Women in the European Community, who already have paid maternity leave, would be guaranteed at least 14 weeks on full pay under legislation being considered by the European Parliament.
The proposal contrasts sharply with policy in the United States, which has no federal law granting maternity leave - paid or unpaid - or guaranteeing a job on return.The European Parliament's committee on women's rights last week passed a draft directive that would give pregnant working women a minimum of 14 weeks' maternity leave at full pay.
The directive also bars dismissals linked to pregnancy and would provide two weeks' compulsory rest before birth. Benefits would apply to women working full or part time.
All 12 European Community members already provide some form of paid maternity leave, but British women have the most to gain.
Under existing British law, women are entitled to six weeks' leave at 90 percent of regular pay, followed by 12 more weeks at $74.50 per week.
French women, by comparison, have 16 weeks' leave at full pay. Germany grants 14 weeks at full pay, and Denmark offers 28 weeks at 90 percent pay.
In the United States, 30 states have laws granting unpaid leave from six weeks to one year.
"It's not a question of pay. We're the only Western industrialized country that does not permit job-protected leave," Rep. Patricia Schroeder, D-Colo., said in a telephone interview from Washington.
She was the prime sponsor of the Family and Medical Leave Act, which will be reintroduced in the next session of Congress. She said the European legislation will increase congressional determination to see it made law.
The Bush administration, in vetoing the Family and Medical Leave Act, argued that it was not the government's role to dictate how private industry dealt with employees.
The European directive will be considered by Parliament during its next full session, which begins on Monday. It then goes to the EC Council of Ministers for approval. If approved, it has the force of law throughout the European Community after Dec. 31, 1992.