We have replied to the public consultation on the review of the working time directive. Both the process and form of the consultation have caused us concerns. The consultation was open to all potential respondents, not only the social partners and given the limited opportunity to highlight our views in a meaningful and comprehensive way, we have decided to also present them to you in this letter.
The legal basis of the working time directive is and should remain protecting workers’ health and safety and the current directive sufficiently meets this objective.
The directive has a clear impact on business, as many of the rules are overly detailed and prescriptive, and therefore complicated and costly for business to apply. This lack of flexibility can also hamper employers and workers in devising arrangements at national, sectoral and company level. We note that the non-regression clause in the directive limits the opportunity for flexibility in national transposing measures after the adoption of the directive.