Free China

RAPID RESPONSE | September 5, 2026 | P5-EVT-2026-0904-18

“996” schedules can violate overtime law in Mainland China, but unlawful overtime is not automatically forced labour. International forced-labour standards require coercion, menace of penalty and a lack of genuine voluntariness.

Authorities should enforce overtime protections and protect workers from retaliation. Companies and importers should examine threats, document retention, recruitment debt, wage withholding and whether workers can actually leave.

The EU product-ban regime should be applied on evidence connecting forced labour to specific products and supply chains, not by collapsing every labour-law violation into the forced-labour category.

News + Editorial: Mainland China’s ‘996’ Overtime, Forced Labour and the EU Product-Ban Rule: What the Law Actually Requires
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