Alot harder. Its a completely different approach to flying. The FAA system is practical and approaches subjects with common sense so it will be easy for the unfamiliar student to learn it. The JAA system, at least at the ATP level, is alot more theorethical, but doesnt explain things at a basic level. If you allready have a degree in something technical, you might just love it, but many people find it hard and even have difficulties passing the written exams (14 in total) not because they are not knowledgable, but because the questions are written with intent to trick the student, and asks about unimportant details no american pilot would ever even have to care about. The FAA really tries to keep things as little beuracratic as possible, but the JAA is opposite: the worst they can do it, the better they feel. It has something to do with the influence of the french people, I'm lead to believe.