Labour Studies Index

Updated: 2022-05-16

U.S. and Canadian Labour Law: Significant Distinctions

Document type Article
Author Sack, Jeffrey
Journal ABA Journal of Labor & Employment Law
Volume 25
Date 2010
ISSN 2156-4809
Pages 241-258


This article is intended to highlight the basic differences between Canada and the United States in the legal principles governing collective bargaining law. While Canadian labour relations legislation is modeled on the U.S. National Labor Relations Act, there are striking differences arising from the particular socio-economic conditions, cultural traditions, and historical experiences of both countries. Generally speaking, it is not widely disputed on either side of the border that Canadian labour relations law is more "progressive" than its U.S. counterpart. The question arises: Why?