I think Search Engine Land makes a pretty appropriate comparison:

Google’s is absolutely correct and the European drive for global removal of links overreaches. Neither CNIL nor any European privacy regulator should be permitted to control what content is available outside of their immediate jurisdictions. Indeed, the EU has no legal jurisdiction over Google outside of its territorial domain.

Acceding to the French-EU position on this question would be tantamount to saying that the Chinese government should be allowed to determine how the world views the Tiananmen Square massacre and censor content not just in China but globally.