The European works council directive is the first directive to be adopted under the Social Protocol of the Treaty on European Union (Maastricht Treaty). The approach involves both a consideration of the American field of human resource management (HRM) and a consideration of the works council directive in order to ascertain the difficulties in reconciling the two. The paper is divided into three parts and a conclusion. Part one deals with trends in American HRM and explains some similarities and differences with European developments. Part two examines the European works council directive. Part three presents the findings of a questionnaire given to human resource managers in American MNC's with operations in the EU. The conclusion, which are preliminary pending personal interviews with HR managers, draws together the implications of the findings in the three parts.