Özet:

As of 2015 Armenia, Belarus, Kazakhstan, Russia and (since May 2015) Kyrgyzstan have entered  into the Eurasian Economic Union (EAEU) with the ambitious goal of ultimately transforming it into  a “Eurasian Union” with a deeper confederative structure in the future. Parallels between this  regional integration project and the European Union integration process are emerging. But there  are also marked differences between them. The article highlights those parallels and differences in  order to assess the general prospects for harmonizing labor law among the member states and to  clarify how much of the EU experience in the harmonization of labor law may be applicable to the  Eurasian integration project. The completely different roots and ways to harmonize the national  labor law systems within the EU and the EAEU are also discussed in the article. The authors claim  that the approaches to harmonizing labor law in the two regions are mirror images of each other.While the EU project attempts to provide at least a partial common legal framework for certain separate aspects of legal regulation of labor among the very diverse national labor  law  systems, the EAEU currently refuses even to address the harmonization of national labor laws.  However, the national labor law systems of EAEU member states are already much more  homogenous than in the EU. Therefore, labor law harmonization in the EAEU may develop as a  consequence of its economic integration and single market. 

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