The 'Yellow Envelope Law' (revised Labor Union and Labor Relations Adjustment Act) enforcement ordinance has been approved by the State Council, wrapping up preparations for the law set to take effect on November 10. The Ministry of Employment and Labor announced on the 24th that the revised enforcement ordinance had been reviewed and approved during the State Council meeting. Beginning on the law's enforcement date, the ordinance will specify the criteria for negotiations involving subcontractors and primary contractors by considering the characteristics of subcontractor unions.

The revised enforcement ordinance provides guidelines for separating or integrating negotiating units for subcontractor unions during negotiations with primary contractors. It emphasizes that the commonality or similarity of interests among unions and the appropriateness of representation by other unions should take precedence in decisions regarding negotiating unit separation or integration, rather than the differences in working conditions or employment methods. This update addresses concerns about employers potentially forming 'fake unions' to infringe upon negotiation rights, although it retains the criticized framework of 'single window for negotiations' from the labor sector.

Additionally, the ordinance allows for an extension of decision-making periods by the Labor Relations Commission to 10 days if the primary contractor fails to properly announce or misrepresents the negotiation requests from subcontractor unions. The Labor Ministry also confirmed the 'interpretation guidelines' for the revised labor law, strengthening the explanation of the 'structural control' concept to clarify the criteria for determining employer-employee relationships. The ministry specifies that the overall control exercised by the employer over collective worker rules or systems can be recognized even without direct instructions to individual workers, potentially easing the strict requirements previously seen in arrangements like dispatching.