Labor standards in EU and US preferential trade agreements: mainstreaming the trade-labor linkage

Abstract

This chapter takes stock of the EU's and U.S.' distinct approaches to the inclusion of labor provisions in their preferential trade agreements (PTAs). It provides a historical overview of European and American attempts to link trade agreements with labor standards, examines the discrepancies and synergies between the two approaches, and points at the limited instances of their convergence. The chapter further assesses the implementation successes and failures of the two approaches, probing their effectiveness and identifying areas where room for improvement might exist. Finally, it charts out the latest developments in EU and U.S. trade policies regarding the inclusion of labor clauses in PTAs and global ramifications stemming from them. It shows that more than two decades of labor rights' incorporation into PTAs by the EU and the U.S. have led to the emergence of a global trade norm replicated in bilateral agreements pursued by other players across the globe.