European labour law is becoming increasingly complex, though there has been little harmonisation of collective labour law so far, and legal systems continue to differ significantly from each other. The terms ‘collective agreement’, ‘industrial action’, ‘workers’ representation’ and ‘workers’ participation’ refer to different legal concepts in the various EU Member States. In his comprehensive analysis, Robert Rebhahn explains and compares these concepts, their differences and similarities, and contrasts them with the respective concepts in the US.
The only field of European collective labour law where harmonisation has taken place so far is information and consultation of workers. Besides a number of specific information and consultation rights laid down in several directives, Directive 2002/14/EC establishes a general framework for informing and consulting employees. It may be assumed that its implementation will bring about fundamental changes in employment relations of those Member States that do not as yet provide a general system of information and consultation, i.e. the United Kingdom and Ireland. In her article Pascale Lorber discusses this assumption in relation to the UK.
International Journal of Comparative Labour Law and Industrial Relations