Procedures Adopted in the Rapid Response Labour Mechanism of the United States–Mexico–Canada Agreement: The Case Study Research and Lessons for the European Union

The aim of this article is to discuss a sanction-based model of labour provisions in free trade agreements (FTAs) adopted by the United States, against the background of the EU “promotional model” focusing on dialogue and cooperation. Using the case study research method, the authors analyses the United States–Mexico–Canada Agreement (USMCA) cases and the procedures adopted in the Rapid Response Labour Mechanism (RRLM). The findings of this paper reveal, among other things, that most USMCA cases were successful. The article shows that the EU should enter FTA negotiations with hard provisions in the templates on the table and should stick to both the pre-ratification and post-ratification conditionality which could increase the enforceability of labour provisions in FTAs.