On March 10, 2026, the first day the so-called yellow envelope law took effect, unionized subcontracted workers targeted major firms like POSCO, Hyundai Mobis and Hanwha Ocean, demanding negotiations over wages and working conditions. Unions threatened strikes if talks are refused, while companies expressed caution within legal bounds.
The yellow envelope law, amendments to Articles 2 and 3 of the Trade Union and Labor Relations Adjustment Act, took effect on March 10, 2026, after a six-month grace period. The law expands the definition of an employer to include principal contractors exercising significant control over subcontracted workers' conditions, even without direct contracts, obligating them to negotiate.
On that day, unionized subcontracted workers from the Korean Metal Workers' Union protested outside POSCO Center in Seoul, urging the steelmaker to join collective bargaining. POSCO has faced Supreme Court rulings deeming its use of outsourced labor illegal at plants in Pohang, North Gyeongsang Province, and Gwangyang, South Jeolla Province. Workers demanded direct employment for regular tasks and an end to discrimination. A union representative said, “POSCO should apologize for the illegal use of subcontracted workers and take part in talks to convert them into full-time employees.”
The union of Hyundai IHL, a Hyundai Mobis subsidiary supplying car lamps, rallied outside the parent firm's Seoul headquarters, opposing the planned sale of the lamp business to France’s OPmobility announced earlier this year for business streamlining. Expressing job security concerns, they demanded direct wage talks. The union stated, “Hyundai Mobis is our real employer.”
Subcontracted workers at Hanwha Ocean delivered a letter after a march organized by the Korean Confederation of Trade Unions in downtown Seoul, demanding the shipbuilder join wage negotiations. They urged bonus payments to employees of Welliv, which runs cafeterias and amenities at the Geoje Island shipyard, after Hanwha Ocean excluded non-in-house subcontractors. The Welliv union said, “Our negotiations with Hanwha Ocean should mark the beginning of the revised Trade Union Act taking root.”
The Korean Confederation of Trade Unions (KCTU) has sent bargaining notices for nearly 140,000 subcontracted workers and plans protests next month if refused. A KCTU official told The Korea Times, “In line with the purpose of the law, the real employer must come forward... If the real employer still refuses, we are planning protests that will directly target them next month.” The Federation of Korean Trade Unions (FKTU) emphasized protecting over 7 million precarious workers, per Secretary-General Ryu Ki-seop.
The conglomerates remained cautious, stating they would hold talks within legal boundaries. An insider said, “Each company is trying to avoid being the first to sit down with subcontracted workers.” Business group Korea Enterprises Federation called for objective determinations by the government and labor commission. A day earlier, KG Steel absorbed two subsidiaries for managerial efficiency, seen as preempting disputes.
