The Mexico-produced Nissan March compact sold in Latin America received a two-star rating from Latin NCAP, while the version sold for about the same price in Europe, called the Micra, scored four stars. The crash tests found the Latin American model had a weak, unstable body structure that offered occupants little protection in even non-serious wrecks.

In an emailed statement, Nissan said the March sold in Brazil is "practically the same model" offered in Europe. "The difference in the results achieved in Europe and Latin America is due to variations in the NCAP tests applied in different parts of the world."

Not so, said Alejandro Furas, technical director for the Global NCAP crash test programs.

"We perform the frontal crash test exactly in the same way as the Euro NCAP," he said. "The March and Micra were tested in the same lab, with the same type of crash test dummies, under the same conditions with the same people running the laboratory."

The Euro NCAP tests are more complete. They include side-impact and other tests, while the Latin American version only records front-impacts. Each type of impact test is individually scored on a 16-point scale.

The March sold in Brazil obtained a 7.62 rating in its frontal-impact test. The Micra fared much better, 12.7 points.

Italian automaker Fiat said in an emailed statement that "in general, Brazilian projects receive more reinforcements" within the cars' bodies to fortify them against the nation's "harsher roads and terrain."

However, NCAP tests found that Fiat's best-selling car in Brazil, called the Novo Uno, had an unstable body structure and scored it just one star.

Crash-test footage shows the front of the car folding up like an accordion, giving it a 2.0 point rating, the second lowest of the 28 cars NCAP has examined. Consumers purchased nearly 256,000 Novo Uno's last year — the second-most popular car in the country.

Renault's safety standards also vary. The French company builds its Sandero in Brazil, selling 98,400 cars last year. That car scored one star on the Latin NCAP test, but the model sold in Europe, made by Renault's Romanian subsidiary Dacia, scored three stars.

Renault said the safety record of the Sandero and its other cars were on par with autos of the same class in Brazil.

One of those is the VW Gol, Brazil's best-selling car for the last decade.

Volkswagen said it strives to maintain a global standard for body strength, putting the same number of welds on the same models regardless of where they're produced, and using high-strength steel in Brazilian cars. It added that since 1998 it's given Brazilian consumers the option of buying a car with air bags — its Gol Trend model with two frontal air bags scored three stars, while the same model without air bags scored one star.

The company didn't respond to requests for figures on how many consumers requested air bags.

"Structural integrity during a crash is a global standard for Volkswagen," the company said in an emailed statement. "The passenger compartment for the Gol remained stable and thus guarantees survival space for occupants."

Latin NCAP has tested three VW models. The Gol and the Polo had stable bodies. The Bora sedan, however, was rated as unstable, though other factors helped it score three stars.

And then there are the cars the companies do not market outside Latin America, such as the Celta by GM. Celta is Brazil's No. 5 car in terms of sales, with 137,615 sold last year. It received one star after its door unhinged and the passenger cabin roof bent into an inverted V shape during its crash test.

General Motors had no comment other than to say that its cars in Brazil are legal.

An engineer for a major U.S. automaker, speaking only on condition of anonymity for fear of losing his job, said he has watched for years as his company failed to implement more advanced safety features in Brazil, simply because the law did not require them.

""The automakers are pleased to make more profitable cars for countries where the demands, whatever they may be, are less rigorous," he said. "It happens everywhere — India, China and Russia, for example."

About 40 million Brazilians moved into the middle class during the past decade with more income than ever to buy their first car. The growth potential is enormous: One out of every seven Brazilians owns a car, while the U.S. vehicle fleet covers nearly every American.

But as auto sales boom in Brazil, so have the number of accidents and deaths.

An analysis of Health Ministry data shows that 9,059 car occupants died in vehicle crashes in Brazil in 2010, according to the most recent statistics available. That same year, 12,435 people in the U.S. were killed in car crashes, though the U.S. passenger car fleet is five times larger than Brazil's. The result: Brazilian automobile crash victims died at four times the rate as those in the U.S.

The dangers come down to basics, engineers said: the lack of body reinforcements, lower-quality steel in car bodies, weaker or fewer weld spots to hold the vehicles together and car platforms designed decades before modern safety advances.

"The electricity used in building a car is about 20 percent of the cost of the structure," said Marcilio Alves, an engineering professor at Brazil's premier University of Sao Paulo and one of the few independent researchers in the nation looking at car safety.

"If you save on electricity, you save on cost. One way to save electricity is either reducing the number of spot welds or using less energy for each spot weld made. This affects structural performance in the event of a crash."

In a car with no air bags and an unstable body structure, a driver's biggest danger is the steering wheel.

A weak body structure and fragile steering column make it easier for the wheel to slam into the driver's chest and abdomen in frontal crashes, the deadliest and most common, causing serious damage to vital organs.

Ward talks of steering wheels that break off and "float" during wrecks in poorly made cars — moving around the cabin in the driver's area. That means that even if an air bag is deployed, the steering wheel may go around or under it and directly hit the driver.

Many Brazilian car bodies also don't contain crumple zones, areas that absorb energy during wrecks. The omission endangers occupants' lower limbs, as foot wells rip off and expose feet and legs to car parts slamming into them from the front.

"If a car's body cannot absorb the energy of a crash, it will logically result in more damage, more injuries to passengers," said Alves, the doctor who specializes in traffic accident victims.

One auto engineer described the situation by sketching two car body designs with identical perimeters, but one depicted internal gaps — missing body reinforcements.

He worked three decades for Volkswagen and spent the last 10 years as an independent engineering consultant for big automakers. He asked that his name not be published for fear of losing contracts and benefits.

"The secret of a car's body being able to withstand the crash test are the weld spots," he said.

"Let's say this is a German car," he pointed to the gapless sketch. "It's really sophisticated. Nothing is missing."

Then he pointed at the car made in Brazil, full of incomplete ink strokes.

"The Brazilian version looks the same from the outside, but it's missing pieces," he said. "In one version they include the reinforcement, in the other they don't. What's of interest is the final shape. What's inside, nobody can see."

What may not happen across the country next year, if Romneycare is any guide, is a dumping of insurance coverage by businesses. Fears circulated that many companies in Massachusetts would stop offering health insurance to workers starting in 2006 because of the costs. The thinking was that firms would rather pay the penalties for not offering insurance than to pay for the insurance itself.

But during the life of Romneycare, and even the year before, the percentage of firms with three or more workers that offer insurance rose from 70 percent to 76 percent, according to the Massachusetts Employer Survey.

It looks like that sentiment could repeat itself nationally. Nearly 70 percent of benefits professionals said in a poll that their companies "definitely will" keep offering coverage to full-time workers next year, according to a recent survey from the International Foundation of Employee Benefit Plans.

(Read more: When It Comes to Health-Care Reform, the IRS Rules)

Another reflection of the future from Romneycare —and not for the best—is what's happening to small businesses.

Health insurance premiums went up by double-digit percentage points for small business policies in the state for four out of the first five years of the reform law, according to the Retailers Association of Massachusetts. Some of that is a result of rising health care costs, but some is also from additional coverage—such as mental health—that businesses must offer under both reform laws.

Adding to the problem for small businesses in Massachusetts was that many did not take part in an insurance exchange set up to help lower costs. The exchange was halted after a year due to a lack of participation.

The Retailers Association of Massachusetts say that costs under Obamacare—which exempts businesses with less than 50 workers from the mandate, while it's 11 in Massachusetts—could rise in the double digits again in the state next year.

State health insurance exchanges set up through Obamacare, which are either run by the states or the federal government starting this October, are supposed to help reduce costs. Analysts aren't so sure.

"I would say that both plans don't really focus enough on reducing health care costs," said Peter Marathas, a health and benefits lawyer in the Boston office of Proskauer.

"Since Romneycare, costs for employers have gone up at least five percentage points over the national average," Marathas said. "There's administrative costs, premium costs, and it all ads up. We really need to focus on that, and these laws don't in my opinion."

Romneycare was expected to prevent businesses, especially smaller ones, from hiring more workers as they attempted to avoid going over the 11-person limit and being penalized if they didn't offer health insurance coverage. Those fears exist with Obamacare as well.

But a study last year by the Urban Institute said that Romneycare did not result in any significant job decreases, and that any job hiring freeze was due more to the troubled economy. Going forward, things might not be so clear cut.

"We have heard reports from across the retail community, including our restaurant members, that the penalty mandates are affecting expansion, franchising and hiring decisions today," said Neil Trautwein, vice president and employee benefits policy counsel of the National Retail Federation, in congressional testimony about Obamacare in 2011. The Congressional Budget Office estimated in 2011 that employers will create 800,000 fewer jobs by 2021 as a result of the law's policies.