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CLB has lodged a formal complaint with Germany’s Federal Office for Economic Affairs and Export Control (BAFA), calling on the regulator to ensure that Volkswagen AG fulfil its obligations under the German Supply Chain Due Diligence Act (LkSG). The case centres on allegations of labour rights violations by one of Volkswagen’s Chinese suppliers, Qiao Feng Technology Industrial (Shenzhen) Co., Ltd.
Qiao Feng, headquartered in Shenzhen, is one of China’s leading manufacturers of plastics and moulds, offering services ranging from structural design to mould production, plastic parts manufacturing, and assembly. Volkswagen is listed among its clients. In early 2024, Qiao Feng announced plans to relocate its operations from Shenzhen to Heyuan, in Guangdong province. However, the company failed to consult with its employees adequately or provide the legally mandated compensation and unpaid social insurance contributions required under Chinese labour law.
In response, workers staged a protest in March 2024, protesting the forced relocation and insufficient compensation. The company retaliated by dismissing two strike leaders, Tian Youliang and Long Yunyi, raising serious concerns about violations of workers' fundamental rights, including the right to freedom of association and collective bargaining. For detailed information on this case, see CLB’s previous coverage and report.
CLB first brought the case to Volkswagen on 19 June 2024, urging the German automaker to investigate potential breaches of Chinese labour laws and LkSG. Volkswagen initially responded on 24 June 2024, acknowledging the seriousness of the allegations. The company stated, "After reviewing your report, we came to the conclusion that the supplier might have violated the German Supply Chain Due Diligence Act," promising further investigations and actions.
However, on 11 February 2025, Volkswagen abruptly reversed its stance. In its latest response, Volkswagen claimed that "non-controlled entities are not within our scope,” and declared the grievance process closed, effectively absolving itself of responsibility for Qiao Feng’s actions.
CLB argues that Volkswagen’s interpretation of LkSG is fundamentally flawed. The law explicitly defines the supply chain as encompassing "all steps in Germany and abroad that are necessary to produce the products and provide the services, starting from the extraction of raw materials to delivery to the end customer." This includes the activities of both direct and indirect suppliers, regardless of whether they are “controlled” by the company.
In its formal complaint to BAFA, CLB has called on the regulator to ensure that Volkswagen adheres to its legal obligations. We argued that excluding non-controlled entities, such as Qiao Feng Technology, undermines the very purpose of the law, which is to safeguard human rights throughout global supply chains. CLB has urged BAFA to compel Volkswagen to reopen its investigation and take concrete steps to address the alleged violations.