Amidst the ongoing criticism of mainstream approaches to capitalist diversity, one question seems to be underestimated: that of how to conceptualise workers as subjects and social actors (see also Fishwick, Taylor and Bailey & Shibata in this special issue). For these approaches, and especially in the varieties of capitalism (VoC) framework of Hall and Soskice (2001), labour is inevitably bound to national institutions, mentalities and histories, and thus it is taken to represent--together with other institutions--the national momentum of capitalism. The theoretical binding of labour to national institutions was accompanied by a more general lack of critical reflection on capitalism and globalisation, and thus became the main paradigm within political and trade union debates, too. Especially the VoC approach spread the idea, at least for German unions, that strengthening the 'typical' national institutions would enhance the comparative advantages of nation-states and thus allow coordinated market economies (CMEs) such as Germany's to persist. Meanwhile, the continued existence of the German or so-called Rhineland model of capitalism has often been questioned, but the theoretical heritage of the VoC and other comparative capitalisms (CC) approaches is largely uncontested, with labour conceptualised as an appendix of national institutions.
Through presenting empirical material from interviews with workers' representatives from different production sites in Europe, and thus with representatives acting on the firm level (EWCs but also others), I argue that it is important to analyse labour as a transnational actor. This entails the deconstruction of the way in which employees position themselves on a transnational scale while also acting locally and nationally. Transnationalisation in this perspective is one important dimension/scale of social (labours') action, and is not to be equated with a positive overcoming of (national) cleavages. On the contrary, as the material shows, the flame of cultural and national differences has become an important ideological flame for labour's participation in the construction of transnational competition. Thus, in order to strengthen emancipatory forms of (labour-)transnationalisation, it seems important to recognise its already existent, competitive and culturalist form. This includes distancing us from the idea that labour is only a national actor, while capital represents the transnational.
National paths and trade union debates
Comparing capitalism(s) is not new (Bohle & Greskovits 2009). But diversity concepts experienced an important upswing with the collapse of the 'Soviet bloc' in the early 1990s and the related widespread political and scientific belief in: (i) market liberalism as the 'end of history'; (ii) globalisation as a transformative force that would lead to convergence on a single, liberal economic and social model via economic strategies following the 'one best way' of technological and economic efficiency (Ohmae 1994; Womack et al. 1990; Bartlett & Ghoshal 1989); and (iii) economic 'shock therapy' for Central and Eastern Europe in particular (Lipton & Sachs 1990). Institutional approaches, for their part, criticised sharply what they called the ideology of 'transitology', built in their view on a non-historical neoliberal telcology, and opposed it via the concept of 'path-dependency':
Path dependency is a variant of the institutional approach which signals that the development trajectory of the new is shaped by the legacy of the old.... For example, long established elements of trade union structures may persist, even when the unions themselves are new creations with new functions for which these traditional elements are no longer appropriate. (Hill et al. 1997: 231)
The deep economic and social crisis in some CEE countries, and the growing differences between them, supported the idea of path-dependency and its emphasis on the importance of historical continuities. But the Western countries also became the object of many studies and empirical demonstrations of the huge national differences between them (Crouch & Streeck 1997; Kitschelt et al. 1999). Moreover, these studies were particularly interested in the systems of industrial relations (Traxler 1999).
Trade union research in the context of Europeanisation, and the question of how to develop a European social model to complement the European internal market, often followed this 'primacy of nation-states or local institutions' (Bohle 1999: 3). Its first and main task consisted in understanding trade unions and systems of industrial relations in their national specification, in order to 'disclose the typical national characteristics and problems of trade unions' (Lecher & Naumann 1991:17). But here the path-dependency paradigm changed the focus: it now became the main factor when explaining the difficulties in developing--as many authors put it--a 'European consciousness', which in their view meant the 'mental emancipation of the national state' and the development of a 'European identity' (see Eberwein et al. 2002). Especially in the literature on European Works Councils (EWCs) the national differences in institutions, culture and 'mentalities' (as it was now termed, mostly without any theoretical or critical reflection), seemed to be the main obstacles to the institutionalisation of a real European structure of workers' representation--which conversely was seen as the potential 'emancipation from the nation-state' (Lecher et al. 1998: 255).
With this methodological and analytical approach, many studies searched for the emergence of common European values and norms, common habitualised practices and common juridical institutions--and instead often found, following the institutional paradigm again, the persistence of national confrontations through nationally specific cultural norms, habitualised practices and juridical institutions. Even when social differences, economic competition and accompanying tensions (for example, concerning plant closures) were described, the analysis was framed by the assumption of inevitable 'cultural conflicts' between workers' representatives coming from different countries (see Stirling & Tully 2004; Miller 1999). Or, as Werner Altmeyer (2004: 38) put it: 'The main difficulty for the successful building and working of European Works Councils is to be found in the different systems of representation in each country and the different value schemes and historical traditions they represent'. It is not by chance, even if unintentionally, that Altmeyer here considers workers' representation as the representation of national value schemes. Indeed, this literature tends to give overviews of traditions and values in the countries in question--mostly a brief history since industrialisation--in order to explain why and in what manner mentalities and values are different. The notion of capital and labour, and the current dynamics of this relationship, get lost--even if every author underlined the importance of unions' Europeanisation and internationalisation due to the globalisation of capital. But it was not at all clear how this might be achieved, even theoretically, since labour was fixed as a national entity embodying a nationally homogenous set of value schemes (see also Gough in this special issue).
This approach has been criticised. For example, Dorothee Bohle (1999) argued that the paradigm of path-dependency seems less relevant for the current historical period, as it theoretically tries to preserve national state forms and practices at a time in which those practices become part and motor of transnational dynamics. Moreover, Guglielmo Meardi (2000) found that what he called 'theoretical laziness': empirical findings about labour's attitudes, in his case the attitudes of Polish workers, are explained with recourse to a 'Polish mentality', and thus without any reference to the context of (transnational) capitalist restructuring. He underlines the political dimension of that 'culturalisation', for instance when waves of strikes in Poland during the 1990s are denounced as 'typically Polish'. Adelheid Hege (1998) also critiqued diversity research and institutionalists for using taken-for-granted and often 'ethnocentric' understandings of the nature and meaning of national institutions. Instead, she argued that for comparison one needs to analyse the process of representation and the function institutions are given by the workers themselves. Finally, Richard Hyman (1998, 2001) doubted that the comprehension of 'the...