Introducing a comparative analysis of union identities

While the work to this point has focused upon understanding the projected identities of unions certified in Great Britain, albeit including some binational and multinational unions, this chapter explores how the multidimensional framework might be applied to unions based in five other countries and to considering what additional sources of union identity might be required. In offering this extremely limited comparative analysis it is acknowledged that it can only scratch the surface of the global experience and therefore should be regarded as a starting point for future work. Although the research reported earlier explored the projected identities of all unions certified in Great Britain, it was not possible within the limitations of this work to do such extensive research on each of the countries considered. The comparative analysis offered in this chapter therefore draws largely upon secondary source material, although it was sometimes possible to explore the websites of national union centres and of some significant unions.

The five countries examined in this chapter are China, France, Germany, Japan and the United States of America (US). In each case they were selected because they provided evidence that either utilized the sources of identity projected by unions certified in Great Britain and/or suggested additional sources which might need to be incorporated in the multidimensional framework to enable a more comprehensive comparative analysis. In exploring the manifestation of union identities and niche unionism in other countries it is recognized that different union structures exist. While the TUC provides the main trade union centre in Great Britain, albeit with regional TUCs in Scotland and Wales, many countries have multiple union centres, often reflecting the identities of their affiliates. It was therefore considered necessary to briefly explain the significance of these in relation to understanding the projected identities of their affiliates.

Union identities in China

In China a single trade union, the All-China Federation of Trade Unions (ACFTU) operates in parallel with the Chinese Communist Party (CCP), having the legal duty to ‘safeguard the legal rights and interests of the employees’ while ‘upholding the rights and interests of the whole nation’ (Cooke, 2012, p 136). However, Liu (2013) suggests that because competing trade unions are illegal, the ACFTU cannot be considered as genuinely representative of organized labour.