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1The meaning of gender equality is contested. The feminist literature and the history of feminist campaigns have been characterized by divisions chiefly between those who argue for equality with men and those who argue for the recognition of difference between men and women as a means to promoting equality. Equality to men, for example in respect of access to education and the labour market (particularly the professions), and before the law, has been hard fought and was always the focus of English-speaking feminism (especially in the US, where even provision for maternity leave was omitted from feminist desiderata). In continental Europe, feminists were always more concerned to campaign for recognition of difference in respect of maternity. In the post-war period the desirability of equality to men on men’s terms has been increasingly questioned, particularly in respect of the need to emulate the male career path in order to gain an adequate – not necessarily equal – income, not just during working life but also in old age. In other words, the most significant issue for gender equality in relation to women’s welfare has been perceived as the impact of the persistent gendered divisions of paid and unpaid work. [1]

2This dimension of gender inequality has become more pressing because of the nature of labour and family change during the last quarter of a century and because of the nature of welfare state change since the 1990s. First, in terms of labour market behaviour, family formation, and the nature of the contributions they make to families, women have changed much more than have men. Women have entered the labour market to a much greater extent than men have increased their household work, and this holds true for all developed countries. In addition, in many northern and Western European countries, and in North America in particular, it is increasingly common for mothers to bring up children alone, as a result of high and stable rates of divorce and high rates of unmarried motherhood, driven by the vast increase in cohabitation. It is therefore increasingly possible for policymakers to assume that women are becoming increasingly “individualized”, which in policy terms tends to be understood simply in terms of increasing economic independence.

3This dovetails neatly with the trend in welfare state restructuring, the main feature of which has been an effort to shift the emphasis from rights to responsibilities and from so-called “passive” to “active” welfare provision, such that claimants on the welfare system are “encouraged” into work and work is made “to pay”. Welfare states were built around the work/welfare relationship and the incentive and disincentive effects of social provision on the worker’s inclination to search for employment and to support him-self. However, the work/welfare relationship has been substantially recast in the face of the growing challenges from an ageing population and globalized markets. Gilbert (2002) has characterized the new trends in terms of a series of shifts from social support to social inclusion via employment, from measures of decommodification (that enable people to leave the labour market for due cause) to ways of securing commodification, and from unconditional benefits to benefits that are heavily conditional on work or training. Crucially, for the first time, this recast work/welfare relationship has been extended to women as well as men (Lewis, 2002). However, there is a danger that the new set of assumptions about the desirability and inevitability of what is now conceptualized as an “adult worker model family” is outrunning the social reality, because there are still profound gender divisions in both paid and unpaid work.

4There are therefore some difficult policy issues that arise from gender inequalities. If working age adults are increasingly to be treated as self-supporting (for example, in respect of pension provision), then policy should surely focus on securing women a more equal place in the labour market. However, first, this seemingly simple goal depends on addressing more than access to and treatment in the workplace; the gendered divisions of unpaid work lie behind what Hochschild (1990) has called the “stalled revolution” in gender equality. Second, a focus solely on securing more equality for women in the labour market ignores the issue of who will do the socially necessary, unpaid work of care for children and the growing number of frail elderly dependants. At present women do a disproportionate amount of this work. One solution may be to reward them for it, but this runs the risk of perpetuating the perception that it is “women’s work”. On the other hand, some women – in some countries more than others – may wish to choose this kind of work more than men do.
A variety of policies have been used at EU and member-state level to promote gender equality, including policies to address the issue of unpaid care-work. The EU level is worthy of consideration because the pursuit of gender equality has occupied such a central place. What it shows [2] is, first, the difficulty in keeping the pursuit of gender equality central to policies designed in whole or in part to achieve it, and, second, a rather narrow understanding of the goal of gender equality policies as, mainly, female participation in the labour market. Gender equality has tended to be harnessed to dominant economic goals of increasing competitiveness and growth. At member-state level, the implementation of common policies (for example in the transposition of the Directive on parental leave) varies hugely, and the policy logics are very different. A necessarily brief consideration of these shows that it is impossible to say that any one policy is either necessary or sufficient to produce a particular outcome. However, taken together, the different kinds of policy approaches to gender equality in different countries can be seen to have particular advantages and disadvantages. Furthermore, these may suit particular cultural orientations. The last section of the paper suggests that the pursuit of gender equality requires a wider policy canvas and more attention to the behaviour of men.

Gender Equality Policies at the EU Level

5Work/family reconciliation, equal opportunities and social policies have all been historically linked at the EU level. In the 1957 Treaty of Rome, the commitment to equal opportunities in the form of equal pay for men and women constituted one of the European community’s main commitments to social policy. This was a measure that lay outside the established contours of social policy development in twentieth-century Western European welfare states, which built their systems of social protection around the relationship between the male worker and the labour market – the work/welfare relationship. However, in fact, the commitment to equal pay was closely linked to the central preoccupation with the work/welfare relationship, in that the main concern was to create an “equal playing field” to ensure fair competition. Thus gender equality, which has been an important goal at the EU level, has been historically linked as much to the pursuit of market-making as to social justice.

The Meaning of Gender Equality

6Much feminist writing on equal opportunities at the European level has commented on the narrowness of the way in which gender equality was conceptualized, the extent to which it was justified by market considerations and the continuing reluctance, especially on the part of the European Court of Justice, to consider unequal gender divisions in the family as well as in the labour market. The initial definition of gender equality in terms of the same treatment of men and women in the workplace was not tested until the mid-1970s (Case 149/77 Defrenne v. Sabena [1978] ECR 1356), and it was not until the late 1980s that equality was understood also to depend on account being taken of difference in the positions of men and women. This allowed for positive action to be taken to benefit women, and, mainly in the arena of work/family reconciliation policies in the early and mid-1990s, it also permitted the idea that the achievement of equal opportunities necessarily involved changes in the behaviour of men. The reworking of Article 119 in the Treaty of Amsterdam (Article 141) permitted positive discrimination in favour of women after a decision in the ECJ suggested that such measures conflicted with the formal principle of equality as equal treatment (Case C-450/93 Kalanke v Land Bremen [1995] ECR 1-3051). In addition, a firm and general commitment to gender equality was embedded in Article 2 of the Treaty.

7The definition of gender equality shifted again with the idea of “mainstreaming” that followed the Beijing Women’s Conference in 1995, and the accession of Sweden and Finland to the Community in 1996. Mainstreaming carries the idea that policies in pursuit of gender equality will no longer be confined to an equal opportunities “ghetto”, but will rather be integrated across all fields of policymaking. Rees (1998) has argued that mainstreaming has the potential to address disadvantage (the aim of same treatment policies) without denying difference. In this view, mainstreaming could prove to be “transformative” and change the gender hierarchy. It is intended to ensure that the standard against which equality is measured is itself subjected to a gender assessment. However, it is difficult to insert gender into what feminists have often referred to as the “malestream”. There is a profound tension between gender equality and the mainstream, which many have argued is dominated by the “sound money, sound finance” paradigm of the neo-liberal project, and which means, in an area such as work/family reconciliation, that “the business case” is likely to become the dominant frame into which arguments for gender quality must “fit”.

8The Commission’s Communication on mainstreaming defined the principle in terms of taking systematic account of the differences between the conditions, situations and needs of women and men in all Community policies and actions. This global, horizontal approach requires the mobilization of all policies. Later elaborations stressed the importance of the systematic consideration of gender differences “at the point of planning, implementing and evaluation” (COM [96] 650 of 12/02/97), and an explicit recognition that positive action and mainstreaming should “be applied together” (ibid.). In fact, it is relatively easy to reduce mainstreaming to a “tick box” approach, with little regard to the meaning of gender equality and the policy outcomes. The Framework Strategy on Gender Equality for the period 2001-5 stressed the value of the integrated approach made possible by mainstreaming, attaching most importance to the tools for achieving it in the form of clear assessment criteria, benchmarking, monitoring and evaluation (COM [2000] 335 of 7/6/00). Some assessments of the policy outcomes from mainstreaming, for example across all the different dimensions of the European Employment Strategy, have not been encouraging (e.g. Webster, 2001). Political will above all is necessary if mainstreaming is to take root at all levels of decision-making and to become “transformative”, but mainstreaming as one element in policy process stands in danger first, of being “ticked off” as having been “considered”; second, of being used instrumentally to serve the dominant policy frame (i.e. the process of cooption) and of therefore losing purchase on specific gender equality issues to do with the valuing of difference and redistribution between men and women; and, third, of losing any possibility of becoming a policy priority, because it treats gender equality as a “horizontal principle”; Maria Stratigaki (2005, p. 180) has gone so far as to describe it as “rhetoric devoid of substance”.
In the absence of political will to make it transformative, mainstreaming has allowed less attention to be paid to gender equality as a specific goal. In the wider policy context, gender equality has been more firmly tied, like social policy, to the economic goals of increased competitiveness and growth and its meaning has been increasingly restricted to the promotion of equal labour market participation rates. Thus, for example, the equal opportunities pillar of the European Employment Strategy (Council, 1998) disappeared in the 2003 version of the EES Guidelines (Council, 2003), because gender equality had become a “horizontal principle” to be mainstreamed across all policy fields.

Anti-Discrimination Legislation

9In parallel with mainstreaming gender equality, the concept of equality has been expanded to include diverse forms of inequality on the basis of race, ethnicity, age, sexual orientation, disability, religion and belief and embodied in “hard” EU law via two Council Directives (2000/43/EC; 2000/78/EC). The first of these required member states to implement the principle of equal treatment more stringently in respect of race and ethnicity than had ever been the case for sex (that is, outside the labour market). Only in December 2004 were women offered the same protection (2004/114/EC). The precise nature of the links in the policymaking processes behind these two dimensions of change in the approach to equality policies is beyond the scope of this paper, as are the extensive discussions as to whether the same tools can be used to address very different types of inequalities. But, it is important to outline the possible differences in the way in which this development of anti-discrimination policies can be interpreted. The expanded definition of equality has been entrenched in the form of Treaty objectives, and many have welcomed this firmer commitment to civil rights. However, the problem of how to read this development is as vexed as the shift to mainstreaming. A rights-based, anti-discrimination approach necessarily involves an individualist approach in the EU context, which raises the question as to how far civil rights are being seen as linked to social rights and social citizenship entitlements, and how far they may be thought to stand in place of them. There is also the issue as to how far these anti-discrimination rights are seen as a means of promoting diverse equalities in all spheres of life, and how far they are intended primarily to serve the dominant policy frame of access to the market and employability. Indeed, Phillips (1993) has stressed the difficulty of using an individual rights model to address the complexities of group injustice.
Since 1997, gender equality has been more firmly embedded at the EU level than ever before. However, the wider policy context also signals a more instrumental approach to the goal of gender equality. Anti-discrimination law has been extended and expanded, and is the main means of ensuring equal access to the market. In this regard the strongest form of gender equality policy at the EU level is similar to that in the USA.

Work/Family Reconciliation Policies

10During the 1990s, more attention was paid by the Commission, the Council and the Parliament to the issue of the unpaid work of care for children, largely in recognition of the impact that this has on the capacity of parents to seek work and/or training and education, in the context of the shift to an adult worker model family. It is possible to read this as a real shift towards policies to tackle socially constructed inequalities, or as part and parcel of an economic agenda. The measures adopted in the early and mid-1990s were couched in gender neutral language, leaving open the more radical possibility of encouraging change in men’s behaviour in regard to family carework. Thus in 1992, a Council Recommendation (92/241/EEC) was issued on childcare, recommending that member states develop and/or encourage initiatives to “enable women and men to reconcile their occupational, family and upbringing responsibilities arising from the care of children”. Indeed, the Recommendation defined childcare broadly and proposed that measures were needed in four areas: childcare services, leave for employed parents, family-friendly policies at the workplace, and measures to promote the increased participation by men in the care and upbringing of children. Peter Moss, who chaired the EC Childcare Network, suggested in 1996 that EU statements and initiatives on reconciliation were mainly grounded in the objective of gender equality, which was defined in terms of the conditions that were needed to attain genuine equality in the labour market (Moss, 1996).

11Most of the key documents on work/family reconciliation issued during the early and mid-1990s made explicit reference somewhere, if only in passing, to the desirability in principle of “sharing employment and family responsibilities”, a phrase defined by the Employment and Social Affairs Directorate in 1996 as reconciliation “so as to promote gender equality” (Commission, 1996c, Annex III, Glossary). Thus, more than one construction of work/family reconciliation could be found in the policy documents of the early and mid-1990s. Even the 1994 White Paper on Social Policy, which endorsed the stress placed on the need for higher “adult” labour market participation by the document on Growth, Competitiveness and Employment (COM (93) 700 of 5/12/93), referred also to the need for “greater solidarity between men and women” at the same time as it prioritized the role of social policies in promoting women’s employment (COM [94] 300 of 27/7/94, p. 43).

12In 1996 a Directive on Parental Leave (96/34/EC) was adopted, which laid down minimum individual rights to three months parental leave for men and women; member states were left to determine the conditions of access, whether the leave should be compensated and whether it should be full – or part-time. The Directive was prepared by the social partners, a by-product of the Maastricht Treaty’s Social Protocol. The leave was non-transferable – fathers could not transfer it to mothers – in order to promote gender equality. However, the fact that no minimum remuneration requirements were specified (a victory for the employer’s side) made it much less likely that men would take it and that it would in practice be reconciliation for women in a majority of member states, for example in Germany only 2.4 per cent of parents taking parental leave are fathers.

13Since the late 1990s, there has been a significant change in the way in which work/family reconciliation policies have been framed. From 1998, work/family reconciliation has been more firmly integrated into the Guidelines accompanying the European Employment Strategy (EES), with the result that, first, the goal of promoting gender equality by changing the behaviour of men has increasingly slipped out of the picture, and second, the policy focus has narrowed substantially to the provision of childcare services, which are more likely to promote female labour market participation than measures that provide time to care. The “virtuous” relationship between social, economic and employment policies was powerfully restated in the 2000 Social Policy Agenda (COM [2000] 379 of 28/6/00) at the same time as the Lisbon Council meeting set targets for increasing the employment of women (to 60 per cent by 2010). The Barcelona Council meeting went on to state that “Member States should remove disincentives to female labour force participation” and to set targets for the provision of childcare services to reach 90 per cent of children between three and school age and 33 per cent of the under-threes, leaving it entirely unclear as to whether parental leave provision “counted” towards meeting the target. This decision was notable for the explicit narrowing of the rationale for childcare services to women’s employment levels and of the policy focus to childcare services. This represented a substantial narrowing of the understanding of childcare (to formal, institutional provision) compared to the 1992 Recommendation. The priority accorded childcare services, which provide unequivocal incentives to women’s employment, rather than leave, which addresses the issue of carework, but if it is long (more than twelve months) and poorly compensated, may act to encourage female labour market exit (female employment rates have dropped in Finland since the introduction of the long home-care leave), is significant in this regard.
The more instrumental treatment of work/family reconciliation as part of the dominant growth and competitiveness agenda has not necessarily furthered the goal of gender equality. Reconciliation has been treated primarily as a policy for women, rather than as a means of changing the way in which paid and unpaid work is shared between men and women. Women’s labour market participation rates have risen in all member states. As a result, the Report from the Commission to the Spring European Council in 2004 focused much more strongly on securing a rise in employment for older workers (COM [2004] 29 of 20/02/04), while the High Level Group on the Future of Social Policy in an enlarged European Union continued to promote reconciliation, but mainly as a means of allowing couples “to have the number of children they desire” (Commission, 2004), a point reiterated forcibly in the Commission’s Green Paper on the need to address demographic change (COM [2005] 94 of 16/03/05). It is not clear that hitching reconciliation to the challenge of falling fertility will do any more for the pursuit of gender equality than the strong link to employment has done.
The most deeply embedded gender equality policy at EU level has been anti-discrimination legislation, which is designed to provide equal access to the labour market above all, but not necessarily to secure equal rewards. Indeed, the gender pay gap has persisted strongly, albeit to different degrees, in member states. Work/family reconciliation policies have been harnessed to different policy goals, but in recent years their attachment to gender equality has weakened. These policies vary hugely in their transposition to member states, even when, as in the case of parental leave, they were subject to “hard” community law. What the EU-level example shows is the importance of the meanings that are attached to gender equality and the way in which different policies to promote it relate to each other. From its inception, gender equality policy at EU level sought to secure equality in the sense of same treatment in the labour market, but this goal has not only proved elusive, but has recently been narrowed to the more economically instrumentalist objective of increasing female participation rates. The next section considers different modes of behaviour of men and women in respect of paid and unpaid work in relation to different policy logics at the member state level.

Gender Equality in Terms of Behaviour and Policy at Member-State Level

The Politics of Time

14Different countries have very different policies in respect of gender equality and in terms of the commitment to address the gendered inequalities in paid and unpaid work. Dual-earner (but not dual-career) families have become the norm in most western countries, although the number of hours women work outside the home varies hugely, and Crompton and Harris (1998) have identified no fewer than six orientations to combining paid work and mothering: “domestic”, “satisficer” (whereby paid and unpaid work is combined without maximizing either), “maximizer” (of paid or unpaid work), “careerist by choice”, “careerist by necessity”, and “undecided”. In part these orientations represent different attitudes and beliefs about the importance that should be attached to paid and unpaid work, which vary considerably between countries. Using ISSP data, Lück and Hofäcker (2003) have found that socialization effects, intergenerational value changes and economic pressures are all important in affecting gender attitudes. Certainly revealed preferences for undertaking paid or unpaid work are likely to be socially, economically and culturally embedded, and social policies play an important part in structuring the environment in which women and men make their choices.

15In Southern Europe, female labour participation rates are low, but women tend to work full-time. In much of Western Europe more women work, but part-time, in a one-and-a-half earner model, extending to a one-and-three-quarter model in the Scandinavian countries. In the USA, women’s participation rates are high and the vast majority work full-time. Indeed, Mutari and Figart (2001) have argued that gender differentiation is increasingly based on time – with men working full-time and a high proportion of women part-time, so that their paid work is combined with domestic work. Indeed, some form of part-time work for women (sometimes supported by state policies) has historically been the main way of reconciling work and family responsibilities in European countries, unlike the US, where women have tended to work full-time and to rely on (the relatively cheaper) market provision of care. The vast majority of men have continued to work fulltime and in the English-speaking countries a significant proportion (just over 31 per cent of UK fathers with children under 16) work more than the 48 hours laid down by the European Commission’s 1996 Working Time Directive. In addition, population ageing has increased care needs. It is now a quarter of a century since Brody (1981) identified the problem of the “women in the middle” – middle-aged women who found that they had to give care to both elderly parents and children, and since then the problem has intensified. Indeed in the UK it may well be in part responsible for the recent finding from a national sample survey that there has been a large increase during the 1990s in the proportion of women in their fifties reporting that they are “very” or “completely” dissatisfied with their paid work.
Labour market policies, particularly those regarding working time have increasingly been recognized as a crucial part of the policy logic structuring the gendered division of paid and unpaid work. However, notwithstanding the EU’s 1993 Directive on working time, the organization of working time remains largely the prerogative of employers. For example, in Sweden, The Netherlands and the UK, parents with children under six have the right to request flexible working hours. But, in the UK, perhaps in order to compensate in what remains relative to other Western European countries a lowwage economy, men with dependent children work the longest hours in the EU. The more flexible labour markets of the English-speaking countries also have higher rates of “shift parenting”. In addition, low-wage, flexible labour markets have implications for the welfare of carers in the formal sector.

Models of Reconciliation: the US and Scandinavia

16Only in the USA and in some of the Nordic countries have models been based on the assumption that both men and women will be fully engaged in the labour market. However these models work in very different ways. In the US case, the obligation to enter the labour market is embedded in strong anti-discrimination legislation to secure equal access and treatment in the labour market, and a residual welfare system that often borders on the punitive. In Scandinavia, anti-discrimination legislation has been historically weak; women and men have relied (relatively successfully) on strong trade union representation to secure equal treatment in the workplace. The adult worker model has been supported by an extensive range of care entitlements in respect of children and older people. The position of lone mothers – always a border case for the study of social policy – is particularly instructive in this respect, because as a group these mothers focus the problem of combining unpaid care work and employment. Since 1996, the US has treated these women as citizen workers, mandating a work-first policy and imposing time-limited welfare benefits. Employment rates for lone mothers are high in the US and they are more likely to work full-time; the push factor is strong. But there is, not surprisingly, much more outcry about family stress and “the crisis of care” in both one – and two-parent families (e.g. Heyman, 2000).

17But employment rates for lone mothers are higher still in Sweden and Denmark and their poverty rates are much lower than in the US, because they still get as much as one third of their income from state transfers. The Nordic model treats women as workers, but then makes allowance for difference, grafting on transfers and services in respect of care work for partnered and unpartnered mothers alike. Hobson (2004) has described the Swedish variant as a “gender participation model”, focusing as it does on promoting gender equality in terms of labour market participation and providing “supports” via cash (for parental leaves) and services (in the form of care for children and elderly dependants) primarily to women.

18Thus, the US operates a fiercely gender-neutral, equality-defined-as-sameness adult worker model, with very few supports for carework, although the market provides relatively good access to affordable (but not necessarily good quality) childcare. Günter Schmid (2000) has referred to this as the reinvention of domestic service, using, as it often does, migrant workers. Scandinavia operates what is in practice, but not in name, a gender-differentiated “supported adult worker model”, with high penetration of services for the care of children and elderly people and cash transfers in respect of parental leave. As a result, moderately high proportions of women work (long) part-time hours, exercising their right to work a six-hour day when they have pre-school children, as well as leaving the labour market for up to three years if they have two children in rapid succession. As a result, the Swedish labour market is the most horizontally sexually segregated in the western world. Swedish women have more choice about combining work and care, but at the expense of inequality in respect of horizontal labour market segregation. Women do a disproportionate amount of paid carework, which tends to be lower paid. The introduction of the “daddy quota” in the Scandinavian countries, whereby men are obliged to take part of the parental leave allocation (usually a month, but two in Sweden) or lose it altogether was aimed at promoting greater gender equality in unpaid work, something that would also begin to tackle labour market inequalities.
Thus, in the US and Scandinavian cases, very different policy approaches secure quite similar amounts of female labour market participation, but with very different provision for care, and with different implications for women and men who want to choose to care. The Scandinavian countries have made substantial progress in reconciling paid and unpaid work for women. They have also recognized the problem posed by the lack of change in men’s behaviour in respect of responsibility for unpaid carework via the relatively high compensation rates paid for parental leave and the introduction of daddy quotas, which have raised men’s take-up rates. To the extent that all “policy supports” are gender neutral in these countries, men have been permitted to choose to care, but labour market segregation means that men are likely, as in other countries, to be in better-paying, private-sector jobs and, again as is the case elsewhere, to experience work cultures that are often unsympathetic to care leaves, which is why the legitimization of men’s caring conferred by state policies in the form of the daddy leave has been important.

Models of Reconciliation: Western and Southern Europe

19Other Western European countries have moved substantially towards assuming the existence of an adult worker model family, but in practice still operate a mixed model of “partial individualization”. Thus The Netherlands and the UK have changed the nature of entitlements for lone-mother families, such that women with school-age children are encouraged to seek employment, the main motives being the wish on the part of Governments to address the issue of child poverty and to limit cash transfers to this group. However, incentives to partnered women to enter the labour market are ambiguous. Germany’s introduction of long (three-year), flat-rate parental leave in the mid-1980s favoured female labour market exit and maternal childcare in the family in contrast to the introduction of a 12-month parental leave (at 80 per cent replacement income rate) in Sweden in the late 1970s, which aimed to promote gender equality in the workplace. In the UK, the operation of a welfare system for adults that relies on means-tested social assistance rather than social insurance provides an inbuilt disincentive to the partners of unemployed men to enter the labour market. Reform of the tax/benefit system such that low-paid jobs are subsidized via tax credits (similar in principle more than in practice to the US’s earned-income tax credit), has served to extend the hours of part-time work, but the vast majority of mothers of young children in the UK (and The Netherlands) continue to work relatively short part-time hours. While the UK has opted to move towards a “supported” rather than an “unsupported” adult worker model since 1997, much more attention has been paid to investing in childcare services, which are more likely to result in women “choosing” to enter employment. In The Netherlands, part-time work is still explicitly the preferred way of reconciling work and family for men and women in terms of the policy discourse and survey evidence on revealed preferences. In Germany, too, providing women (but not men) with the “choice” of working or caring remains an important part of the political debate.
In Southern Europe, women (especially younger cohorts) are much less likely to be in the labour market, but when they are, they are more likely to work full-time (which is also true of French women). In Spain, this has resulted in increasing reliance on immigrant labour for domestic care work, in a manner not dissimilar to the US.

National Policy Assumptions and Logics

20It is possible to discern ideas about what is appropriate for women in particular to do in respect of work and care in all these models. In some countries, the desire to promote an adult worker model family is stronger in respect of some groups of women (particularly lone mothers) than others. The point is, first, that policymakers in different countries effectively operate with different assumptions about the contributions that men and women make and should make to families, and second, that choice in all these models is profoundly structured by social policies. In the US and Scandinavia it is assumed that adults will be in the labour market, but in Scandinavia sufficient “policy supports” in the form of cash compensation for care are provided to permit women to choose to care, such that these countries operate a “one-and-three-quarter-earner model family”.

21National systems have developed differently, which is important in respect of what kind of policy development may be possible and/or considered appropriate. In the USA, where the gendered division of unpaid work in the family has not been considered an appropriate concern for government, it would be very difficult for the state to intervene directly and explicitly in any way to implement policies that address unpaid carework. In EU member states, where for the most part there is a strong tradition of intervention in respect of care in terms of both cash transfers and services, there are nevertheless important constraints in terms of the mechanisms that can be used in particular policy contexts. It would, for example, be very difficult to introduce a German or Japanese-style, long-term care insurance for elder care in the UK, where social insurance has dwindled dramatically as a mechanism for social provision over the last two decades. Both the UK and Germany have expanded the number of childcare places over the last decade, but in the UK this has been done relatively quickly by central government offering pump-priming money to (mainly) private-sector providers, whereas Germany has used the long-established system of local finance and local consensus between public and voluntary providers to determine the way in which services should develop. Service development has been slower than in the UK, but the places created have proved much more sustainable. Addressing the gendered division of unpaid work is complicated by the needs and wants of carers (and of care-recipients), and is further constrained by the nature of the social welfare system. However, as at EU level, the focus of member states has been mainly on enabling women to engage in the labour market and therefore on “reconciling” paid and unpaid work for women. As the next section shows, the pursuit of gender equality requires more than this, and in particular attention to policies designed to promote the more equal sharing of paid and unpaid work between men and women.

Work, Family, Policies and Gender Equality

What can be Hoped for from Equal Opportunities Legislation

22The problem of reconciling work and family has become a more pressing policy issue because of the nature of family and labour market change. At the EU level and in many member states, the problem is as or more likely to be framed in terms of the need to encourage female labour market participation in order to increase competitiveness, or to address the issue of low-fertility rates, as to promote gender equality. Like the English-speaking countries, the EU has historically relied on anti-discrimination legislation applied to the workplace as its chief means of promoting gender equality.

23But almost fifty years after the inclusion of the commitment to equal pay in the Treaty of Rome, there remains a significant gender pay gap in all member states. The gap tends to be less severe in Southern European countries than in some Western European member states; the prevalence of part-time work has a detrimental effect on women’s pay, particularly in the UK. Occupational segregation is also still strong; women are disproportionately to be found in paid care jobs which tend to be low paid. Carework is not highly valued either by the market or in respect of state benefits. It is not clear how far anti-discrimination legislation is an effective tool to promote gender equality in the labour market. Jill Rubery (2003), Chair of the Commission’s Gender and Employment Expert Group, and her colleagues have reviewed the debate over measurement of the gender pay gap, and has suggested that there is evidence to support focusing more on occupational structure as a cause of inequality than human capital, and more on demand-side conditions than on individual choice. This means paying more attention to the overall wage structure, systems of collective bargaining, minimum wage policies and workplace policies. This is not to argue against legislation focused on the supply side. At the least, the existence of anti-discrimination legislation has helped to embed gender equality as normative in the EU. But Rubery’s analysis does signal the need for a wide range of employment-oriented measures to tackle inequalities in the labour market. Women have entered employment in much greater numbers, but their position in the labour market is far from equal.
Anti-discrimination legislation has always been criticized for the way in which it works at the level of the individual and through the courts, doing nothing directly to address the broader inequalities in the division of unpaid work in the home that lie behind inequalities in the labour market. Work/family reconciliation policies do have the potential to address the fundamental gender divisions in paid and unpaid work in a way that antidiscrimination legislation does not. EU level policy has only encompassed work/family measures during the past decade, but has increasingly envisaged them as a means to increasing women’s employment rates and, most recently, as providing a means of addressing low-fertility rates, rather than as policies focused mainly on securing gender equality. In fact, work/family legislation has probably not been very important in promoting equal labour market participation; tax/benefit policies, for example, have been more decisive in this respect, although the OECD (2001) has suggested that highly developed work/family reconciliation polices may boost the labour participation rates of women in their thirties. In Sweden, the rise in female labour market participation preceded the major initiatives to provide childcare services and parental leave in the 1970s (Nyberg, 2004), although there was in all probability a subsequent iterative relationship between the development of work/family reconciliation policies and further increases in female employment. In the US, high rates of female labour market participation have been achieved in the absence of work/family reconciliation measures.

What Work/Family Reconciliation Measures Need to Do

24In the main, as they have developed so far, most work/family reconciliation policies have helped women to combine paid and unpaid work. This is not unimportant, given the attitudinal evidence that shows that some women in some countries want to able to choose to do the unpaid work of care (Lück and Hofäcker, 2003). The major policy problem remains that in enabling the choice, policies are tending also to perpetuate gender unequal outcomes. This is likely to be particularly serious in respect of future pension entitlements, given the direction of pension reform (lengthening the number of years necessary to qualify for a pension and increasing the place of private provision). At present the social costs of choosing to perform socially valuable unpaid carework tend to lie where they fall – on women.

25Governments have been invited to think that work/family reconciliation will address a whole variety of policy problems. For example, the OECD’s (2005) recommendations on work/family reconciliation advise that: “Governments need to get family-friendly policies right if they are to reduce poverty and promote child development and gender equity, underpin economic growth and bolster pension systems.” In fact, some of these goals may be contradictory. While the social psychological evidence on the relationship between childcare and child development is now reasonably firm in advocating that good quality care has positive outcomes for three to four-year-olds, the evidence on the outcomes for the under-twos is much more divided. It could be that the interests of child welfare come into conflict with the desire to maximize female labour market participation in order to underpin economic growth and bolster pension systems. Certainly, different work/family reconciliation policies can provide different incentives to prioritizing work or family. Policy priorities matter hugely in terms of policy design and there is a “politics” of policy development in this field. Indeed, the more conservative, corporatist countries of continental Europe often supported work/family reconciliation in the form of parental leave in order to try to preserve traditional family values and with a view to promoting female labour market exit.

26If gender equality is to be prioritized, and a genuine choice to be given to women and men to engage in both paid and unpaid work, a wide range of policies is required, with close attention to their design. From the point of view of those doing unpaid carework the following are important:

  • Time: working time and time to care
  • Money: cash to buy care, cash for carers
  • Services: for children and for older people
Limits on paid working time are necessary but not sufficient to secure men in particular time to care. For example, French working hours for men are far fewer than in the English-speaking countries and have been significantly constrained (particularly in larger enterprises) by the 35-hour legislation (Fagnani and Letablier, 2004). However, according to ECHP data, fathers in France (in common with those in Greece, Portugal, Italy and Austria) spend low proportions of their time on childcare especially compared to fathers in the Scandinavian countries and in the UK (where fathers are engaged disproportionately in shift-parenting). Crompton and Lyonette (2004) have suggested that this might help to explain the high levels of work/life stress experienced by women in France, despite the high levels of childcare provision. The UK Government is firmly opposed to adopting the 48-hour Working Time Directive, insisting that the option to work flexibly is more important than the total number of working hours. Flexibility is important to carers, although most want and need what might be termed “predictable flexibility” (for example, to be able to fetch children home from school at a particular time) rather than the looser form often favoured by employers. Nor is it clear how progress in eliminating the gendered inequalities in unpaid work can be further eliminated if fathers continue to work very long hours. As Bianchi and Casper’s (2004) US data have suggested, if nothing is done to encourage a reduction in men’s working hours, then women will be unable to choose to increase their hours of employment.

27Time to care is of course intimately linked to providing cash for carers, although, crucially, not all leave schemes are paid. In Finland half as many mothers of two-year-olds engage in paid work as is the case in Sweden, which the OECD (2005) has suggested is associated with the introduction of long (three-year) home-care leave in Finland in 1990. The cash payments introduced in respect of care for one – and two-year-old children in Norway in 1998 resulted in a small decline in women’s employment, although not among highly educated women. Long leaves, together with low compensation, may encourage women who are in low-paid jobs to stay at home to care and tend to result in lower earnings.

28It is particularly hard to devise policies that encourage men to change their behaviour. A recent Eurobarometer (2004) survey of 5,688 men over 18 (EU=15) showed that 84 per cent of the respondents had not taken parental leave and were not thinking of taking it. Workplace cultures may operate to reinforce male stereotypes, although Haas et al. (2002) concluded that the amount of variance in respect of men taking parental leave that was explained by organizational culture was “surprisingly low” (p. 338). If men are to take care leave, the evidence suggests that there must be high compensation levels and also that a portion of the leave must be designated as an individual entitlement for men. The Icelandic division of leave into one-third maternity, one-third paternity and one-third parental is interesting and has resulted in 80 per cent of men taking leave. Scandinavian daddy leave also meets these requirements and has had good take-up rates. However in Denmark, the new Right-wing Government abandoned the policy in 2002 because of the way in which it explicitly tries to change behaviour in the family, which was felt to place restrictions on men’s choices. In fact, first, the daddy leave is a “use it or lose it” policy – it does not compel men to care – and second, given that men’s choices constrain those of women, a policy that attempts to change male behaviour without resorting to compulsion (which would probably prove counter-productive), is to be welcomed by those wishing to promote gender equality. Other dimensions of leave policies are important if they are to encourage take-up by both men and women: the degree of flexibility, for example whether part-time work is possible, and when in the child’s life the leave has to be taken. The UK has both unpaid parental leave and very little flexibility as to when it may be taken. The proportion of men opting for it is infinitesimally small. All member states have underdeveloped leave policies in respect of the care of elderly people.

29Finally, cash to buy care is intimately connected to the provision of services. Since the late 1990s, the trend in Western Europe has been away from the provision of leave and towards the provision of services, in recognition that services provide a more unequivocal incentive to women to enter the labour market, whereas in Eastern Europe the trend has been the opposite. The desire to increase women’s labour market participation (especially of lone mothers in the UK), as well as, to a somewhat lesser extent, to improve early learning, has proved a powerful spur to laggard member states, but one that does not necessarily have much to do with the promotion of gender equality per se. Interestingly, the European Parliament’s Women’s Committee expressed the view that without a legally-binding (“hard”) instrument, member states with a poor record on the provision of childcare services would do nothing. This has not proved to be the case, with, for example, both Germany and the UK creating about 600,000 childcare places since 1996/7. However, the proportion of costs of childcare services paid by parents varies enormously between countries, from 11 per cent in Sweden, to around 20-25 per cent in the German Lander, and 45 per cent in the UK. In the UK, the literature on the household division of resources has long shown the extent to which responsibility for childcare remains with women even when they go out to work, with the result that paying for someone else to care for children tends to be an expense that women meet out of their earnings. Thus the high cost of childcare tends to dissuade British women from full-time employment, unless they are highly educated and highly paid.
It is difficult for policies designed to “reconcile” work and family responsibilities to actually strike a balance in terms of the incentives to work and to care for both men and women. Yet, the Employment Options of the Future survey, sponsored by the European Foundation for the Improvement of Living and Working Conditions carried out in the Summer of 1998 and covering 30,000 people aged 16-64 who were either working or intending to take up work during the following five years, showed large gaps between the average hours worked and preferred hours for men and women. The vast majority of respondents in all countries preferred a dual-earner model family, very few preferred the male breadwinner model family (the highest percentage being in Spain with 20 per cent – but compared to the 57 per cent actually experiencing this pattern) (OECD, 2001, Table 4.3). In fact 71 per cent of all respondents wanted to work a 30-40 hour week, with convergence between male and female respondents towards a preference for long part-time working. However, in all probability, respondents assumed all other things – particularly income – to be equal. Nevertheless, there may be increasing support for the recommendation made by Nancy Fraser (1997), on the basis of a philosophical analysis and Janet Gornick and Marcia Meyers (2003) on the basis of their empirical analysis of work/family reconciliation policies for a move towards a universal citizen worker/carer model. The Netherlands is the only country to have made this official policy, via the Combination Scenario, which envisages part-time work and part-time care as the desired pattern for men and women. But implementation has proved difficult and while part-time employment rates for men in The Netherlands are the highest among EU member states (11 per cent), the men involved are for the most part not the fathers of young children.
However, if gender equality is to be actively pursued, more attention must be given to ways of promoting a citizen worker/carer model family, rather than the adult worker model that is seemingly rapidly replacing the male breadwinner model in the assumptions that are made by policymakers. Bonoli (2004) has argued that family and labour market change has created a new set of social risks. Certainly, the old forms of social protection that characterized the post-war settlement based on the regularly employed male breadwinner and stable families are hard to sustain. Family policies and policies to address carework have been areas of policy expansion in EU member states in recent years, however the instrumentalist nature of policy-making, harnessed to what has become “employment-anchored” social policy (O’Connor, 2005) is not likely to effectively address the issue of gender equality.


  • [*]
    Professor of Social Policy at the LSE and a Fellow of the British Academy.
  • [1]
    Other dimensions of inequality particularly in respect of “voice” and political participation, and sexual harassment and violence are also fundamental, and many would argue that “social protection” or “women’s welfare” broadly defined should include consideration of them. However, I do not have the space to do so in this piece.
  • [2]
    This paper draws on research carried out under ESRC grant no. 225-25-2001. Part I draws on “Work/family reconciliation, equal opportunities and social policies: the interpretation of policy trajectories at the EU level and the meaning of gender equality”, Journal of European Public Policy (2006) 13 (3): 420-437.


The promotion of gender equality requires policymakers to define the goal: equality as ‘sameness’ (to men), or more recognition of ‘difference’, particularly in relation to motherhood and the unpaid work of care. The problem of progressing gender equality has become more pressing with rapid family and labour market change, and with the trend in welfare state restructuring since the 1990s, which has emphasised the importance of all adults being active in the labour market.
This article explores first, the development of policy at the EU level, where there has always been an explicit commitment to gender equality, and shows that it has proved difficult to keep the goal of gender equality in the centre of the policy agenda. In addition, as section II shows, the policy approaches of member states vary hugely; their policy logics are profoundly different. The article concludes by suggesting that if gender equality is to be prioritised, and a genuine choice to be given to women and men in relation to both paid work and care work, a wide range of policies relating to carework in particular are needed, and that these must address men as well as women.


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Jane Lewis [*]
Professor of Social Policy at the LSE and a Fellow of the British Academy. She has long-standing research interests in family policy, gender and welfare regimes, and the relationship between paid and unpaid work.
  • [*]
    Professor of Social Policy at the LSE and a Fellow of the British Academy.
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