ABSTRACT
In September 1996 the transposition of the Directive on the Establishment of European Works Councils (EWCs) took place-in theory simultaneouslyin all seventeen countries subject to its requirements. In addition to the fourteen EU member states, with the UK excluded under its opt-out from the Agreement on Social Policy, the Directive also embraces the three states which make up the European Economic Area (EEA; Iceland, Liechtenstein and Norway). At the time at which the Directive was transposed into national law, around 420 agreements had been concluded on a voluntary basis between managements and employee representatives, including trade unions.
