Labor Relations Commission Receives 31 Applications for Bargaining Unit Separation
KCTU Submits 357 Requests, FKTU Submits 42
Government Vows "Prompt Decisions, Minimize Initial Confusion"

On the first day of enforcement of the Yellow Envelope Act (amendments to Articles 2 and 3 of the Labor Union and Labor Relations Adjustment Act), more than 400 demands for collective bargaining by subcontractor unions with their respective principal companies were filed, throwing industrial sites into confusion. Observers say that the business community's concerns about a "bargaining crisis," which had been raised even before the law took effect, are now becoming a reality.


According to the Ministry of Employment and Labor, on March 10—the first day the Yellow Envelope Act went into effect—407 subcontractor unions, branches, or chapters submitted requests for collective bargaining to 221 principal workplaces. The total number of union members involved was approximately 81,600. Of these, 143 were in the private sector and 78 were in the public sector. Notably, on the same day, the labor commissions received 31 applications for "bargaining unit separation," increasing the risk of labor-management conflict from the very start of the new system.

On the first day of enforcement of the "Yellow Envelope Act" (Amendment to Articles 2 and 3 of the Trade Union and Labor Relations Adjustment Act) on the 10th, members of the Korean Confederation of Trade Unions shouted slogans at the declaration rally held in Sejong-ro, Seoul. Photo by Yonhap News Agency

On the first day of enforcement of the "Yellow Envelope Act" (Amendment to Articles 2 and 3 of the Trade Union and Labor Relations Adjustment Act) on the 10th, members of the Korean Confederation of Trade Unions shouted slogans at the declaration rally held in Sejong-ro, Seoul. Photo by Yonhap News Agency

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407 Subcontractor Unions Demand Bargaining... KCTU Accounts for the Majority

By union affiliation, the Korean Confederation of Trade Unions (KCTU) accounted for the majority. Under the KCTU umbrella, 357 subcontractor unions (with 67,200 union members) demanded bargaining from 218 principal workplaces. By industrial sector, the Korean Metal Workers' Union submitted bargaining requests for 36 subcontractor branches or chapters (containing 9,700 union members) at 16 major manufacturers, including Hyundai Motor Company, Hyundai Mobis, Hyundai Glovis, HD Hyundai Heavy Industries, Hanwha Ocean, and GM Korea.

407 Bargaining Requests Flood In on First Day of Yellow Envelope Act... "Concerns Become Reality" View original image

The Korean Construction Workers' Federation (with 17,000 union members) also requested bargaining with 90 principal workplaces, including Hyundai Engineering & Construction and Hyundai Engineering. Demands for bargaining also continued in the service and public sectors. The Public Transport Workers’ Union filed bargaining requests at workplaces employing indirectly hired workers, such as call centers and university janitorial staff—including janitorial labor organizations at Yonsei University and Korea University.


Subcontractor unions, branches, or chapters affiliated with the Federation of Korean Trade Unions (FKTU) filed requests for bargaining with 42 organizations (9,200 union members) across 9 principal workplaces. The targets for bargaining included POSCO, Coupang CLS, Seoul Metro, Korea Railroad Corporation, and Incheon International Airport Corporation. Additionally, several non-affiliated subcontractor unions (not belonging to any umbrella organization) also submitted bargaining demands. At five principal companies—Hanwha Ocean, POSCO, Coupang CLS, Busan Transportation Corporation, and Hwaseong City—the bargaining process began immediately.

407 Bargaining Requests Flood In on First Day of Yellow Envelope Act... "Concerns Become Reality" View original image

"Request for Ruling on Employer Status"... 31 Applications for Bargaining Unit Separation

On the same day, subcontractor unions and others filed a total of 31 "bargaining unit separation" applications with the labor commission. Bargaining unit separation is a process in which multiple unions at the same workplace apply to the labor commission to be recognized as separate bargaining units. The commission first determines whether the principal company qualifies as an employer before deciding on the separation. If employer status is recognized, a separate process for unifying the bargaining channels within that unit proceeds, thereby ensuring that subcontracted workers have practical bargaining rights—the main purpose of the amended law.


With hundreds of bargaining demands and dozens of bargaining unit separation applications filed on the first day, concerns about confusion in the workplace are mounting. Cho Chunghyun, Director of Labor-Management Cooperation Policy at the Ministry of Employment and Labor, stated, "When requests for authoritative interpretation—such as whether an employer status is recognized—are received from the field, we plan to provide swift decisions through expert consultation. We will also make accumulated case studies publicly available to reduce initial confusion at worksites."


The government announced that, as it is still early in the implementation of the amended law, it will continue to monitor conditions on the ground and regularly release related information. The goal is to enhance transparency in bargaining processes and foster trust between labor and management. In particular, for bargaining topics raised by subcontractor unions where the principal company's employer status is acknowledged, support for on-site bargaining will be strengthened through dedicated teams at local labor offices to ensure smooth negotiations.


Furthermore, if requests for authoritative interpretation regarding employer status arise, the "Collective Bargaining Decision Support Committee" will swiftly issue rulings. The results of accumulated expert consultations will also be released regularly to improve predictability in the system’s operation.


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Kim Younghoon, Minister of Employment and Labor, said, "As the first steps toward mutually beneficial bargaining in accordance with the law and due process—such as public announcements of bargaining demands and bargaining unit separation—have now begun, the government will also responsibly support the stable settlement of labor union law in the field."

Kim Younghun, Minister of Employment and Labor, attended the Emergency Economic Ministers' Meeting held on March 11 at the Government Seoul Complex in Jongno-gu, Seoul, and made remarks related to retirement pensions.  Photo by Jo Yongjun

Kim Younghun, Minister of Employment and Labor, attended the Emergency Economic Ministers' Meeting held on March 11 at the Government Seoul Complex in Jongno-gu, Seoul, and made remarks related to retirement pensions. Photo by Jo Yongjun

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