China Labour Bulletin (CLB) has conducted a preliminary investigation and identified potential labour law violations involving several Tesla China suppliers. These alleged practices fall into three common categories of labour law non-compliance, raising serious concerns about workers’ rights.
- Excessive working hours: Tesla's Shanghai Gigafactory and its suppliers may require workers to work extended hours, with shifts reportedly reaching up to 12 hours per day, 6 to 7 days per week. This could result in monthly overtime exceeding up to four times the legal limit of 36 hours as stipulated by the Labour Law of the People’s Republic of China.
- Wage withholding: Some Tesla suppliers may withhold wages unless workers complete a required number of hours or days. If confirmed, such practices could be interpreted as coercive labour practices, raising concerns about forced labour or modern slavery.
- Trade union interference: Some Tesla suppliers may improperly influence or control trade unions, which could infringe on the Trade Union Law of the People’s Republic of China.
Complaints Filed Against Tesla Suppliers
CLB has filed complaints with local Human Resources and Social Security Bureaus in the jurisdictions where the alleged violations occurred. Two Tesla suppliers have been named in these complaints.
1.Huayu Automotive Systems Co., Ltd. (SH600741) and Subsidiary Yanfeng Automotive Trim Systems Co., Ltd.
CLB’s complaint outlines several alleged labour law violations, including:
- Improper implementation of the comprehensive working hour system: The factory may not meet the conditions specified in Article 5 of the "Approval Procedures for the Implementation of Flexible Working Hours System and Comprehensive Working Hours Calculation System in Enterprises" issued by the Ministry of Human Resources and Social Security.
- Excessive Overtime: Workers reportedly earn between 7,000–8,000 yuan per month, but to achieve these wages, they must work 73-93 hours of overtime per month for 7,000 yuan, and 99-132 hours for 8,000 yuan. These figures significantly exceed the legal overtime limit of 36 hours per month, violating China’s Labour Law.
- Wage withholding: Workers are reportedly required to meet a minimum of 36 hours of work after being hired to receive wages. Failure to meet this requirement results in forfeiture of wages. CLB’s complaint describes this practice as a potential form of forced labour or modern slavery.
Screenshot of CLB's complaint filed with the Shanghai Human Resources and Social Security Bureau
Johnson Electric (0179.HK) and Subsidiary Johnson Electric (Shenzhen) Co., Ltd.
On December 5, 2024, CLB filed a complaint with the Bao’an, Shenzhen Human Resources Bureau regarding alleged labour law violations by Johnson Electric (Shenzhen) Co. Ltd. The complaint highlighted excessive overtime and wage withholding at the factory.
In response, on December 19, 2024, the Bao’an Human Resources Bureau issued a "Notice of Rectification for Violations" to the factory in connection with its illegal overtime practices.
"Notice of Rectification for Violations" issued by Bao'an, Shenzhen Human Bureau of Resource to Tesla supplier Johnson Electric (Shenzhen) Co., Ltd. on December 19, 2024
"Statement of Handling Opinions" issued by Bao'an, Shenzhen Human Bureau of Resource in response to CLB's complaint on January 6, 2025.
Ongoing Monitoring and Additional Complaints
Despite the rectification notice, CLB has continued to monitor the situation and filed an additional complaint with the Bao'an Human Resources Bureau on February 19, 2025. The new complaint raised the following issues:
- The Tesla supplier is reportedly continuing to implement a "two-shift" work system.
- Workers’ monthly income is reported to range from 5,500–8,000 yuan. Based on these figures, total monthly working hours could reach up to 366 hours, with overtime potentially reaching 192 hours per month - four times the permissible limit under Chinese labour law.
In this complaint, CLB recommended the following actions:
1. Conduct random inspections of the Tesla supplier to verify whether the factory has ceased its illegal practice of withholding wages for workers employed for less than seven days.
2. Strengthen enforcement measures to ensure compliance with labour laws and take further legal action against the Tesla supplier for its continued violation of overtime regulations.
Complaint Filed with Germany’s BAFA
On 20 February 2025, CLB sent an email to the German Federal Office for Economic Affairs and Export Control (BAFA), the authority responsible for overseeing corporate compliance with the German Supply Chain Act (LkSG). This email lodged a complaint regarding alleged labour law violations by Tesla suppliers in China, urging BAFA to investigate the suppliers’ compliance with international labour standards.
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CLB’s ongoing actions
The allegations against Tesla China and its suppliers highlight significant concerns about labour law compliance and workers’ rights within its supply chain. Despite some corrective actions, reports of ongoing violations underscore the need for stricter enforcement and accountability. As CLB continues to monitor and file complaints with both local and international authorities, this case serves as a critical reminder for multinational corporations to uphold labour standards and ensure ethical practices across their global operations.