The "Europeanisation" of labour law: can comparative labour law solve the problem?

Abstract

The debate surrounding the nature of "Europeanisation" has been raging in the EU for a number of years. It raises a variety of issues regarding the impact of the EU and its effects on the domestic politics and institutions of member states. In terms of labour law, the EU has, over the years, attempted to Europeanise national labour law systems directly and indirectly by introducing measures under the banner of "European labour law". However, there has always been a debate on the success of such measures as well as on the existence of a category of European labour law. This paper examines the debate surrounding the Europeanisation of the German and UK labour law systems.