Europe is hitting the unvaccinated with fines, lockdowns, and mandates. Could America be next?

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The jury is still out in the U.S. on how to deal with Americans who are unwilling to get vaccinated, but European countries are increasingly choosing the stick over the carrot as governments across the continent turn to hard-line methods from lockdowns to fines in order to coax the unvaccinated to take the jab.

The message: Get vaccinated, or don’t participate in society.

European Commission President Ursula von der Leyen said today that the European Union should discuss whether EU-wide mandatory vaccinations are needed to fight spikes in COVID-19 and the new Omicron variant. “This needs discussion. This needs a common approach. But it is a discussion that I think has to be led,” von der Leyen said during a news conference.

Von der Leyen is not alone in taking the tough approach. Here is a partial list of restrictions put in place to get people across Europe vaccinated:

  • Greece is imposing a monthly fine of €100 ($114) on people over 60 who aren’t vaccinated, calling it a health fee.

  • Austria has restricted the movement of unvaccinated people in two of the hardest-hit regions, with only those vaccinated allowed to leave lockdown when restrictions end in mid-December or face a fine of up €3,600 ($4,000).

  • Germany is facing pressure to follow Austria’s example in the face of spiking cases, with its incoming chancellor Olaf Scholz throwing his support behind making COVID-19 vaccines compulsory, calling for a parliamentary vote on the plan.

  • France has mandated health workers and other civil servants be fully vaccinated, and has suspended 3,000 health workers for being unvaccinated. It also requires people to carry a kind of valid vaccine pass to get into most public places.

  • Italy has made COVID-19 vaccinations a requirement for all health care workers, and there is a rising debate over extending this to other groups. Italy was the first European country to mandate that workers present a “green pass,” or proof of vaccination or a clean bill of health before entering a workplace. The unvaccinated must get tested every 48 hours to participate in just about every facet of public life, a personal expense that quickly builds up.

  • The United Kingdom, no longer part of the EU, is taking a more relaxed approach, requiring all National Health Service workers to be jabbed by next spring.

Breeding mistrust

Europe has often made COVID-19 moves before the U.S., and some analysts expect these measures to migrate across the Atlantic—against the wishes of Republicans and many business trade groups. The Biden administration’s current plan is to get U.S. companies with 100 workers or more to vaccinate staff or bring in regular testing, a proposal that’s hung up in the courts.

A big roadblock to expanded mandates is the uncertainty factor. Although some countries are moving ahead with vaccine mandates, public health experts have yet to determine whether they actually work. “The problem with mandatory vaccination is that it doesn’t necessarily fix the low uptake issues,” said Peter English, past chair of the British Medical Association Public Health Medicine Committee. “It is hard to enforce. How do you, in practice, vaccinate somebody who refuses consent?”

He notes there is the possibility that the public reaction to enforcing vaccination might drive up distrust in the vaccine, increase dissent and protest, and subsequently drive down vaccination uptake.

Commenting on the Austria vaccine mandate, Thomas Czypionka, head of health economics and policy at the Institute for Advanced Studies in Vienna, told Time, “It deepens the chasm in our society.”

Regardless of chasms, the prospect of the vaccine mandate has successfully increased vaccination rates in Austria already.

In the U.S., there is immense pushback against a government-backed vaccine mandate. This week, District Judge Terry Doughty in Monroe, La., blocked the Centers for Medicare & Medicaid Services (CMS) from enforcing vaccine mandates among health care workers until legal challenges are resolved. And in some states, Americans are using religious exemptions to find a loophole in mandatory vaccination laws.

Even if there is pushback against a government-enforced mandate in the U.S., this won't stop private employers from requiring vaccines for work. In a survey conducted in mid-November by advisory firm Willis Tower Watson, a majority of U.S. employers already have or will require their employees to get vaccinated against COVID-19.

This story was originally featured on Fortune.com