From the inception of the European Community until the adoption in 1986 of the Single European Act (hereinafter SEA) the concept of free movement was directed exclusively toward the factors of production, i.e., labor, business, and capital. Prior to SEA, workers were primarily viewed as mere tools of production and their exercise of rights under the EC Treaty was within that economic context. The SEA introduced a more encompassing view from an individual engaged in free movement as a factor of production, i.e., a worker, to the free movement of a worker as a free movement of a person now appearing as Article 14 (ex Article 7a) of the EC Treaty, which states:The movement from viewing an individual as a tool of production to a person with inherent rights was taken one step further with the adoption of individual citizenship status within the EU. Citizenship within the EU occurred as a result of the Treaty on the European Union (hereinafter TEU), commonly called the Maastricht Treaty, signed in February 1992 and entered into force on November 1, 1993. The Treaty provides:and…Every citizen of the Union shall have the right to move and reside freely within the territory of the Member States, subject to the limitations and conditions laid down in this Treaty and by the measures adopted to give it effect.While taking thirty-five (35) years to recognize by Treaty the inclusion within the concept of free movement of tools of production, EU citizenship, various efforts moving in that direction occurred during and after this extended transition period. One of the events came three (3) years after the adoption of the SEA with the Charter of Fundamental Social Rights for Workers (hereinafter the Social Charter) in 1989.The Social Charter was initially promoted in 1988 by then EC Commission President Jacques Delors to ensure that workers in the EC would benefit as much as employers from a fully functioning single market.