Can trade union representatives be the appropriate representatives for collective redundancy consultation purposes where the affected employees are not union members?

Yes. In accordance with s.188(1B) of the Trade Union and Labour Relations (Consolidation) Act 1992, it does not matter if none of the affected employees are members of the trade union; as long as the union is recognised to conduct collective bargaining in respect of employees of their description, the employer is required to consult with the union about the proposed redundancies.

If one or more affected employees belong to a grade or class of employees for which no union is recognised to conduct collective bargaining, the employer must instead consult with existing employee representatives, or employee representatives who are elected specifically for the purpose of consultation on the redundancies, in respect of those affected employees.