
Port Arthur, Australia
Australia had its own reckoning with gun violence in 1996 when a gunman killed 35 people with a semi-automatic rifle in Port Arthur, Tasmania. Within two weeks, both the federal government and state legislators backed bans on semi-automatic rifles and pump-action firearms. At least 650,000 assault weapons were bought back by the government and melted into slag. Lawmakers also mandated licenses to prove a “genuine need” to own weapons, and firearm safety courses.
A subsequent mass shooting, in which the shooter killed two students using different types of handgun, at a Melbourne university in 2002 prompted further restrictions: harsher punishment for misuse of handguns, anti-trafficking laws, and restrictions on the types of handguns that can be owned by civilians. Since 1997, the proportion of Australians who hold a gun license has nearly halved, and the homicide-by-firearm rate has dropped dramatically.
The U.S. is an outlier on gun control
Mass shootings may prompt grief and anger in the U.S., but rarely result in tightened weapons restrictions at a federal level. “Other countries experience horrific, fatal mass shootings with an assault style rifle and they say, ‘Never again,’ and they mean it,” Cassandra Crifasi, deputy director of the Center for Gun Violence Solutions at Johns Hopkins University, tells TIME. “In the U.S., we say, ‘Never again.’ But then we keep doing the same thing, which is almost nothing.”
The U.S. has the highest number of guns per capita than any other country in the world. Unlike other countries with recent mass shootings, gun ownership in the U.S. is ingrained in the nation’s history, pop culture, and core identity. But the majority of Americans support at least some regulation of gun ownership—according to a Morning Consult/Politico survey taken last year, 84% of voters support universal background checks for gun purchases.
The right to bear arms is baked into the U.S. Constitution and supported by the absence of nationwide licensing mandates. However, experts argue that reform can be achieved through alternative interpretations of the Constitution which require applying the document to today’s society. Introducing restrictions and registration rules on gun ownership won’t violate the right to bear arms, but will account for the kind of powerful assault weapons which are readily available today and used by mass shooters to inflict maximum harm. “Folks wrongly interpret the Second Amendment as being that you can’t have any kind of regulation,” Crifasi says.
More specifically, Crifasi points to two key reforms that the federal government could introduce that would still uphold the constitutional right: license registration for gun ownership, and extreme risk protection orders, which allow for the temporary removal of weapons from owners in times of crisis. Some states, including Illinois and Massachusetts, have these rules already in place, but the patchwork of rules across the country means dangerous gun owners can move seamlessly from state to state.
Apart from mandating licenses, another way to regulate ownership is through advertising reforms. Military-grade weapons are marketed to the public for use in their homes, and the advent of social media means they’re reaching more people than ever. Just days after the Uvalde mass shooting, images emerged of a since-deleted Twitter ad by Daniel Defense—the company behind the weapon used by the shooter—featuring a young child holding an assault weapon.
Daniel Defense had not responded to TIME’s request for comment at the time of publication.
Cities and states in the U.S. can and do impose additional restrictions on gun ownership. For example, in response to the Sandy Hook shooting, Connecticut lawmakers voted to strengthen the state’s ban on assault weapons and prohibit the sale of high-capacity magazines. Meanwhile New York passed gun laws in response to mass shootings in other parts of the country which are known collectively as the SAFE act and include a Red Flag Law which prevents people from buying or being in possession of a gun if they have displayed signs of hurting either themselves or others.
The gridlocked nature of U.S. politics—with a system of checks and balances—in part explains the inability to tackle the issue. However, experts say that, ultimately, the reason why the U.S. has been unable to match the progress made in other countries, is the outsized influence of the gun lobby and manufacturers. “The gun lobby has put a stranglehold on some of our elected officials so that they are more beholden to gun manufacturers than to their constituents,” she says. The National Rifle Association (NRA) spends $3 million a year per year to influence gun policy.
While these dynamics still exist, reform will be limited. Mass shootings like Uvalde will be what Crifasi calls “the cost of doing business.”
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