Chinese workers are looking at Brussels.Radio Free Asia on September 4With the EU’s Forced Labour Regulations coming into effect in December 2027, more and more Chinese employees are beginning to discuss whether to submit evidence to the EU if overtime, refusal of overtime is reduced, dismissed or punished, and whether to investigate or even ban products in the European market. The video playback of the EU reporting website “EU reporting procedures” has exceeded 200,000, showing that the system originally belonged to trade and supply chain regulation is being understood by Chinese workers as a new external defense tool.

This is a very symbolic change: when domestic labor laws are not able to protect workers effectively for a long time, workers begin to expect foreign market rules to restrict their. The so-called “996” is not a new issue. China’s Supreme People’s Court and the Ministry of Social Affairs have already made it clear that the fixed overtime work pattern for nine nine nights and nine or six days a week violates working hours.

原始来源 · rfa.org自由亚洲电台:“996”能举报到欧盟吗?rfa.org ↗

From Overtime Disputes to Supply Chain Risks

The recent employment dispute has warmed this discussion.RFA that Starbucks has recruited 440 graduates this year, then terminated labor contracts with 107 of them, and the local people's society department criticized the company's "simple tough" negotiation method, and the enterprise apologized publicly after. On September 1, Volkswagen announced the launch of a special investigation into this supplier. While corporate review is not equivalent to EU forced labor enforcement, it has illustrated a reality: Labor problems inside Chinese factories are being transmitted through the global supply chain to the compliance system of multinational brands.

In the past, companies could interpret overtime labor as “Chinese-style struggle”; in the future, once labor conditions affect products to enter the European market, it could escalate from corporate cultural issues to trade risks.

布鲁塞尔欧盟委员会总部前的欧盟旗帜。|来源:European Commission
布鲁塞尔欧盟委员会总部前的欧盟旗帜。|来源:European Commission

The EU Forced Labour RegulationThe key is not to stipulate that employees work several hours a day, but rather to prohibit the use of forced labour products from entering the EU market. The ILO’s core definition of forced labour is that workers are not voluntarily providing work under the threat of punishment. Therefore, the mere “long hours” are not sufficient to automatically constitute forced labour; but if employees refuse to work overtime, they will face dismissal, reduction of salary, depreciation, limitation of leave or other substantial punishment, the problem will go into a more dangerous jurisdiction.

What Chinese companies are really afraid of is not complaints, but evidence chains.

The EU rules provide a path completely different from traditional Chinese labor arbitration. It is not for an employee to recover overtime fees, but to track whether goods are associated with forced labor. If regulators form reasonable doubts, they can investigate companies, products and supply chains; after final confirmation, related goods may be banned from selling, importing or exporting and required to withdraw.

For workers, what is really valuable is not a sentence “We 996 every day” but the ability to form verifiable material. The evidence listed in the EU Commission guidelines includes employee testimony, labor contracts, salary and financial records, emails, schedule information, and workplace photos and videos.In other words, the most difficult variable in future Chinese factories may not be workers’ public protest, but a large number of internal labor records are systematically submitted to overseas regulators.

This will put three levels of pressure on the export manufacturing industry:

富士康工厂电子装配线工人资料图。|来源:The Business Times
富士康工厂电子装配线工人资料图。|来源:The Business Times
  • Brand pressure: International brands such as Volkswagen, Apple, Nike will intensify audits to avoid supply chain risks and require suppliers to rectify;
  • Market pressure: Once products are linked to compulsory labor issues, may lose the European market directly;
  • Finance and reputation pressure: Labor disputes may further affect ESG ratings, investor decisions and long-term orders.

“Low-cost advantages” cannot always be based on workers’ right of concession.

China's manufacturing has long relied on complete supply chains, infrastructure and scale effects to build competitiveness, but low wages, overtime labor and labor pricing capacity have also represented hidden cost advantages. In the past, this cost was mainly borne by Chinese workers; now, the EU and the United States are increasingly inclined to write labor, human rights and supply chain transparency into trade rules, which is equivalent to recounting part of the cost originally pressed inside the factory into international trade.

This is an embarrassing policy contradiction for Beijing.On the one hand, the Chinese government wants to expand exports and maintain manufacturing competitiveness; on the other hand, it lacks a truly independent trade union system, and the collective bargaining capacity of workers within the enterprise is very limited. When the country lacks effective labor balancing mechanisms, external market regulation naturally fills this vacuum.

According to Focus China, “Can 996 report to the EU?” is really worth concerning, not a reporting entry, but Chinese labor governance is being reversed by global trade rules. Chinese companies can continue to emphasize efficiency, hard work and competition, but if this efficiency is based on overtime labor that employees cannot freely reject, then it will sooner or later become export costs.

When Chinese workers began to see Brussels as a possible subject of appeal, Beijing really needed to reflect not on whether the EU was “interfering,” but on why domestic workers would rather trust distant foreign regulators than their neighboring unions, labor surveillance and judicial systems.

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