ABSTRACT
Globalisation of the economy has accelerated the emergence of new regionalism, which takes the form of new transborder regional systems. While these are mostly sites for regional economic liberalisation, the European Union and the North American Free Trade Agreement (NAFTA) stand out as the first to incorporate a labour relations element. Comparisons of European and North American transnationalism in the area of labour policy are difficult given the very different natures of these two exemplars of new regionalism. But in labour matters, the initial transnational regimes are actually surprisingly similar. This chapter will outline how, from a like starting point – strong transnational coordination on liberalised markets alongside national labour policy independence with pledges to harmonise upwards on worker rights and workplace standards – the labour dimensions of the European Union and NAFTA evolved in very different directions. Europe’s social dimension has been fully institutionalised, through hard law directives and regulations as well as soft law framework agreements and national policies and practices wrought by empowered social partners. While more recent, the North American Agreement on Labor Cooperation (NAALC) features limited institutionalisation via either formal legal and regulatory mechanisms or informal social networks; the NAALC is a limited mechanism for addressing labour concerns respecting continental economic integration.1
