This article examines labour protection in the US and EU FTAs. It shows that the US and the EU have different approaches to labour issues in FTAs, which can be measured in three main aspects: (i) scope of labour commitments; (ii) institutional arrangements for implementation and (iii) enforcement mechanisms. While the interests of state actors are different, social partners have the same preferences toward labour protection through trade in the US and the EU. However, this research finds that trade unions in the US have been more influential than those in the EU. The findings of this research show the different linkages, interactions, and influence of social partners on state actors when developing labour provisions in US and EU FTAs.

GEG WP 2017/133