Industrial relations in the EU, Japan and USA, 2001

This overview compares a number of key aspects of industrial relations in the EU, Japan and USA, focusing particularly on developments in 2001.

This report examines industrial relations developments in 2001 in the world's three leading economies - the European Union, Japan and the USA - with the aim of highlighting some of the main areas of difference and similarity. It looks at a number of important structures and processes and the way in which several key issues - such as pay and working time - were dealt with in 2001. The information for the EU is taken mainly from the European Industrial Relations Observatory (EIRO), while the data for Japan and the USA are taken largely from special reports on industrial relations developments in 2001 prepared for EIRO from experts in these countries - see JP0211101F and US0211101F- plus sources such as the US Bureau of Labor Statistics (BLS) and the Japan Institute of Labour (JIL). Further background information on the industrial relations systems of the EU, Japan and USA is provided in TN0111148F.

Economic and employment context

The economic and labour market setting for industrial relations differed considerably between the EU, Japan and the USA in 2001 - see table 1 below - though all three economies were affected by the worldwide economic downturn, which was exacerbated by the events of 11 September and their aftermath. The US economy had started to slow down in 2000 and GDP growth fell to 1.2% in 2001, having stood at over 4% a year since 1997. The EU economy also saw a considerable slowdown, with growth falling by around half to 1.7% in 2001, after two years of steady increase. Signs of an economic recovery in Japan during 2000 proved short-lived, with the relatively strong GDP growth of 2.4% in that year followed by a contraction of 0.5% in 2001. The EU thus had higher economic growth than both the USA and Japan in 2001, though in a context of general decline.

US inflation eased from 3.4% in 2000 to 2.8% in 2001, while the EU rate rose slightly from 2.1% to 2.3%. Continuing the trend of recent years, prices continued to fall in Japan.

Despite the growing economic problems and job losses towards the end of the year, employment levels continued to rise in the EU during 2001, albeit (at 1.2%) by less than in 2000 and slowing in latter months. After many years of growth, employment fell slightly in the USA in 2001, while a greater fall was recorded in Japan, where employment has been declining since the late 1990s. Nevertheless, EU employment rates are still some way below those in both Japan and the UK. In all three cases, male employment rates exceed female rates.

Unemployment rose in both Japan and the USA in 2001. The US unemployment rate increased to 4.8% following many years of decline, while Japan saw a continuation of a long-term upward trend. EU unemployment, by contrast, continued to fall. However, the EU unemployment rate remained about half as high again as that in both Japan and the USA.

As in 2000, the USA saw the greatest pay and productivity increases in 2001. Nominal compensation growth, at 5.2%, exceeded that in the EU by nearly two percentage points and that in Japan (which experienced a fall) by over five points. In the EU and USA, nominal compensation grew by more than in 2000, despite the economic situation. US productivity growth remained higher than that in both the EU and Japan (where productivity fell), but in all three cases the growth figures were considerably lower than in 2000. In Japan, nominal unit labour costs fell in 2001 (by 0.9%), as they had in 2000. This compared with increases of 2.8% in the EU and 3.9% in the USA - both considerably higher than in 2000.

Table 1. Economic and employment indicators, EU, Japan and USA, 2000-1
. EU Japan USA
. 2000 2001 2000 2001 2000 2001
GDP growth 3.3 1.7 2.4 -0.5 4.2 1.2
Inflation (CPI) 2.1 2.3 -0.7 -0.6 3.4 2.8
Employment rate 63.7 64.2 77.2 76.6 82.3 81.6
Employment growth 1.9 1.2 -0.2 -0.5 1.9 -0.1
Unemployment rate 8.1 7.6 4.7 5.1 4.0 4.8
Growth in nominal compensation per employee 3.0 3.3 0.4 -1.0 5.1 5.2
Labour productivity growth 1.5 0.4 2.6 -0.1 2.1 1.3
Nominal unit labour costs 1.4 2.8 -2.1 -0.9 3.0 3.9

Sources: European Commission- Employment in Europe 2002 and European Economy 2002.

Collective bargaining

The level at which collective bargaining is conducted is perhaps one of the most notable differences between most EU countries on one side, and Japan and the USA on the other.

The EU Member States have widely differing systems of collective bargaining over pay and conditions. However, despite these differences and a widely-observed trend towards the decentralisation of bargaining, most countries have relatively centralised systems, and there was little change in this area in 2001. To take the key issue of pay determination, table 2 below indicates the levels at which wage bargaining is currently conducted in the EU Member States (plus Japan and the USA).

As the table indicates, in three EU countries (Belgium, Finland and Ireland), the intersectoral level is currently the dominant wage bargaining level and in eight countries (Austria, Germany, Greece, Italy, the Netherlands, Portugal, Spain and Sweden) the sectoral level is most important, while in two countries there is no predominant bargaining level (Denmark, Luxembourg). In only France and the UK is the company the key pay bargaining level, while it is also important in Luxembourg. On issues other than pay, some matters are more likely to be determined by company bargaining in many countries, but conversely they are also liable to be dealt with at a higher level in some cases.

The situation is very different in Japan and the USA, where the predominant bargaining level for pay and all other issues is the individual company. Intersectoral or sectoral bargaining is virtually unknown (with some exceptions at industry level in the USA). Although the picture is not uniform among Member States (the UK, for example, has a highly decentralised bargaining structure), it is clear that collective bargaining is much more centralised in the EU than is the case in its two major competitors.

However it should be noted that in Japan, there is a degree of coordination on both trade union and employers' sides during the annual 'Shunto' bargaining round. The general pattern for these spring-time negotiations is that major manufacturers in leading industries such as electrical goods or cars take the lead in bargaining and are then followed by other large companies and then by small and medium-sized enterprises (SMEs). In the USA, many trade unions seek to conduct 'pattern bargaining', whereby an agreement is achieved in a particular company or companies and then extended to other firms in the sector.

It may be noted that when new Member States start to join the EU, probably from 2004, the general picture of relatively centralised bargaining may be diluted to some extent. Taking 10 candidate countries examined by recent EIRO research (TN0207104F) (Cyprus, the Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia and Slovenia), it is clear that the company is the dominant pay bargaining level in all cases apart from Slovakia, Slovenia and Cyprus. Intersectoral bargaining is absent from all countries apart from Slovenia and, to a lesser extent, Hungary and Latvia. Sectoral bargaining (in a broad sense) plays the dominant role only in Slovakia and Cyprus, is a very important bargaining level in Slovenia, and a relatively significant bargaining level in Hungary and to a lesser extent the Czech Republic. It exists in Estonia, Latvia and Poland, but is of very limited significance.

It might thus be argued that the expanded EU may be rather more similar to Japan and the USA in terms of bargaining structure than is currently the case.

Table 2. Wage bargaining levels, EU, Japan and USA
. Intersectoral level Sectoral level Company level
Austria . XXX X
Belgium XXX X X
Denmark XX XX X
Finland XXX X X
France . X XXX
Germany . XXX X
Greece X XXX X
Ireland XXX X X
Italy . XXX X
Japan . . XXX
Luxembourg . XX XX
Netherlands . XXX X
Portugal . XXX X
Spain . XXX X
Sweden . XXX X

X = existing level of wage bargaining; XX = important, but not dominant level of wage bargaining; XXX = dominant level of wage bargaining.

Source: EIRO (see TN0007402S ).

The coverage of collective bargaining – ie the proportion of workers that have their pay and conditions set, at least to some extent, by collective agreements – varies greatly in the EU, but is generally high (and relatively stable), as indicated by table 3 below (the figures are mostly taken from a recent EIRO study - TN0212102S- and are in most cases 'adjusted' rates, which exclude employees without bargaining rights, such as civil servants in some countries). At one extreme is Austria, where nearly 100% of private sector employees are covered by a system of sectoral agreements. Indeed, high bargaining coverage rates are found in most countries with a system of sectoral collective agreements, such as Denmark, France, Germany, Italy, the Netherlands, Spain and Sweden. In some cases – such as Austria, France, Germany and the Netherlands – systems of extending sectoral collective agreements to employers and employees that are not members of signatory organisations contribute to high levels of bargaining coverage. In Finland, Greece and Ireland, high levels of bargaining coverage are achieved by intersectoral agreements. At the lower end of the coverage spectrum is the UK, where bargaining occurs largely at company or lower levels – here only a little over a third of employees have their pay set by collective bargaining. On average, around 80% of the relevant workforce in the current EU Member States are covered by collective bargaining.

Direct bargaining coverage is relatively low in the company-dominated systems of Japan and the USA. The USA is very much distinguished by a division between a 'union sector', where collective bargaining determines pay and conditions, and a 'non-union sector', where management decision governs pay and conditions. The union sector covers only around 15% of the workforce. In Japan, there is a similar distinction between the 'bargaining sector' and 'non-bargaining sector', with the former covering only 21% of the labour force. However, it should be noted that the wage increases agreed in the Japanese bargaining sector have a major influence on general wage levels, both setting the market rate in the non-bargaining sector and being passed on through recommendations on the wages of public servants and through the minimum wage system.

Again it is interesting to note that the candidate countries for EU membership generally have a lower level of bargaining coverage than the current Member States, with an average rate of around 40%. There are exceptions such as Slovenia, Cyprus and Malta (and to a lesser extent Slovakia and Hungary). However, the expanded EU is likely to have lower overall levels of bargaining coverage than at present, though not approaching Japanese and US levels.

Table 3. Collective bargaining coverage, Europe, Japan and USA
Country Coverage
Austria 98%
France 90%-95%
Belgium 90%
Sweden 90%
Finland 90%
Italy 90%
Netherlands 88%
Portugal 87%
Denmark 83%
Spain 81%
Average of 13 EU Member States c. 80%
Germany 67%
Luxembourg 58%
Average of 9 candidate countries c. 40%
UK 36%
Japan 21%
USA 15%

Sources: figures for EU Member States and candidate countries – referring to various years from 1999-2002, and in some cases estimates – are in most cases as calculated by EIRO for TN0301102S and TN0207104F; figure for Japan (2001) is from JIL; figure for USA (2001) from BLS.


Figures are available from the EU and Japan for collectively agreed pay increases in 2001. According to EIRO estimates (TN0202102U), average collectively agreed pay increases across the EU stood at 3.4% in 2000, up slightly from 3.1% in 1999. There were considerable variations between Member States – from 7.5% in Ireland to 2.1% in Germany. The 3.4% increase should be compared with average EU inflation of 2.3% over the year – indicating a real pay increase of 1.1% (1.0% in 2000).

In Japan, the average pay increase resulting from the annual spring bargaining round in 2001 was 2.01%, down from 2.06% in 2000. Inflation stood at –0.6%, indicating a real collectively agreed pay increase of around 2.6%. However, it should be noted that the spring wage increases are not directly reflected in the trend in average wages.

In the USA, collective bargaining plays a far less important role in setting overall pay increases than in most EU countries or Japan. Furthermore, no statistics are available on average collectively agreed pay increases. However, BLS does provide figures on the average increase in the wages and salaries of 'union workers' in private industry. These increased by 4.4% in the year ending December 2001, up from 3.4% in 2000 (the equivalent figures for 'non-union' workers were 3.6% in 2001 and 4.0% in 2000). This indicates a real pay increase for these workers of 1.6% in 2001, given inflation of 2.8%. More broadly, all private industry wages and salaries rose by 3.8% for the year ending December 2001, compared with a 3.9% increase in 2000.

Given its negative inflation, real pay increases in 2001 thus seem to have been considerably greater in Japan than in the USA or the EU, as was the case in 2000.

Figures on changes in average earnings are available for all three cases for 2001, and probably provide a better comparative picture. In the EU (according to EIRO estimates), average earnings increased by an average of 4.5% in 2001 (an average of 12 countries), compared with 3.9% in 2000. In the USA, the median usual weekly earnings of full-time wage and salary workers in the private sector rose by 3.6% between 2000 and 2001, down from 5.4% over 1999-2000. In Japan, total cash earnings fell by 1.2% from 2000 to 2001, following an increase of 0.5% in the previous year. Again correcting for inflation, it seems that real earnings in 2001 increased by most in the EU (2.2%), followed by the USA (0.8%) and Japan (-0.6%).

Table 4. Pay developments in EU, Japan and the USA, 2000-1 (%)
. EU Japan USA
. 2000 2001 2000 2001 2000 2001
Average nominal collectively agreed pay increase 3.1 3.4 2.1 2.0 3.4 4.4*
Average real collectively agreed pay increase 1.0 1.1 2.8 2.6 0.0 1.6*
Average nominal earnings increases 3.9 4.5 0.5 -1.2 5.4 3.6
Average real earnings increases 1.8 2.2 1.2 -0.6 2.0 0.8

* Figure refers to wages and salaries of 'union workers' in private industry.

Sources: EIRO, US Department of Labor, JIL. See main text for definitions.

Minimum wages

A statutory minimum wage system underpins pay in Japan and the USA and in many EU countries (with a collectively agreed minimum wage system applying in most others - TN0208101S).

The US statutory national minimum wage has remained unchanged at USD 5.15 (EUR 5.75) per hour since 1997. Individual states often have their own statutory minimum wages, which are in some cases higher than the federal rate (the higher rate always applies). Alaska (USD 5.65), California (USD 6.75), Connecticut (USD 6.70), Delaware (USD 6.15), the District of Columbia (USD 6.15), Hawaii (USD 5.75), Maine (USD 5.75), Massachusetts (USD 6.75), Oregon (USD 6.50), Rhode Island (USD 6.15), Vermont (USD 6.25) and Washington (USD 6.90) currently have minimum wage rates higher than the federal level.

In Japan, minimum wages legislation provides for the establishment of minimum wage rates by geographical area (prefecture) and industry. In January 2002, the weighted average minimum wage by prefecture was JPY 5,292 (EUR 48.7) per day, or JPY 664 (EUR 6.11) per hour, while the weighted average minimum wage by industry was JPY 6,022 (EUR 55.4) per day.

In EU countries with a national minimum wage, increases ranged from 10.8% (UK) to 0.02% (Belgium) in 2001, and the overall average rate of increase (for nine countries) stood at 4.5% in 2000. The US federal minimum wage did not increase during 2001, while the Japanese weighted average daily minimum wage by prefecture rose by 1.5% between January 2000 and January 2002, and the weighted average daily minimum wage by industry by 1.3%.

Table 5 below provides estimated cash monthly minimum wage rates at the beginning of 2002 for the nine EU Member States with a national minimum wage system, along with the US federal minimum wage and the Japanese average prefectural wage. While these absolute values do not take into account factors such as variations in the cost of living or exchange rates, or the relationship of the minimum wage to average wages, they do suggest that there is relatively little difference between the EU average and the Japanese and US figures. However, there are EU countries with minimum wages significantly above and below the Japanese and US levels.

Table 5. National minimum wage rates, EU and USA, and average rate, Japan
Country Monthly minimum wage (EUR) (January/February 2002)
Luxembourg 1,290
Netherlands 1,207
Belgium 1,163
France 1,126
UK 1,124
Japan 1,071
Ireland 1,009
USA 951
EU average 924
Spain 516
Greece 473
Portugal 406

Note: Japanese figure calculated on basis of weighted daily average minimum wage by prefecture, assuming 22 days per month.

Source: for EU and USA - Eurostat Statistics in focus, Population and social conditions No.5/2002, 'Minimum wages in the European Union, 2002', for Japan, JIL, Labour situation in Japan 2002.

Gender pay inequality

One feature of pay which is common to the EU, Japan and USA is the gender wage differential. In the EU (plus Norway), women's earnings (based on hourly figures) were on average 79.6% of men's in 2000 (according to EIRO estimates - TN0202102U). In the USA, the equivalent figure for 2001 (based on the median usual weekly earnings of full-time wage and salary workers) was very similar, at 76%. In Japan, the figure ranged in 2000 from 64.3% for workers who are graduates of senior high schools to 75.5% for graduates of higher professional schools or junior colleges. Although the gender pay gap appears to be narrowing somewhat in Japan, the USA and most EU Member States, it remains persistent and relatively high

It seems that pay equity (and gender equality more widely) is not a central issues in collective bargaining in the EU (TN0201101S). However, a few significant collective bargaining developments occurred in 2001. Finland's 2001-2 central agreement contains an 'equality allowance' of 0.4% to be used at sector level to improve the position of women and lower-paid workers (FI0011167F). Belgium's 2001-2 intersectoral agreement obliges the social partners to take special measures to draw up gender-neutral job descriptions and task classifications (BE0101337F). In Germany, the abolition of traditional job descriptions which put 'typical female jobs' in low pay grades was raised in long-running negotiations on the modernisation of the collective framework pay agreements in the influential metalworking sector.

Outside the bargaining arena, there were a number of other equal pay developments in the EU in 2001. For example, new legislation in Denmark sought to create a higher degree of transparency in wage data, especially in the light of equal pay for women and men (DK0106123N). In Sweden, new legislation introduced a new definition of 'work of equal value' in assessing equal pay and an obligation on employers to conduct an annual wage survey (SE0102179N), while a number of Labour Court cases related to equal pay received considerable attention (SE0110101F). In the UK, a report by the Equal Opportunities Commission's Equal Pay Taskforce made a number of recommendations on how to address the country's 18% gender pay gap, including advising employers to carry out regular equal pay reviews (UK0104126F).

No legislative or collective bargaining initiatives relating specifically to gender pay equality are reported from either Japan or the USA in 2001 (both countries have equal pay legislation in place). However, in the USA, trade unions continued to campaign over the issue in 2001. According to the American Federation of Labor and Congress of Industrial Organisations (AFL-CIO), unions pursue a number of equal pay strategies. In the area of collective bargaining, they seek: pay upgrades for lower-paid and female-dominated job classifications; job reclassifications and new classifications; and pay equity studies with phased-in pay adjustments. In other areas, they: support individuals who take out individual grievances or discrimination cases, or take such action collectively (claiming a number of significant victories in court cases); and support enhanced federal and state equal pay legislation. In Japan, a major priority for trade unions in 2001 was achieving equal treatment and pay for part-time workers, a large majority of whom are women.

Working time

According to EIRO estimates (TN0103999U), the average normal weekly working hours set by collective bargaining across the EU (plus Norway) stood at 38.2 hours in 2001, virtually unchanged from the 2000 figure. Agreed normal weekly hours ranged from 40 hours in Greece to 35 hours in France, but almost all other Member States were in the 37-39 hours range. In most countries, agreed weekly hours have leveled out in recent years, with significant overall reductions rare (with the main exception being France, where bargaining prompted by legislation has cut the normal week from 39 hours to 35 in the past couple of years - ). In most EU countries, relatively high collective bargaining coverage levels mean that the average collectively agreed normal working week is probably relatively close to the actual normal working week (though this is less likely to be the case in a country such as the UK).

Figures on collectively agreed normal weekly hours are not available from Japan and the USA, but some comparisons can be made with the former. For Japan, the figure for 'average scheduled weekly working hours' was 39.2 hours for full-time workers in 2001 (one hour higher than the EU average figure), the same level as in 2000. Working time reduction was on the agenda of the Japanese social partners in 2001, with a debate on maintaining employment focusing on sharing out employment opportunities though cutting working hours ('work-sharing') (see below under 'Company restructuring').

Comparison of actual hours worked is also very difficult, owing to a lack of uniform statistics. A major problem is that in some cases national figures distinguish between full- and part-time workers and in others they do not. According to Eurostat's 2001 Labour Force Survey, the average usual weekly hours worked by full-timers stood at 40.1 (varying between 43.5 hours in the UK and 38.3 in France), compared with 40.3 in 2000. In the USA, full-time workers – defined as those working at least 35 hours per week – worked an average of 42.8 hours per week in 2001, compared with 43.3 hours per week in 2000. The Japanese figures for actual hours worked do not distinguish between full- and part-timers and are expressed in monthly, rather than weekly, terms. However, the figures indicate a slight decrease between 2000 and 2001.

Overall, it seems that there was a slight decline in the duration of weekly working time in 2001 in the EU, Japan and the USA.

Perhaps the best way of comparing working time between the EU, Japan and USA, and of assessing trends, is to look at annual working hours. The Japan Institute of Labour (JIL), based on various national figures, has produced estimates for annual total hours actually worked (by production workers in manufacturing industry) for Japan, the USA and three of the largest EU countries – France, Germany and the UK – see table 6 below.

Table 6. Annual total hours actually worked (production workers in manufacturing industry), Japan, USA, France and Germany, 1980-2000
. 1980 1990 1996 1997 1998 1999 2000
Japan 2,162 2,214 1,993 1,983 1,947 1,942 1,970
USA 1,893 1,948 1,986 2,005 1,991 1,991 1,986
France 1,759 1,683 1,679 1,677 1,672 1,650 1,589
Germany 1,719 1,598 1,517 1,517 1,525 1,525 -
UK 1,883 1,953 1,934 1,925 1,925 1,902 1,902

Source: JIL.

The table indicates that actual annual working time in Japan rose from 1980 to 1990, whereafter it declined substantially over the 1990s before rising slightly at the end of the decade. In the USA, annual hours also rose from 1980 to 1990, continued to increase until 1997, and has fallen slightly since. France and Germany both experienced an overall downward trend over the period, though levelling out over the second half of the 1990s in the case of Germany, and accelerating in France. The UK saw a rise up until 1990, followed by a slight fall since. In 2000, the USA had the highest annual hours, followed relatively closely by Japan and the UK. France and Germany were far behind.

Turning to normal annual working time, figures for average collectively agreed annual working hours are available from EIRO for eight EU countries where working time is measured on this basis, while JIL has produced figures for 'scheduled' annual working hours in Japan and the USA – see table 7 below. Allowing for differences in calculation methods, the table indicates that the differences between the EU countries, Japan and the USA are generally far less when considering normal/scheduled hours than for actual hours. This suggests that the differences between the EU, Japan and the USA lie more in the overtime and additional hours worked in the latter two cases.

Table 7. Average collectively agreed or scheduled annual working hours, EU, Japan and USA, 2000
Country Annual hours
Japan 1,795
Spain 1,762
USA 1,747
Netherlands 1,740
Italy 1,739
France* 1,735
Finland* 1,723
Average of 8 EU countries 1,721
Belgium 1,714
Denmark 1,695
Germany 1,658

* 1999 figure

Source: JIL and EIRO.

With regard to statutory working time limits, all EU Member States have a framework of legal rules on maximum working times. These should, at the least, respect the provisions of the 1993 EU Directive (93/104/EC) on certain aspects of the organisation of working time, which include a 48-hour maximum working week (on average over a reference period not exceeding four months). The EU countries divide fairly equally between those that set the statutory maximum working week at 48 hours (Denmark, France, Germany, Greece, Ireland, Italy, Luxembourg the Netherlands and the UK) and those which set it at 40 hours (Austria, Finland, Portugal, Spain and Sweden) or 39 (Belgium). In the first group of countries, the statutory maximum is far in excess of average collectively agreed weekly working hours, and of actual average weekly hours – it thus appears to operate essentially as a 'safety net'. In the second group of countries, the statutory maximum is far closer to average agreed or actual weekly hours, indicating a more active role for the law in governing working time.

In Japan, the normal working week was set at 40 hours by the Labour Standards Act in 1988 – however, as is frequently the case, extension of working hours may be specified in individual labour-management agreements, although guidelines issued by the Ministry of Health, Labour and Welfare set a maximum limit. In 2001, the average scheduled weekly working hours for full-time workers was below this 40-hour norm, at 39.2 hours. In the USA, there is no statutory maximum or normal working week as such, but employees covered by the Fair Labor Standards Act must receive overtime pay for hours worked in excess of 40 in a working week (at a rate not less than 50% over their regular rates of pay). With full-time workers working an average of 42.8 hours per week in 2001, there appears to be considerable overtime working in practice.


Another important aspect of working time is the amount of paid annual leave to which workers are entitled (a factor which obviously influences the annual duration of working time). In the EU, figures are available from EIRO for the average number of days of collective agreed annual leave for 13 countries (harmonised on the basis of a five-day working week). These indicate an average annual leave entitlement in 2001 of 25.7 days (varying from 31.5 in the Netherlands to 20 in Ireland) – a slight increase from 2000.

For Japan, figures are available from JIL on the average paid holiday entitlement, which stood at 18.0 days in 2000, up from 17.8 days in 1999. However, a notable feature of holidays in Japan (which is not known to be a major issue in the EU), is that by no means all of this leave entitlement is actually taken up. In 2000, only 49.5% of annual leave entitlement (8.9 days) was taken on average, down from 50.5% (or 9.0 days) in 1999. This rate of take-up has been decreasing as leave entitlement has increased over the past decade.

The latest figures available for the USA from BLS refer to 1997 and cover 'average vacation days' in the medium and large private sector. No overall figure is available for all workers, but separate ones for varying lengths of service. Thus, annual vacation days stood at 9.6 days at one year's service, 13.8 days at five years' service, 16.9 days at 10 years' service and 20.3 days at 20 years' service. All these figures had increased slightly over the previous decade.

All EU Member States have a statutory minimum period of paid annual leave. The countries fall into two groups – those which have a 20-day minimum entitlement (Belgium, Germany, Greece, Ireland, Italy, the Netherlands and the UK) or 22 in the case of Portugal, as laid down in the EU working time Directive, and those with a 25-day minimum entitlement (Austria, Denmark, France, Luxembourg, Spain and Sweden) or 24 in the case of Finland. The EU average is 22.3 days' leave (harmonised for a five-day week). In Japan, legislation entitles workers with at least six months' continuous service to a minimum of 10 days' paid annual leave, with the number of days increasing with the length of service. There is no statutory annual leave entitlement in the USA. The 1997 BLS statistics referred to above indicate that 89% of employees in the medium and large private sector had paid holidays in 1997 (down from 96% in 1988).

It seems clear that annual leave, both in law and in practice, is considerably higher in the EU than in either Japan and the USA, and constitutes a key factor in their different overall annual working time levels.

Finally, public holidays also have an impact on annual working time. According to research from the UK Trades Union Congress (TUC), the average number of public holidays in the EU stands at 10.8 days. This compares with 10 days in the USA and 15 in Japan (according to JIL figures). There is considerable variation within the EU, between 12-14 public holidays per year in Portugal and Spain and eight in the Netherlands and the UK.

Table 8. Annual leave and public holidays in the EU, Japan and USA
Country Average annual leave entitlement* Statutory minimum annual leave entitlement Public holidays per year Average annual leave plus public holidays Statutory minimum annual leave plus public holidays
Austria 25 25 13 38 38
Belgium NA 20 10 NA 30
Denmark 30 25 9.5 39.5 34.5
Finland 25 24 12 37 36
France 25 25 11 36 36
Germany 29.1 20 9-12 38.1-41.1 29-32
Greece 23 20 10-12 33-35 30-32
Ireland 20 20 9 29 29
Italy 28 20 12 40 32
Luxembourg 27 25 10 37 35
Netherlands 31.5 20 8 39.5 28
Portugal 24.5 22 12-14 36.5-38.5 34-36
Spain NA 25 12-14 NA 37-39
Sweden 25 25 11 36 36
UK 24.5 20 8 32.5 28
EU average 25.7 22.3 10.8 36.5 33.1
Japan 18 10** 15 33 25
USA 16.9*** 0 10 26.9 10

* Average collectively agreed entitlement for EU countries, average paid holiday entitlement for Japan, average vacation days in medium and large private sector for USA.

** Basic entitlement after six months' service – increases with length of service.

*** After 10 years' service in medium and large private sector.

Sources: EIRO, JIL, BLS, TUC (Banking on your holiday?, August 2001).

The organisation and role of the social partners

Trade unions

Trade unionism in the EU is characterised by a high degree of unity and coherence at European level, and diversity and sometimes division at national level. The European Trade Union Confederation (ETUC) brings together almost all major confederations and centres in the EU Member States and, increasingly, in other European countries (currently 76 organisations from 35 countries). The most notable exceptions are: a number of specific organisations for managerial and professional staff, which belong to the European Confederation of Executives and Managerial Staff (CEC); and a number of organisations (generally outside the trade union 'mainstream') affiliated to the European Confederation of Independent Trade Unions (CESI). Also affiliated to ETUC are 11 'European industry federations', grouping most major EU trade unions in their respective sectors. ETUC claims a total affiliated membership of 60 million and continues to grow - for example it has recently admitted new member organisations from Belgium, Estonia, Lithuania and Norway.

At national level, there is a complex pattern of trade union organisation in the EU (and also in the candidate countries). The simplest situation is probably found in Austria and Germany, where there is a single dominant confederation (with only relatively minor alternative organisations in Germany, and none in Austria) made up of a quite small number of primarily industrial unions. A single major national centre is also the case in Ireland and the UK, though with a greater number of member unions, which are a mixture of industrial, general and occupational unions.

Multiple competitive trade union confederations, divided (at least originally) mainly on political and religious grounds are the case in Belgium, France, Italy, Luxembourg, the Netherlands, Portugal and Spain – with the number of main confederations varying from five in France to two in Portugal and Spain. In many cases, these confederations are made up of sectoral federations. In some of these countries – notably France and Italy – there are significant trade unions outside these 'representative' confederations. In the Nordic countries, the general picture is of separate confederations for different occupational groups – typically blue-collar, white-collar and professional/academic – made up of industrial and occupational unions. Finally, the distinction in Greece is between confederations (made up of a variety of types of member organisation) for the private and public sectors.

The structure of trade unionism in the USA is relatively straightforward and similar to that in Ireland and the UK. There is a single main national centre, the American Federation of Labor and Congress of Industrial Organisations (AFL-CIO), made up of a relatively large number (currently 65) of industrial and occupational unions. Only a few unions lie outside the AFL-CIO umbrella.

In Japan, there are two confederations of significant size. By far the larger is the Japanese Trade Union Confederation (Rengo), which organises over 60% of unionised workers. Rengo's membership is based largely on enterprise-level unions, organised in sectoral federations (there are thus some similarities with a country like France, where the main union confederations are made up essentially of local unions organised in sectoral federations). The second confederation, the National Confederation of Trade Unions (Zenroren), represents only around 7% of all unionised workers.

A common trend across the EU (at both European and national levels), Japan and the USA is towards consolidation and merger of trade union organisations. The number of European industry federations affiliated to ETUC has been reduced by mergers in recent years (eg in the food and agricultural sectors, and in services), while the number of member unions of most national union confederations has declined (and there are plans for further rationalisation in future in some countries). A particularly notable recent merger was the creation in Germany in 2001 of the Unified Service Sector Union (Vereinigte Dienstleistungsgewerkschaft, ver.di), which is thought to be the largest union in the democratic world, with nearly 3 million members. Elsewhere in the EU, 2001 saw major mergers in Belgium, Finland, Norway and the UK and proposed in Austria and Finland (though a number of planned mergers were rejected by members in Denmark and Sweden). In the USA, the number of unions affiliated to AFL-CIO has fallen from 96 in 1985 to 65 today, with around 40 mergers occurring during the 1990s - a recent major merger was that of the Communication Workers of America (CWA) and International Union of Electronic Workers (IUE) in late 2000. A process of consolidation has been occurring among federations affiliated to Rengo, albeit a relatively slow one.

Overall, union membership has generally been falling across the industrialised market economies in recent decades – according to most commentators, this is due largely to a number of common trends such as a decline in employment in traditionally high-unionisation manufacturing industry and the growth of lower-unionisation services employment, and increasing levels of 'atypical' employment. This decline seems to be the case relatively uniformly across the EU (and, to a greater extent, most candidate countries) Japan and the USA - though some EU countries, such as Sweden, have only recently started to experience union membership loss. However, in some cases, membership losses have been slowed (as in Austria or Germany) or even slightly reversed in the most recent years.

In 2001, union membership declined by 2.8% in Japan and remained virtually stable in the USA. No overall figures are available for the EU, but decline or at best stability seems to be the overall picture.

Even where union membership losses have been stemmed, increasing employment levels in many countries have meant that union density (the proportion of those in employment who are union members) has fallen – examples include Denmark and Ireland. Current union density levels are set out in table 9 below.

Table 9. Trade union density, Europe, Japan and USA
Country Union density (%)
Denmark 87.5
Finland 79.0
Sweden 79.0
Belgium 69.2
Luxembourg 50.0
Ireland 44.5
Unweighted EU average 43.8
Austria 39.8
Italy 35.4
Unweighted average of 10 candidate countries 34.1
Greece 32.5
Weighted EU average 30.4
Portugal 30.0
Germany 29.7
UK 29.0
Netherlands 27.0
Weighted average of 10 candidate countries 21.9
Japan 20.7
Spain 15.0
USA 13.5
France 9.1

Source: EIRO and national figures.

As the table indicates, the average trade union density in the EU (unweighted for the different sizes of the 15 countries) is more than double that in Japan and more than three times that in the USA. Union membership is clearly an altogether more common phenomenon in Europe than the minority activity it is in Japan and the USA. However, the unweighted average for the EU does not represent the proportion of the total EU workforce who are union members. Density in the largest countries – France, Germany, Italy, Spain and the UK – is considerably lower than the unweighted average (very much so in the cases of France and Spain), so the true average is substantially less. An estimate based on comparing the above density figures with Eurostat Labour Force Survey figures for total employment gives a weighted EU average of 30.4%

Union density varies considerably among EU Member States, from around 70% or more in Belgium, Denmark, Finland and Sweden to under 20% in France and Spain. However, the USA's union density is lower than any EU country's except France, while Japan's density exceeds only that of France and Spain.

Again it is worth noting that trade union density is generally lower in the candidate countries for EU membership than in the EU, with the unweighted average for 10 candidate countries just over a quarter lower than that for the EU. Weighting the averages gives an EU figure which is nearly half as high again as the candidate countries figure. This reflects the fact that union density is below average in the largest candidate countries – Poland, the Czech Republic and Hungary - though relatively high in countries such as Cyprus and Malta. Expansion may therefore bring the overall EU density situation somewhat nearer to Japanese and US levels.

In gender terms, unionisation levels are higher among men than women in the USA and probably Japan (though no figures are available in the latter case). This reflects the pattern in many EU countries with low to medium overall unionisation rates – such as Austria, Germany, the Netherlands and the UK. However in the high-unionisation Nordic countries – Denmark, Finland and Sweden – women's unionisation rate exceeds that of men (TN0103201U).

Employers' organisations

As with trade unionism, the representation of employers' interests at EU level is relatively comprehensive and coherent. The Union of Industrial and Employers' Confederations of Europe (UNICE) represents almost all the main national intersectoral confederations of private sector employers and business in the EU Member States (and elsewhere in Europe, including many candidate countries), with a current total of 34 national member organisations and five observers. It acts as both an employers' organisation (in that it engages in dialogue and, in specific circumstances, negotiations with ETUC) and as a trade/industry association (in that it is involved in promoting its members' interests in a range of areas, and in seeking to influence EU decision-making in areas of relevance). UNICE's coverage of organisations representing SMEs is arguably patchy, and a separate European-level body, the European Association of Craft and Small and Medium-sized Enterprises (UEAPME), seeks to represent this category of businesses. Since 1998, UEAPME and UNICE have cooperated closely in EU-level social dialogue and negotiations with ETUC (EU9903159F). Furthermore, the European Centre of Enterprises with Public Participation and of Enterprises of General Economic Interest (CEEP) represents enterprises and organisations with public participation or carrying out activities of general economic interest, whatever their legal or ownership status. It is treated as central social partner organisation alongside UNICE by the European Commission, and is involved in dialogue and negotiations with ETUC.

At European sectoral level, there are many hundreds of organisations representing business interests. However, very few of these are employers' organisations, in the sense that they represent their members with regard to employment issues or have relations with trade union organisations. The main exceptions are the organisations in those sectors where a 'sectoral social dialogue' has developed, either autonomously or on the instigation of the European Commission. There are currently 26 sectoral dialogue committees, bringing together European-level representatives of trade unions and employers for discussions on employment and social issues. Thus, there are European-level bodies acting in some ways as employers' organisations in sectors such as agriculture, banking, civil aviation, cleaning, commerce, construction, electricity, footwear, hotels and catering; inland navigation, insurance, leather, maritime transport, personal services (hairdressing), postal services, private security, public services, railways, road transport, sea fishing, sugar, telecommunications, textiles and clothing, tobacco and woodworking.

Joint texts (opinions, declarations, codes of conduct etc) on a range of issues (eg training, employment, fundamental rights or health and safety) have been reached in most of these sectors, but the employers' bodies (and union organisations) do not have a genuine bargaining role over pay and conditions, except in exceptional circumstances.

At national level, the organisation of employers varies substantially between the Member States. At intersectoral level, in countries such as Belgium, Denmark, France, Ireland, Italy, the Netherlands, Spain, Sweden and the UK, there is essentially a single umbrella organisation (at least for the private sector) representing companies' employer and business/trade interests – though accompanied by separate SME organisations in some cases (as in France or Spain). In other countries – notably Germany – there is a division between the representation of employer and of business/trade interests, with separate central organisations for each. The trend, however, appears to be towards the unification of representation of employer and business/trade interests – see for example the 2001 merger of the Swedish Employers' Confederation (Svenska Arbetsgivareföreningen, SAF) and the Federation of Swedish Industries (Industriförbundet) to create the Confederation of Swedish Enterprise (Svenskt Näringsliv) (SE0105199N), or the 2002 merger of employers' and trade associations in the Danish services sector (DK0207102N). Another difference at intersectoral level is that there may be a single central (private sector) body – as in the countries mentioned above – or there may be separate bodies for industry, services and in some cases agriculture – as in Finland, Greece and Portugal.

In terms of the role of employers' organisations, regular national intersectoral bargaining with trade unions over substantive pay and conditions issues is part of the remit of central employers' bodies in Belgium, Finland, Greece, Ireland and Portugal. Intersectoral bargaining over specific issues or procedural matters is part of the employers' confederations' role in Denmark, France, Italy, Spain and Sweden. While usually falling short of bargaining, employers' confederations have close cooperative relations with trade unions in various fora in Austria, Germany (the tripartite Alliance for Jobs) and the Netherlands (the bipartite Labour Foundation, Stichting van de Arbeid), which may lead to joint texts or approaches. It is perhaps in the UK that the main employers' body (the CBI) has the least 'bargaining-like' role in any area.

At industry level, sectoral employers' organisations with a collective bargaining role are key components of the industrial relations systems of most EU countries – Austria (where sectoral sections of the Chamber of the Economy [Wirtschaftskammer Österreich, WKÖ], play this role), Belgium, Denmark, Finland, France, Germany, Greece, Italy, Netherlands, Portugal, Spain and Sweden. Only in Ireland, Luxembourg and the UK are there few sectoral employers' associations with a bargaining role, as collective bargaining occurs essentially at company level (though overlaid with intersectoral bargaining in Ireland – see above under 'Collective bargaining').

Strong and representative employers' associations, especially at sectoral level, are relatively uncommon in most central and eastern European candidate countries for EU membership. At intersectoral level, employers' bodies in these countries rarely engage in bipartite bargaining with trade unions over pay and conditions, and in only few countries do sectoral employers' associations with a bargaining role play an important part.

Until 2002, Japan was like a number of European countries in having a single central employers' body - the Japan Federation of Employers' Associations (Nikkeiren) - and a separate central organisation representing companies' trade/business interests - the Japan Federation of Economic Organisations (Keidanren). However, reflecting the trend noted above for Europe, Nikkeiren and Keidanren merged in 2002 to form the Japan Business Federation (Nippon Keidanren). Nippon Keidanren does not participate in collective bargaining with trade unions, but it is involved in formal tripartite dialogue with government and unions, and less formal bipartite dialogue with unions. Furthermore, Nippon Keidanren attempts to influence the annual 'spring offensive' (Shunto) bargaining round, by issuing guidelines to employers.

Nikkeiren is composed of 127 sectoral associations (both industry and employers' organisations), plus 47 regional employers' associations, which do not generally have any direct bargaining role (though it has been suggested that they play a 'behind the scenes' role in coordinating member companies). Almost all bargaining occurs at the level of the individual enterprise.

The USA is unlike Japan and all EU Member States in that it has no identifiable national intersectoral employers' body with an industrial relations role. A special organisation has been created to allow US employers to be represented by a single intersectoral body in international organisations and fora – the United States Council for International Business (USCIB). Major business organisations such as the National Association of Manufacturers (NAM) and the US Chamber of Commerce do not deal with trade unions, though they do have some role in labour issues. NAM, for example, has a human resources policy department and human resources committee and runs a Center for Workforce Success. There are few national sectoral employers' bodies with any bargaining role, and bargaining takes place predominantly at enterprise or local level (see above under 'Collective bargaining').

Industrial action

International comparison of industrial action figures is difficult, not least because the definitions of industrial action used in national statistics vary so dramatically. For example, the US statistics record only 'major work stoppages' (with no distinction between strikes and lock-outs) – defined as those in which at least 1,000 workers are involved for at least one shift. By contrast, the UK figures, for instance, record all stoppages involving 10 or more workers or lasting more than one day (plus smaller-scale disputes when the aggregate of working days lost exceeds 100). Furthermore, no data are available for Japan or for the whole EU in 2001.

In the USA, major work stoppage activity was at a record low in 2001, in terms of the number of days of 'idle' workplaces and the percentage of estimated working time lost because of strikes and lockouts. Only 29 major work stoppages began during the year, 'idling' 99,000 workers and resulting in 1.2 million working days of idleness (less than 1 out of every 10,000 available working days). Comparable figures for 2000 were 39 stoppages, 394,000 workers idled, and 20.4 million days of idleness. Most of the stoppages were in the private sector.

The most recent figures available for Japan are for 2000, when there were 305 disputes which involved strike action, in which 85,000 workers participated, with 35,000 working days lost. Compared with 1999, the number of strikes fell by 27.2%, the number of participants by 20.4% and the working days lost by 59.7%.

Comprehensive figures are not available for the EU in 2001, but the picture varied from country to country. Some countries saw no significant industrial action at all during the year (such as Denmark, Luxembourg and Norway), and in most cases the year's collective bargaining passed off relatively peacefully (with specific exceptions in some countries, such as Lufthansa pilots in Germany and doctors in Finland). However, other Member States experienced a difficult year of industrial unrest - at least in terms of high-profile action, if not necessarily in statistical terms - for a variety of reasons.

'Political' industrial action by trade unions against government policies (notably in the social security field) was a feature of 2001 in Austria (AT0111201F), Greece (GR0105108N), and Italy (IT0201108N). Elsewhere, public sector action over reform plans and private sector action over restructuring were the key aspects of industrial action in varying degrees in countries such as Belgium, France, Spain and the UK.

However, despite a number of high-profile actions, in quantitative terms industrial action remained at low levels, in a historical perspective, in most Member States, as in Japan and the USA.

Company restructuring

In 2001, faced with an economic slowdown of varying intensity, which was exacerbated by the aftermath of the events of 11 September, companies across the EU, Japan and the USA engaged in major restructuring initiatives, often resulting in large-scale job losses, both in their home countries and abroad. Particularly hard hit were telecommunications (eg Sonera and KPN), information and communications technology (eg Ericsson, Fujitsu, Gateway, Hitachi, Lucent, Matsushita, Motorola and Toshiba) and (especially after 11 September) aviation and travel (eg Aer Lingus, Alitalia, American Airlines, Boeing, British Airways, Delta, Iberia, LTU, SABENA and United Airlines). Elsewhere, sectors such as motor manufacturing (eg General Motors and Fiat), iron and steel (eg Arcelor and Corus), food (eg Danone) and retail (eg Carrefour and Marks & Spencer) also saw deep restructuring.

The responses to this corporate restructuring's effects on workers and employment differed. At EU level, a number of initiatives aimed at cushioning the social effects of restructuring were either launched or were ongoing during 2001. A high-level group examining industrial relations and managing change, created by the European Commission, met during 2001 and issued a final report in January 2002 (EU0103200N). The European Parliament adopted a resolution on the social consequences of industrial restructuring in February (EU0103199N). The Commission issued in May a package of measures designed to reduce the social impact of large-scale job cuts (EU0106216N). Finally, the Commission launched consultations with the European-level social partners on the issue of industrial restructuring, in January 2002 (EU0201235F).

In individual Member States, company restructuring sometimes resulted in disputes between companies and the workers affected, but negotiation was in some cases the path taken to mitigating job losses and their effects. At European level, the French-based food group Danone concluded in October 2001 (EU0111206F) a European-level accord with the International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF) on the restructuring of its biscuits division, a development which had caused considerable criticism when first announced earlier in the year. European-level restructuring agreements were also reached at General Motors (BE0109301F). At national level, agreements to reduce redundancies or help redundant workers were reached in cases such as Adam Opel AG in Germany and KPN in the Netherlands. The high incidence of restructuring exercises had an impact on the regulatory framework in some countries, as in France, where the government redrafted and tightened redundancy legislation.

In Japan, with increasing restructuring, even those companies which formerly gave strong support to employment stability for regular workers have begun to show signs of a change in direction, with a succession of major workforce reduction plans announced in late 2001, especially in the ICT sector. However, many of these reductions affected multinationals' overseas establishments and, even when they affected domestic operations, they often concentrated on 'natural wastage', though with some use of voluntary retirement schemes.

Japanese trade unions and employers' organisations responded at national level to this weakening orientation among enterprises toward employment stability and avoidance of unemployment. Discussion took place in 2001 between Rengo and Nikkeiren on measures to sustain employment, and in August, agreement was reached to continue discussions along these lines, including on the issue of 'work-sharing' (ie sharing out employment opportunities though reducing working hours). The conclusion was that while the employer side should endeavour to maintain/secure employment, while unions should respond flexibly to reductions in working hours, as well as to the wage situation resulting therefrom. The government subsequently joined the debate on work-sharing, and a certain level of consensus was reached. In legislative terms, in October a new Employment Measures Law came into force, aimed at promoting smooth re-employment in response to changing socio-economic conditions, notably requiring employers which make a large number of redundancies at one time to adopt a plan to support re-employment systematically ahead of termination.

In the USA, 2001 saw waves of major job losses, especially after 11 September. No information is available on individual company responses, but following 11 September there were a number of relevant legislative measures aimed at providing immediate relief to distressed industries such as airlines and extending the time limits for unemployment benefits. More generally, measures to enhance workers' employment security in situations such as restructuring are a major issue in US collective bargaining. Research from the Bureau of National Affairs (BNA) indicated that some 95% of current collective agreements in early 2002 contained job security provisions such as extended 'recall rights', subcontracting restrictions, or advance notice of shutdowns.

Equal opportunities and diversity

In 2001, equal opportunities and diversity-related issues were prominent in new employment legislation in the EU Member States, reflecting both domestic agendas and the implementation of EU Directives (it was a quiet year in terms of new EU legislative activity in this area, following recent major developments). In the area of gender equality, new legislation, either adopted or proposed, covered matters such as: lifting bans on night work for women, as in France (FR0010196F) and Austria (AT0107222F); equal opportunities for federal employees in Germany (DE0112206N); positive action programmes in Greece (GR0108119F); and the burden of proof in discrimination cases in Luxembourg (LU0109171N). There was new legislation related to equal pay in Denmark and Sweden (see above under 'Gender pay inequality').

With regard to time off and leave related to childcare, there were legislative moves to extend or improve leave rights in 2001 in countries such as the Netherlands (NL0002182F), Belgium (BE0112361F), France (FR0112153F), Luxembourg (LU0110108F) and the UK (UK0105128N).

In terms of equality and non-discrimination on grounds other than gender, there was activity in some countries to implement the EU Directive (2000/78/EC) establishing a general framework for equal treatment in employment and occupation (EU0010274F). New legislation thus focused on age discrimination in Denmark (DK0102113N) and both age and disability in the Netherlands. In Germany, disability was also the focus of several new items of legislation relating to social security and employment (DE0112238F).

While equality and diversity issues feature to varying extents in collective bargaining in EU Member States, 2001 saw little in the way of new developments in this area (though see above under 'Gender pay inequality').

There was little legislative activity on equality issues in Japan in 2001, with the only relevant legislation reported relating to age discrimination in recruitment. Although no notable agreements are reported for 2001, equality and related issues are dealt with in enterprise-level collective bargaining and in negotiations within establishment-level 'labour-management consultation organisations'– permanent structures in which labour and management consult on issues related to management, production, working conditions and welfare programmes. According to a 1999 official survey (the most recent), equal treatment between men and women features in labour-management consultation organisation negotiations in a quarter of cases, while it features in collective bargaining in 9.7% of cases where a labour-management consultation organisation exists, and in 14.0% of cases where no such organisation exists.

No new equality legislation is reported from the USA in 2001 (as in 2000), but the country already has in place a relatively comprehensive set of federal civil rights laws prohibiting discrimination in the workplace on the grounds of race, colour, religion, sex, national origin, age and disability. These laws are the main vehicle for ensuring equal opportunities, but equality issues do feature in collective bargaining (such as equal pay for women, sexual harassment, diversity training, child- and eldercare, and combating discrimination). However, no statistics are available on the extent of such bargaining, and no particularly notable agreements were reported in 2001.

Training and skills development

Training and skills development featured prominently in collective bargaining in many EU countries during 2001, often linked to efforts to increase the employability of workers within the framework of the European employment strategy. Numerous collective agreements at all levels included clauses relating to training and skills development, such as paid training leave (Austrian paper and pulp sector and Luxembourg vehicle sales and maintenance); targets for employers' training expenditure (Belgian private sector); identifying and meeting employees' training needs (German metalworking); and training measures for vulnerable groups (Belgian private sector). Training was also high on the social partners' agenda in Germany's tripartite national Alliance for Jobs (DE0103213F). Legislative activity relating to vocational training was relatively limited in the EU in 2001. One exception was the UK, where legislation was proposed (UK0112104N) which included a right for 'union learning representatives' to take paid time off to promote training and development in the workplace (the Employment Relations Act 1999) had required employers to consult employee representatives over training issues.

Training and skills development are important issues for both labour and management in Japan. However, in terms of collective labour-management relations, since these matters are subject to discussion at the individual company level, there is no systematic data available. Nevertheless, a 1999 survey found that 'education and training plans' are dealt with by a majority of the labour-management consultative bodies which exist in around 40% of private-sector establishments with more than 30 employees.

In the USA, while specific data on developments in 2001 are not available, many companies have established extensive programmes to train employees not only in specific skills required for concrete workplace tasks, but also in broad academic subjects. In unionised workplaces, such training initiatives may be conducted on a joint basis. A notable example is the jointly-managed 'Alliance for Employee Growth and Development' created by AT&T and the Communications Workers of America, which has helped train and educate some 160,000 employees since 1986. A Garment Industry Development Corporation (GIDC), whose tasks include the provision of training, has been set up and jointly funded in New York's apparel industry by manufacturers and the Union of Needletrades, Industrial and Textile Employees (UNITE).

According to a Task Force on Retraining the American Workforce, commissioned by the Century Fund (a public policy 'think-tank'), there are indications that training practices may be spreading as more US manufacturing firms adopt 'high-performance workplace' principles, endorsed by management and labour, that emphasise the importance of training and giving responsibility to 'frontline' workers. Joint union-management training agreements involving the United Auto Workers, the United Steel Workers, the Service Employees Union, the Building and Construction Trade Unions and UNITE all include formal labour-management commitments to upgrade the skills of workers at most job levels in order to enhance both worker productivity and job security.

New forms of work

The growth of 'atypical' forms of employment – such as temporary work (mainly fixed-term contracts and temporary agency work), part-time work, teleworking or on-call work - is a common trend across the EU, Japan and the USA is and so on. Table 10 below gives comparative figures for part-time and temporary work.

Table 10. Extent of part-time and temporary work in Europe, Japan and USA (% of employment)
. Part-time work Temporary work
EU 18.0% 13.4%
EU candidate countries 9.8% 8.0%
Japan 15.4% 12.8%
USA 17.0% 4.9%

Notes: EU and candidate countries - figures from 2001 Eurostat Labour Force Survey, part-time work self-reported, temporary work refers to contracts of limited duration; Japan – figures for 2001 from JIL, part-time work is less than 35 hours per week, temporary work refers to non-agricultural employees classified as temporary or daily; USA – figures from BLS (December 2001 for part-time work, February 2001 for temporary work), part-time work is less than 35 hours per week, temporary work refers to 'contingent' work ('workers who do not expect their jobs to last') plus temporary agency workers.

Part-time work (despite differing definitions) is at around the same level in the EU, Japan and the USA, at approximately one-sixth of all employment (though the EU figure masks huge variations). It may be noted that the level in the candidate countries for EU membership is considerably lower, at something over half the EU figure. Another common issue is that part-time work is predominantly a female phenomenon – 33.8% of female employees are part-time in the EU (2001 Eurostat figure), nearly 40% in Japan (1999 JIL figure) and nearly 20% in the USA (1999, JIL). Some 80% of all part-timers are women in the EU (2001, Eurostat), compared with 68% in the USA and 67% in Japan (1999, JIL).

Temporary work is much more common in the EU and Japan than in the USA (though problems of definition are particularly acute in this form of employment).

Teleworking/telecommuting is on the increase in all three cases, though again differences in definition may make comparisons difficult. According to the European Commission, there are about 4.5 million employed teleworkers in the EU (around 2.8% of all employment) and about 10 million teleworkers in total. Japanese research (from Japan Telework Association) indicated that there were 2,464,000 telecommuters (both those working at home and those working in satellite offices) in 2000, over 3% of total employment. In the USA, the number of teleworkers was put as high as 28 million - or around a fifth of the adult workforce - in 2001 (by the International Telework Association and Council): the definition used includes teleworkers working at home, at telework centres or satellite offices, or 'on the road'. Other new forms of employment are particularly relevant in some countries. For example, 2 million US workers (1.5% of total employment) work on-call – ie they are called to work only as needed.

Faced with the growth in 'atypical' employment, a framework regulating a number of types of 'new forms of work' is being created at EU level, seeking to prevent discrimination against the workers involved and promote quality and flexibility in such work. Following Directives, based on social partner agreements, regulating part-time work (1997) (EU9706131F) and fixed-term work (1999) (EU9706131F), the Commission issued a proposal for a Directive on working conditions for temporary agency workers in March 2002 (EU0204205F), following the breakdown of social partner negotiations on this issue in May 2001 (EU0106215N). During 2001, the social partners were engaged in negotiations on the issue of teleworking (EU0111102N), which resulted in agreement in July 2002 (EU0207204F).

At national level, new legislation on part-time work was adopted in a number of EU Member States in 2001. For example, the 1997 part-time work Directive was implemented in Denmark, Germany, Ireland and Sweden, while Spanish labour market reform legislation sought to foster part-time employment. With regard to fixed-term employment, the 1999 EU Directive was implemented in Germany, Italy (on the basis of a joint statement signed by many social partner organisations), the Netherlands, Portugal and Sweden, while a French 'social modernisation' law included restrictions on fixed-term contracts. In the area of temporary agency work, legislation adopted in Greece introduced a new legislative framework for temporary employment agencies, while new legislation in Finland stipulated that employers of temporary agency workers must adhere to the terms and conditions of the collective agreement which applies to the user company, clarifying a situation which was previously opaque. New labour market legislation in Germany sought to enhance the opportunities to integrate unemployed workers into the labour market through temporary work agencies.

In the collective bargaining arena, regulation of temporary agency work was the subject of a number of collective agreements in 2001 in EU countries such as Belgium, Germany and Sweden. Notably, Germany's ver.di trade union and the leading temporary employment agency Randstad Deutschland GmbH concluded an agreement on pay increases for about 21,000 of the latter's employees working in various companies (DE0105222N). This sought to set an example for the whole sector, with most agency workers currently not covered by collective agreements. A first independent collective pay agreement was concluded for Sweden's 20,000 white-collar temporary agency workers (SE0112101N).

Bargaining also covered telework in some EU countries in 2001. For example, the Italian Confederation of Small and Medium-sized Industry (Confederazione italiana della piccola e media industria, Confapi) signed a national intersectoral collective agreement with trade union confederations to regulate teleworking in its affiliated companies (IT0108194N).

In Japan, the diversification of employment patterns has continued - the percentage of employed persons (excluding those in managerial positions) who are 'regular' employees declined from 80.2% to 72.8% between 1991 and 2001 - and created important industrial relations issues. For example, ways of ensuring equal treatment for part-timers and full-timers have become an important subject for debate. The changes in employment types, the growth of non-traditional work schedules and increasingly diversified personnel practices suggest that the former 'group-based' employment contracts under which all workers shared common conditions will increasingly be replaced by contracts of an individual nature. In these circumstances, the adaptations that this will necessitate in existing patterns of labour-management relations can be expected to become the subject of considerable debate. There has also been substantial recent legislative activity to take account of the growing levels of atypical employment, though 2001 was a quiet year in this regard..

No legislative developments relating to new forms of employment are reported from the USA in 2000, while no data is available on the content of any collective bargaining on the issue. However, flexible work arrangements are an increasingly prevalent issue in US employment relations, both inside and outside the collective bargaining context. These include 'flexiplace' (working at home or at a designated work facility near home) and 'flexitime' (allowing employees to vary the time of their arrival and departure) and credit or compensatory time arrangements (allowing employees who accumulate overtime hours to use them for future time off from work). Employees have also raised the issue of safety as a justification for flexible work arrangements in the wake of 11 September. However, some employees are thought to be reluctant to use these flexible arrangements for fear of being perceived by management as less important to the organisation's operations, while many managers are still not comfortable with flexiplace arrangements, preferring instead to have 'instant access' to their employees. In 1997, 27.6% of all wage and salary workers were on flexitime or flexiplace, and the figure is likely to have gone up since then due to greater availability of computer technology. However, such work schedule flexibility is not mandated by law.

Finally, in 2001, the US government created an Office of the 21st Century Workforce within the Department of Labor, to promote the study and the development of strategies to assist the 'American workplace' to meet the challenges of the global, information-based economy. The mission of the Office is to study trends and recurring issues within modern workplaces and develop workable strategies for resolution.

Mark Carley, SPIRE Associates

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