On October 10, the revised Yellow Envelope Law (Labor Union and Labor Relations Adjustment Act) will come into effect, allowing subcontractor unions to form a separate bargaining structure from primary contractor unions when negotiating collective agreements with the latter. This marks a significant shift in the government's previous stance, which sought to unify the negotiation channels for primary and subcontractor unions into a single bargaining unit based on workplace conditions. The Ministry of Employment and Labor, in collaboration with the Central Labor Relations Commission, announced this new procedure during a briefing at the Government Seoul Building in Jongno-gu, Seoul.

The manual stipulates that all subcontract workers will be viewed as a single bargaining unit, and when negotiating with primary contractors, a unified negotiation process among subcontract unions is required. However, the labor committee retains the discretion to subdivide the bargaining units based on specific factors, including job roles, labor organizations, and characteristics of the subcontractors. Despite the separate negotiations for subcontractor unions being established, primary contractors and their unions will still negotiate as distinct entities, reflecting the fundamental differences between them, according to Minister of Employment and Labor Kim Young-hoon.

The manual further states that if a subcontract union requests negotiations, the primary contractor must publicly announce this request to all internal subcontract unions so that they are informed. It also emphasizes the need to extend this announcement to external subcontracts if there is any potential recognition of the user's role. However, the labor community has criticized the retention of 'unified negotiation channels,' with some labor organizations arguing that the structures still impede true representation and fairness in labor negotiations.