There seems to be a paradox: The use of flexible working hours (i.e. variable hours) is more widespread in Germany than in Denmark, yet at the same time the discussion on the need for further flexibilisation of working hours is also more prevalent in Germany than in Denmark. In order to answer to this paradox a qualitative study of working time regulation in the metal industry in Denmark and Germany was performed in the spring of 2005. In addition to five case studies of company-based agreements in Denmark and Germany (Baden-Württemberg) the study consisted of analysing statistical data, legislative information, collective agreements and interviews with representatives from tradeunions and employers' associations in Germany and Denmark.

Based on our preliminary findings three explanatory theses for further research are developed in the article: 1) The level of specification, i.e. the level where the framework agreements on variable hours are specified, is more decentralised in Denmark and allows an adjustment of working time closer to the single employee. 2) Both in the German and Danish metal sectors company-based agreements regulate the growing use of flexible working hours. Though the trade union response to this pressure from the company level can be described as a form of organised decentralisation in both countries, the response within the Danish collective bargaining system can be characterised as a proactive organised decentralisation while the response of the German system should rather be while the response of the German system should rather be interpreted as a reactive organised decentralisation. 3) The varying regulation of working time flexibility in Germany and Denmark implies varying risks in the regulation. In Germany lacking competencies in small or medium-sized companies lead to unbalanced trade offs. In Denmark the strong decentralisation combined with a lacking demand on +/- hours limits for time banks without reference periods seems to impose risks for certain groups of employees who, regardless of company size, can have extraordinary long working hours violating the 48-hour rule.

The article is based on a pilot-study launched in the first phase of a three-year research project on the efficiency of Danish labour market regulation in an international comparative perspective. In this context "efficiency" refers to both economic competitiveness and the ability to create jobs i.e. security for employees.