The Fight Over Working Hours: Trade Union Action or State Control? A British-Dutch Comparative Perspective

This paper examines the historical development of the control over working hours in the United Kingdom and the Netherlands. The voluntaristic approach of British trade unions, employers and government is contrasted with the regulatory approach achieved through consensus in the Netherlands. Historical data is used to show how British trade unions have tried to control the length of working hours through negotiation and industrial action, whereas their Dutch counterparts have relied more on seeking statutory controls over working hours through pressure on the Dutch parliament. We show how these two approaches have been changing in the last twenty years and provide guidance as to how they may converge in the manner advocated by the European Working Time Directive.