Comparing US and EU labour governance ‘near and far’ – hierarchy vs network?

Abstract

ABSTRACTThis article investigates how the European Union (EU) and the United States of America (US) govern labour provisions in Mexico and Morocco. Drawing on the external governance approach and distinguishing between governance through hierarchy and governance through network, it aims to assess the extent to which the EU and US enforce labour provisions by hierarchical means and promote them through horizontal, network-based interaction. In doing so, this study not only sheds light on the de jure component (i.e., modes of labour governance in preferential trade agreements), but also analyses the de facto dimension (i.e., modes of labour governance at the domestic level). The article reveals that the EU and US de jure rely on hierarchical and networked means while de facto they generally emphasize the latter. Hence, contrary to what a power-based hypothesis would suggest, structures of power do not determine EU and US external governance of labour provisions.