Good luck on the comparison…there have been a number of discussions over the years on the differences between the FAA system and other regulatory systems…some good…some bad. It mainly boils down to where you are in the food chain in either system and how the system works for you.
While the A&P certificate does provide a carte blanche authorization in one respect…there are a number of defined performance requirements and experience minimums before you can use it to sign off something. A new A&P straight out of school...or an "old" opinionated one...has to satisfy one of 3 basic experience requirements before signing a job: been previously instructed on the job, work under supervision of A&P who has done it, or by a method acceptable to the Administrator (FAA). So its not a true “blank check” sign off on anything and everything.
Also instead of “type ratings” like pilots have, the FAA system is driven by type of maintenance performed. In its most basic form by Airframe and/or Powerplant (A&P)…then whether work performed is a major or minor repair /alteration/inspection (IA)…then by ops type Part 91, 121, 125, 129, 135, 145etc.
Now as you move up the food chain of operations types (Part 121, 135, 145) then you start to see requirements for specific qualifications like factory schooling on specific models, minimum times of performing jobs before qualification, etc. These requirements are dictated by the operator’s manual through the FAA approved Air Carrier Certificate and Ops Specs. So while there is not a defined “type rating” at the basic mechanic level…like EASA system…there is a similar structured system of specific “type ratings” or qualifications farther down the line.
Final note on Repairman…normally an A&P provides a much greater level of privileges than a Repairman Certificate…but there are exceptions…Repairman with rated RS can certify a transponder but a straight A&P can’t…etc.
w1