NEWS + EDITORIAL | September 5, 2026 | P5-EVT-2026-0904-18
Mainland Chinese legal authorities have long stated that a 9 a.m.–9 p.m., six-days-a-week “996” schedule can violate statutory overtime limits. But excessive or unlawful overtime is not automatically forced labour under international standards. Forced labour requires work extracted under menace of penalty and without genuine voluntariness.
The European Union’s Forced Labour Regulation creates a product-based prohibition on goods made with forced labour and will become fully applicable in December 2027. Its enforcement turns on evidence linking forced labour to products and supply chains. It is not a general EU complaint channel for every unlawful overtime dispute.
Free China Editorial
Worker protection requires both accurate legal categories and effective enforcement. Mainland authorities should enforce overtime limits, protect workers from retaliation and allow independent reporting of abuses. Companies and importers should examine coercion, recruitment fees, document retention, threats, wage withholding and inability to leave—not merely hours worked—when assessing forced-labour risk. The EU should publish clear evidentiary standards and enforcement outcomes as its product-ban regime begins.
Legal baseline: EU Regulation 2024/3015; ILO forced-labour standards; Mainland Chinese overtime-law guidance and court/MHRSS materials.
Free China 