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The American policy of “hire and fire” is simply not allowed under some European labour laws.

After announcing massive rounds of layoffs, US tech companies like Amazon and Google are struggling to reduce staff in places like Germany and France, according to Bloomberg.

In the highly volatile US labour market, companies can simply decide to let go of hundreds if not thousands of workers with little notice. In Europe, however, the mass layoffs announced by large tech companies have stalled because of labor protections, Bloomberg notes. This is because the labour laws in some countries make it difficult if not impossible to fire people without going through an extended process of consultations and negotiations with employee interest groups.

In France, for example, Google parent Alphabet is currently trying to reduce headcount by getting employees to leave voluntarily. The company is seeking to entice workers to leave by offering generous severance packages, sources told Bloomberg.

Another French source said that Amazon has tried to convince senior managers to resign by offering as much as one year’s severance pay. The company has also granted leave to departing employees so their shares can vest and be paid out as bonuses.

Employers are legally required to negotiate with workers

In France and Germany, which have the strongest labour laws in the EU, Google finds itself embroiled in legally required negotiations with works councils. Unlike large trade unions, these councils are internal, company-specific groups whose elected employee representatives negotiate with management about workforce issues.

Bloomberg’s sources explained that due to these processes, the Google branches in Germany and France will be some of the last locations to effect the cuts. There is even a possibility that the layoff plans might have to be abandoned, they said.

Laws still vary by country

When asked to comment, Google admitted that it was negotiating in France and Germany, but that it was not planning any layoffs in other places like Romania, Greece or Austria. 

“We have been working carefully and individually through each country where reductions are taking place to fully adhere to local legal requirements, which vary per location, are complex, and take time”, a Google spokesperson told Bloomberg.