The ongoing globalization of the economy and the entanglement of the economies of the EU Member States increasingly make comparisons between the labour law systems in Europe necessary. This book aims to provide a key to such comparative research.
The author, Prof. Antoine Jacobs, is emeritus professor in labour law, social insurance law and social politics at Tilburg University, the Netherlands, where he still teaches a course in Comparative Labour Law.
The aim of this coursebook is to present a satellite view on labour law in Europe, notably of the Member States of the European Union (EU) and the United Kingdom. In the United States the most important labour laws have an all USAcharacter. New York, California, Florida etc. have their own labour laws. However, the basic labour and social security law is overwhelmingly uniform from the Atlantic to the Pacific coast. Things are different in Europe. Presumably at least 80% of labour law in Europe is determined by the various States. As a consequence there are still numerous differences between the labour laws of the various countries in Europe. And it is bound to stay so for several more decades, as the EU does not have the ambition to bring about full scale harmonization of labour law in its Member States. However, I believe that – even if harmonization of labour law is not the deliberate objective of the EU – the legal systems of the European countries are in fact getting closer to each other. The countries are looking beyond their national fences and they are often voluntarily adapting their systems to those of their neighboring countries. It is therefore tempting and challenging to study the labour law of the countries in Europe from a comparative perspective.
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