"This article reviews international, European and national regulation of transnational primary and secondary collective action. There is no explicit provision mentioning the right to international primary or secondary collective action in the relevant international instruments. Within the European Union, several legally binding instruments refer to the right to collective action but none explicitly refers to transnational secondary action. An overview of national regulation of international secondary action shows that at least some countries require or will require that transnational action be subject to the same limitations as those laid down for national secondary action. The possibility for legitimate transnational collective action needs to be clarified. "

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