The Ethical Toy Program, which covers more than half of toy factories in the country, is strengthening its social auditing criteria and improving communication with workers but denies allegations of labour abuses from an NGO. Terry Slavin reports

China makes around 75% of all the toys in the world, and nine in 10 of the toys sold in the US. Focused mainly around the coastal area of Guangdong, this $30bn industry employs some six million mainland workers.

The toy sector was early to move manufacturing into China. And the problems came almost simultaneously. For the past 18 years the toy sector has been implicated in research into human rights abuses such as child labour.

China Labor Watch said even companies that have promised to uphold human rights “continue to blatantly violate the rights of workers

Many of these allegations come from New York based NGO China Labor Watch (CLW), which describes the toy industry as “one of the worst industries in terms of labour rights” and regularly conducts undercover investigations.

In an investigation last year of four toy factories primarily supplying western brands, including Mattel (see How Mattel’s quick move rescued Barbie), Walmart and Disney, China Labor Watch said even companies that have promised to uphold human rights “continue to blatantly violate the rights and interests of workers who manufacture their products”.

It said workers in all four factories were putting in more than 80 hours in overtime a month, CLW also reported exposure to toxic chemicals with inadequate protective equipment, sub-standard conditions in the dormitories where the workers, who are mainly internal migrants from elsewhere in China, live, and incidents where workers had committed suicide.

Nearly 75% of the world's toys are made in China. (Credit: Mikhail Rulkov/Shutterstock)

All four factories are certified by the Hong Kong headquartered Ethical Toy Program (formerly ICTI Care), which, since it was set up in 2004, has worked collaboratively with thousands of toy factories, brands, licensors and retailers to establish a global standard for ethical toy manufacture. Its social compliance and certification program covers more than half the industry in China.

Mark Robertson, senior vice-president of communications and stakeholder engagement at the Ethical Toy Program, said his organization “fundamentally disagrees” with CLW’s assertion that the toy industry is amongst the worst in terms of labour rights.

“The toy industry continues to lead other industries by delivering transparency and progress on key issues such as working hours, wages and overtime, [and] maintaining high labour standards even during highly seasonal production cycles.”

Some of the issues raised are valid and of concern to us, and we continue to work with each factory to address these

He added that at more than two-thirds of the toy factories in its programme maximum working hours are limited to 66 or 60 hours per week. “We continue to work across the toy industry to seek further reductions in working hours, and in August 2018 we will introduce a six-hour reduction in our maximum weekly working hour limit.”

And while the programme welcomed “any robust investigation that increases understanding of working conditions at toy factories”, the Ethical Toy Program's own investigations into the allegations in the latest report, through interviews with workers and onsite visits, had not found evidence to support the majority of CLW’s allegations.

Some of the issues raised by CLW, however, “are valid and of concern to us, and we continue to work directly with each factory to address these”.

Ethical Toys Program creates family-friendly spaces in factories. (Credit: Ethical Toy Program)

Robertson said these included the need to strengthen communications within factories so that policies and management systems are communicated more effectively to frontline workers.

And while the programme’s existing audit checklist covers dormitory conditions, issues raised by CLW’s investigations have resulted in strengthened requirements for factory owners in a new audit checklist that the programme plans to publish within the next few weeks, the result of a detailed public consultation process last year.

The programme is providing family-friendly spaces in some factories to reunite migrant workers with their children

As well as strengthening criteria for certification in a number of areas, he said, “we are evolving our audit checklist from a pass/fail to a risk-rated approach” in line with the UN Guiding Principles on Human Rights.

One way the Ethical Toy Program is trying to improve communications with workers is by piloting the use of worker voice technology at 50 different toy factories in China, using an app developed by Shanghai-based start-up Microbenefits.

The app, which workers will download onto their own phones, will allow companies to communicate directly with staff and get anonymized feedback at scale.

Mark Robertson of Ethical Toy Program.

The programme is also working to improve conditions for its predominantly female labour force with family-friendly spaces in some factories to reunite migrant workers with their children during the summer months, and by offering migrant parent training to thousands of workers. (See Women and children first, how brands are innovating to help female workers).

Robertson expresses frustration that China Labor Watch has refused to work with the industry to improve conditions for workers, particularly its refusal to feed into its consultation with stakeholders on the new checklist.

Toy makers share that frustration. In a letter to China Labor Watch in January in response to the report, Mattel said:“We welcome constructive feedback and, as we have done in previous years, again request that China Labor Watch reports non-conformances with our responsible supply chain commitment promptly to us so that we can take immediate action ... We remain hopeful that China Labor Watch will consider a more collaborative approach moving forward, which can only benefit the very workers we are both interested in protecting.”

We remain hopeful that China Labor Watch will consider a more collaborative approach moving forward

Hopes that the new checklist will change attitudes at China Labor Watch may be in vain. Asked by Ethical Corporation why it was not collaborating with the industry, programme officer Elaine Lu said in an emailed response: “We would like to collaborate with them, but when we did previously, between 2008 and 2012, ICTI always said that they will make improvements ‘next year’.”

She also alleged that when CLW previously alerted a major toy brand that it had discovered child labour at a supplier factory “they said they would communicate this with ICTI. One of our investigators was actually at the factory during this time and found out that the factory knew auditors were coming to check. Child workers were not discovered at the factory by the time the auditors arrived, because they had already been asked to leave.”

Robertson denied that factories receive prior notice of its audits: “All of our audits are unannounced. Child labour remains a zero-tolerance issue for us.”

Terry Slavin is editor of Ethical Corporation and a former correspondent for Guardian Sustainable Business. @tslavinm
James Rose contributed to this article

Main picture credit: China Labor Watch

This article is part of the in-depth briefing China’s New Dawn. See also:


Green bond market helps China’s green revolution overcome headwinds

China looks offshore for its new renewable frontier

Chinese companies slow to join RE100

Women and children first: how brands are innovating to help China’s female workers

IKEA and Audi pulled up for sexist marketing

Global goals: Huawei’s strategy to connect the world – and take on Apple

Electronics sector charts new path after ‘bloody decade of labour abuse’

The brands going beyond auditing to give China’s apparel workers a voice

How QuizRR is taking human rights training to the factory floor

How Mattel’s quick move rescued Barbie

China ramps up search for solutions to meet urbanization challenges


toy sector  ethical toy program  China Labor Watch  migrant workers  Mattel  Microbenefits 

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