This article surveys the differing approaches of the US and the EU on trade and labor linkage and evaluates the extent to which either model has had a meaningful impact on the protection of workers’ rights in the territory of their trade partners. It finds that pre-ratification leverage has resulted in legislative reforms, particularly as demanded by the US, though post-ratification efforts have been much less successful. The article identifies the possible reasons therefore and concludes with recommendations to overcome these weaknesses in the context of the US-EU bilateral trade agreement negotiations for the proposed Transatlantic Trade and Investment Partnership.