Abstract

Despite decades of labor governance initiatives, most attempts to improve working conditions for vulnerable workers in global supply chains have produced limited and short-lived results. This outcome is because prevailing approaches have failed to address the structural factors of hypercompetition among suppliers, monopsony power of lead firms, and state control over labor. However, by analyzing labor campaigns led by apparel workers in Honduras and auto workers in Mexico, the authors identify cases in which change has been both significant and sustained. These cases demonstrate how labor can leverage external governance mechanisms to build bottom-up power that enables workers to organize and bargain collectively. In these successful cases, top-down labor governance mechanisms are displaced by bottom-up labor governance. Findings underscore the importance of dynamic interaction between external enforcement and grassroots organizing in addressing power asymmetries in global supply chains to improve working conditions.

The literature on labor in global production provides ample explanations on why wages, benefits, and other terms and conditions of work at the bottom of global supply chains remain so poor. The literature also provides a wide array of illustrative cases in which activists’ campaigns, state interventions, and a private governance mechanism1 solved a particular labor issue at a factory or group of factories. However, these changes are most often modest and short-lived. An activist campaign might achieve the re-hiring of a fired worker without ever addressing the competitive pressures and power imbalances that allow such labor abuses to persist, much less curtail the likelihood of future dismissals. Corporate social responsibility (CSR) programs may successfully identify minor health safety issues, such as the location of a factory fire extinguisher, while overlooking more significant and costly issues, including building structural concerns and safety. And factory participation committees may help managers identify worker concerns, such as poor food quality, yet workers on the committee raising concerns about low wages are unlikely to be heard. Under the right circumstances, national states can be an effective source of change by increasing the minimum wage or enforcing freedom of association rights. In repressive labor regimes focused on competitiveness rather than rights, however, states can be a source of worker control and often lead to labor-averse, market-oriented reforms.

An emerging literature has examined how governance might overcome the limitations of such single labor governance mechanisms, highlighting the interaction among multiple mechanisms through “hybrid” or “synergistic” forms of governance (Amengual 2010; Mayer 2014; Gereffi and Lee 2016; Gereffi, Posthuma, and Rossi 2021). That is, this literature suggests that, if any one mechanism is too weak to address structural imbalances, then perhaps the interaction among two or more mechanisms might provide the needed leverage to ensure more meaningful change. However, interactions among two weak mechanisms are unlikely to produce impactful results, especially when the interaction is circumstantial. The industrial relations literature indicates that a powerful mechanism for sustained improvements for workers is collective bargaining by well-organized labor unions. Yet, it is precisely the rights to organize and bargain collectively that are among the most curtailed rights in repressive labor regimes where the squeeze on labor through global supply chains intersects with the repressive power of the state.

If weak mechanisms such as voluntary CSR programs are unable to address power asymmetries, and if strong mechanisms such as collective bargaining are repressed, how can poor working conditions be addressed? This article helps to answer this puzzle by arguing that significant and sustained improvements to terms and conditions of work can occur when labor shapes and then leverages “top-down mechanisms” (understood as mechanisms that are external to factory-level industrial relations institutions) in order to empower “bottom-up mechanisms,” notably union organizing and collective bargaining. In general, agile mechanisms with strong enforcement provisions are likely to be highly impactful. However, the effectiveness of interacting mechanisms is also contingent upon the labor regime, understood here as a set of social relations and institutions that construct and shape labor relations across multiple scales of production (Baglioni, Campling, Mezzadri, et al. 2023). Put simply, combinations of mechanisms that work well in one context might not be as effective in another, and vice versa.

To better understand the dynamics of interacting labor mechanisms across labor regimes, this article explores campaigns in two labor regimes: the auto supply chains in Mexico and the apparel supply chains in Honduras. In Honduras, in the context of the 2009 right-wing coup d’état and an exploitative apparel supply chain, workers developed a transnational activist network, negotiated an enforceable brand agreement with the Fruit of the Loom company, pursued a trade agreement labor complaint that contributed to labor reforms, and organized workers. The result was a growth of trade unions and collective bargaining. By 2020, 45.9% of garment export workers had union representation and were covered by substantive collective-bargaining agreements. In Mexico, after many decades of management-controlled unions in auto supply chains and state-sanctioned protection contracts, between 2021 and 2024, workers organized or strengthened independent unions and leveraged labor reforms and the Rapid Response Labor Mechanism (RRLM) of the United States-Mexico-Canada Agreement (USMCA), resulting in the formation of 11 independent unions2 in the auto sector and 8 collective-bargaining agreements that improved terms and conditions of work for approximately 20,527 workers.

This article draws on in-depth interviews with workers and their allies, researchers, labor journalists, business association representatives, and government actors in Honduras and Mexico between 2021 and 2024. It also includes primary data analysis of the economic clauses in collective-bargaining agreements and, in the case of apparel workers in Honduras, an original survey that was designed, implemented, and analyzed with full worker participation.

Interacting and Dynamic Labor Governance in Global Production

Labor conditions and respect for workers’ rights remain poor in global production and, by some accounts, are in decline (Anner 2020; Baglioni, Campling, Coe, and Smith 2023). This finding has motivated an exploration of more impactful mechanisms to improve terms and conditions of work. In the field of labor studies and industrial relations, it is generally understood that trade unions and collective bargaining are the most effective, inclusive, participatory, and sustainable mechanisms for addressing poor labor conditions (Freeman and Medoff 1984; Hayter and Visser 2018; Fischer-Daly and Anner 2023). However, precisely because unions and bargaining are so effective in improving terms and conditions of labor (and thus presumably increasing the cost of production), employers often vigorously push back not only on union campaigns but also attempts to strengthen state regulation of freedom of association rights (Seidman 2007; Gereffi and Lee 2016).

To avoid increased state regulation of workers’ rights compliance in global supply chains, brands and retailers pursued private governance approaches in the form of corporate social responsibility (CSR) programs and Multi-Stakeholder Initiatives (MSIs) (Bartley 2018; Fransen and LeBaron 2019). These approaches provided weak protections for labor because they were largely voluntary and because attention was placed on issues that could cause reputational harm to firms, notably child and forced labor, while marginalizing collective labor rights that could allow workers to challenge managerial control in the workplace (Anner 2012). As Locke (2013: 12–13) found, brands and retailers were “unwilling to pay extra for improved working conditions.”Bartley and Coe (2023) importantly observed that transnational private regulation (such as CSR programs) was unable to improve labor conditions beyond the confines of its local context, which they refer to as the “mythical hope of transcendence.”

In the 2000s, labor rights advocacy groups began promoting Enforceable Brand Agreements (EBAs) as an alternative labor governance mechanism to CSR programs (Vanpeperstraete 2021; Ford and Gillan 2022). Unlike CSR programs, EBAs include binding arbitration clauses that enable labor unions and their allies to act against firms that fail to meet the terms of the agreement. Through EBAs, issues of non-compliance are governed by oversight committees that include labor and employer representatives. One of the more researched of these agreements is the 2013 Bangladesh Accord, which has had a positive impact on building safety (Reinecke and Donaghey 2023). However, the Accord does not include strong provisions on freedom of association rights (Bair, Anner, and Blasi 2020). As a result, it has not had a direct impact on wages and benefits. One EBA that does focus on freedom of association rights is the 2009 Washington Agreement between labor in Honduras and the Fruit of the Loom company, as we will see ahead.

Parallel to these developments has been an evolution in how states address labor rights through labor reforms, driven by considerable pressure from organized labor and its allies. In Honduras, the impact of this pressure was relatively modest, resulting in moderate labor reforms. In Mexico, the reforms were more substantial (Bensusán Areous 2020). These reforms have often been tied to approval of regional trade agreements, with labor chapters that resulted from pressure by labor. The Dominican Republic-Central America trade agreement with the United States (CAFTA-DR), signed in 2004, includes a labor chapter and a binding arbitration provision on internationally recognized labor rights, including freedom of association and collective-bargaining rights. However, the mechanism has been slow and largely ineffective (Compa, Vogt, and Gottwald 2018; Brooks 2022).

The United States-Mexico-Canada Agreement (USMCA), which replaced NAFTA in 2020, covers all core international labor standards, including the right to unionize and bargain collectively. The Dispute Settlement Chapter (31) provides for the United States-Mexico Facility-Specific Rapid Response Labor Mechanism (Annex 31-A, RRLM), which focuses on the denial of freedom of association and collective-bargaining rights. The mechanism provides for a time-bound review process that could include, should violations not be resolved at prior stages, a review by a panel of labor experts and significant trade sanctions (Polaski 2022).

The most significant impact of labor governance mechanisms, the extant literature suggests, occurs when mechanisms interact and reinforce each other, especially when private mechanisms are combined with state mechanisms. This combination brings together the flexibility of private initiatives with the authority and universality of public regulation (Locke 2013). Yet, such interactions are not necessarily planned. As Amengual (2010) found in the Dominican Republic, complementary state–private regulation (what he labels as “hybrid regulation”) is often “unwitting” or uncoordinated. He adds that, rather than private mechanisms displacing state labor regulation, they often relieve pressure on scarce state resources and thus complement state action. In this vein, the International Labour Organization (2016) references “synergistic governance,” which is conceptualized as governance complementarities among institutions and actors that build on their respective strengths and scopes (Gereffi et al. 2021).

Which combination of public and private labor governance mechanisms will be most effective is highly dependent on the local context (Bartley and Coe 2023). This context, as noted by Baglioni, Campling, Coe, and Smith (2023), constitutes a part of multi-scalar phenomena that includes the commercial demands of lead firms in global production. Building on this literature and on political economy and industrial relations literature (Piore and Sabel 1984; Bergquist 1986; Collier and Collier 1991), we argue that labor regimes within countries are partly shaped by the dominant economic sector through which they are inserted in the global economy. Labor regimes are also shaped and transformed through processes of contestation among labor, capital, and state actors, as will be seen later in the article in the case studies on Honduras and Mexico.

This article explores the contexts of the Mexican-auto labor regime and the Honduran-apparel labor regime to analyze which combination of mechanisms achieve substantial and sustained improvements in terms and conditions of work. A core component of this analysis is understanding the puzzle: If strong unions3 are needed to organize workers and bargain to improve terms and conditions of employment, how do countries with marginalized or otherwise weak unions make progress? The answer, we suggest, is labor’s leveraging of external (or top-down mechanisms) to enable bottom-up (factory-level, worker-driven) mechanisms. Top-down mechanisms include labor laws, state enforcement institutions, and labor and remediation chapters in trade agreements, as well as private governance via EBAs.

The process follows a general pattern that begins with workers who are blocked from establishing a strong union and improving conditions due to employer resistance and state labor control. Workers then mobilize with the support of allies to strengthen existing external mechanisms, such as labor laws or labor chapters in trade agreements, or to create new ones, such as EBAs. Depending on the labor regime context and worker strategies, labor then leverages a range of external mechanisms to put top-down pressure on management in a boomerang pattern (Keck and Sikkink 1998). When successful, this external leveraging results in stronger unions and effective collective bargaining that, in turn, contributes to improvements in working conditions.

The impact of interactive mechanisms depends on the relative strength of each mechanism within the context of each labor regime. Since leveraging external mechanisms allows labor to organize and bargain, thereby re-taking agency and controlling the process, these external mechanisms become less critical in workers’ efforts to improve their terms and conditions of employment. Thus, the relative importance of top-down and bottom-up approaches crisscrosses over time. Moreover, as will be illustrated in the case studies, these dynamics are far from linear. Instead, there are often counter efforts by employers and official unions who also turn to the state to achieve their goals. This process might result in backsliding for independent unions and, thus, the need for them to leverage external mechanisms once again (see Figure 1).

Figure 1. Worker-Controlled Dynamic Mechanisms for Improving Terms and Conditions of Labor in Global Production

In sum, this article contributes to the labor governance literature by arguing for a dynamic and interactive analysis of labor governance mechanisms in the context of variegated labor regimes. It theorizes that labor can overcome power asymmetries in global supply chains and transform conditions of work through interactions among enforceable labor governance mechanisms. It further argues that, to sustain these transformations, there is a need to transition from top-down external mechanisms to bottom-up mechanisms that are internal to the workplace.

Case Selection and Data Collection

In this article we examine the dynamics of interactive labor governance mechanisms through the lens of the Honduran apparel labor regime and the Mexican auto labor regime. This approach aims to go beyond a simple “paired comparison” or “most different/similar system method.” Instead, following Fairfield and Charman (2022), the goal of the cases is to maximize expected information gain to assist in testing and revising arguments. For the purpose of this article, that goal is to explore whether workers and their representatives and allies, as anticipated by the argument presented above, were able to shape and then strategically leverage labor governance mechanisms with the ultimate outcome of improving terms and conditions of work.

Honduras and Mexico are countries with active labor movements that have experienced recent labor reforms, are highly dependent on trade with the United States,4 and are subject to labor clauses in trade agreements with the United States. Nevertheless, they differ in terms of their economic structures. Textile and apparel dominate Honduran exports (44%),5 whereas autos and auto parts comprise a critical component of Mexico’s export economy, accounting for 32% of exports.6 These dominant sector supply chains helped to shape the labor laws, institutions, and practices of each country. The labor chapters and enforcement mechanisms in the US trade agreement with Honduras are also considerably different, with the USMCA providing a much stronger labor mechanism relative to CAFTA-DR due to its time-bound, facility-specific sanctioning power.

Historically, independent unions have been stronger in Honduras relative to Mexico, and Honduran trade unions played a key role in establishing one of the industry’s first and most substantial enforceable brand agreements. By contrast, unions in Mexico have yet to establish such a mechanism. However, since the 2019 reforms, Mexico’s labor laws and institutions have been more robust than those in Honduras. In sum, both countries have relatively strong and relatively weak labor governance mechanisms (see Table 1).

Table 1. Case Selection and Relative Strength of Labor Governance Mechanisms

Dominant supply chain sector Labor laws and institutions Independent unionism Enforceable brand agreements Labor chapters in trade agreements

Honduras Textile/apparel Weak Moderate Strong Weak

Mexico Autos/auto parts Moderate Weak n.a. Strong

To test these arguments, data were gathered in Honduras and Mexico between 2021 and 2024. In both countries, we interviewed a range of stakeholders, including workers, union organizers, employers, government representatives, industry association representatives, local researchers, and transnational worker rights advocates. Interviews lasted from one to two-and-a-half hours. To complement data collected via interviews, the lead authors employed a “worker-driven co-research in global supply chains” research methodology that included worker participation in investigating corporate and factory structures and financial performance.7 Data on outcomes were also gathered by analyzing the content of collective-bargaining agreements and comparing it with the terms and conditions of employment established by the labor code, or, in cases where a pre-existing corporatist union was present, with prior collective-bargaining agreements.

The lead author interviewed 33 stakeholders, mostly Honduran workers, researchers, and labor, government, and management representatives, and also several US labor advocacy group representatives. Data on the impact of the EBA and collective bargaining in Honduras were also gathered via workers’ participation in a worker survey. The survey focused on the northern Honduran provinces of Choloma, Villanueva, and San Pedro Sula, where more than 80% of the country’s textile and apparel export production is concentrated. The survey was designed and implemented, and analysis was conducted with the active participation of the group through weekly Zoom meetings between August and December 2021.8 There are 146,000 maquila workers in Honduras,9 and 390 workers were surveyed by teams of two surveyors who entered neighborhoods where garment workers are concentrated, knocked on doors, and surveyed workers who met the survey criteria.10 An effort was made to have an approximately equal distribution among workers with collective-bargaining agreements (CBAs) and workers not covered by CBAs. Of the surveyed workers, 205 (53%) were covered by CBAs, and 185 (47%) were not covered by CBAs.11 Survey questions covered wages, hours of work, production targets, health and safety, and gender-based violence at work. This survey, which had the goal of measuring outcomes, complemented the interviews, which had the goal of process tracing.

Research in Mexico was conducted between December 2022 and September 2024 in Mexico City and San Luis Potosi. To test the arguments via process tracing, the authors conducted in-person interviews and focus group discussions with approximately 45 production workers. Interviews with organizers lasted, on average, two hours. In Mexico City, the lead author interviewed five national labor organizers, three professional labor advisors, and seven academics specializing in labor relations. Given the relatively recent organization of independent unions in the auto, auto parts, and other sectors, and given time constraints, it was not possible to survey a significant number of workers covered by new CBAs to contrast their conditions of labor with those covered by old, protection-contract CBAs. To measure impact, however, it was possible to analyze the text of CBAs and compare this text to those of prior agreements negotiated by official unions.

Honduras

Honduran-Apparel Labor Regime

For four decades, apparel has been the most important export in Honduras, surpassing traditional agricultural exports such as coffee and bananas. The first garment export processing zones (EPZs) began operations in Honduras in 1976 along the Atlantic coast region of Puerto Cortés. As production expanded in response to favorable trade incentives with the United States, the state granted special authorization to allow factories outside the zones to receive the same benefits as those within the zones, thereby shaping the Honduran apparel labor regime of the contemporary period. Benefits for investors include a 100% exemption from income taxes, exemption from taxes, duties, and other charges on imports and exports, a 100% exemption from municipal taxes, and exemption from taxes on petroleum-based fuels used for production.12 The Dominican Republic-Central America Free Trade Agreement (CAFTA-DR), which entered into force in 2006, provided for duty-free (zero tariff) market access for Honduran-made textile and apparel products entering the United States, and further shaped the labor regime.13 In 2023, Honduras exported USD 3.5 billion in apparel, accounting for 65% of its total manufacturing exports.14

Unionism in Honduras is the strongest in the Central American region, with roots dating back to the banana worker strikes of 1954 (Portillo Villeda 2021). As labor organized, it pushed for more favorable labor laws. However, as Honduran apparel exports experienced growth in the 1990s and early 2000s and global competition increased, violations of workers’ rights to organize escalated. In its human rights report of 2009, the U.S. Department of State found, “Workers attempting to form unions in the export processing zones face dismissals, blacklisting, intimidation, isolation from colleagues, mental harassment, and, in some cases, physical assaults. Judicial processes are lengthy, and even when rulings support workers’ re-instatement, companies generally ignore them without sufficient follow-up from the state” (U.S. Department of State 2009). Labor rights and civil liberties, in general, deteriorated in Honduras following the June 2009 coup d’état that removed President Manuel Zelaya from office.15

Global Solidarity Campaign and the FOTL Enforceable Brand Agreements

In 2008, in this context of growing apparel exports, active independent unions, and weak labor law enforcement, workers at a Fruit of the Loom (FOTL)-owned factory, Jerzees de Honduras, formed a union to represent the factory’s 1,800 workers. Three months later, the union and management engaged in a collective-bargaining process as required by law. Nevertheless, during that time, workers reported harassment and threats of plant closure by factory management (WRC 2008). By October 2008, bargaining reached an impasse, and FOTL announced the plant’s closure for “economic reasons.” Union leaders alleged that the true motive behind the closure was to eliminate the union. Thus, the FOTL case fits the pattern outlined above in Figure 1, where workers facing poor working conditions are blocked from exercising their right to freedom of association.

The union allegation was supported by research from an independent US advocacy organization, the Worker Rights Consortium (WRC), whose report prompted student activists organized in United Students Against Sweatshops (USAS) to launch a campaign in coordination with the union to ensure the factory’s reopening (Anner 2013). Pressure on FOTL intensified, and in November 2009, these parties signed an EBA, known as the “Washington Agreement.” As a result of union pressure, the EBA emphasizes a commitment to “good faith collective bargaining” at the reopened factory, and FOTL committed to respecting freedom of association rights at all FOTL-owned plants in Honduras. Additionally, FOTL granted union representatives access to all its plants in Honduras for training sessions. The unions and their allies also demanded that the EBA include an oversight committee of five representatives selected by the union and the brand and establish a mechanism for binding arbitration to resolve disputes that cannot be settled through the oversight committee. Thus, workers and their allies successfully campaigned to establish a labor governance structure that could be subsequently leveraged when worker demands emerged.

CAFTA Labor Complaint and Honduran Labor Law Reforms

The labor chapter in the CAFTA trade agreement was partly shaped by the US labor movement’s intense opposition to the weak trade provisions in the NAFTA agreement and its argument that a lack of respect for workers’ rights in the region would result in job losses in the United States (Erikson 2004). Indeed, Erikson (2004: 21) found that labor unions have been “the loudest and most effective voice in opposition” to CAFTA. They did this through public protest, lobbying congressional representatives, and providing testimony to the US Senate Finance Committee.16

While labor did not achieve a vote against CAFTA, its pressure did result in a labor chapter with stronger provisions relative to the NAFTA side agreement. Using those provisions, on March 26, 2012, the AFL-CIO, along with 26 Honduran labor unions and civil society organizations, filed a CAFTA complaint submission. What this illustrates is that some of the same unions that leveraged for the formation of the FOTL EBA subsequently made the strategic decision to leverage the labor provisions of public labor governance mechanisms, suggesting that the reinforcing impact of multiple regulatory institutions in this case was the result of labor’s strategic actions.

In the case of the CAFTA complaint, the submission documented systematic and severe worker rights violations, including many within the apparel export sector. It also indicated that the Honduran government failed to investigate, penalize, and rectify these violations. Much to the frustration of the labor movement,17 it took the U.S. Office of Trade and Labor Affairs (OTLA) three years to respond to the complaint. However, its findings were substantial. On February 27, 2015, the OTLA released a public report stating that it had investigated the allegations in the submission and had “serious concerns regarding the protection and promotion of internationally recognized labor rights in Honduras, including concerns about the Government of Honduras’s enforcement of its labor laws” (OTLA 2015).

This led to the establishment of a joint government Monitoring and Action Plan (MAP), followed by the enactment of the Honduran Comprehensive Labor Inspection Law in 2017 and an increase in the country’s total number of labor inspectors from 137 in 2014 to 169 in 2018 (U.S. Department of State 2020: 25). In 2019, the Honduran Secretariat of Labor and Social Security (STSS) also issued implementing regulations to impose significant monetary penalties for violations of freedom of association. Many limitations in the Honduran labor regime persist. In an interview by the author, Olvin Villalobos Velásquez, the Honduran Minister of Labor and Social Security (2020–2021), stated that while the increase to 169 was a step forward, “the Honduran Ministry of Labor requires 600 inspectors to carry out its functions and protect workers effectively.”18

Despite these limitations, the resulting labor reforms from labor’s leveraging of CAFTA gave Honduran workers opportunities to leverage state institutions. While the labor law reforms themselves were insufficient to address labor abuses, when combined with leveraging of the EBA and dynamic grassroots organizing, the outcome for labor was significant, as will be seen in the section that follows.

Worker Organizing, Leveraging Labor Mechanisms, and Outcomes in Honduras

As noted above, in late 2009, the EBA was established, and in 2011, the first CBA was signed, followed by several other CBAs at FOTL factories. Building on the momentum of this success and following the 2012 CAFTA labor complaint and the Honduran government’s Labor Inspection Law in 2017, labor organizing was relentless. By the end of 2021, there were 22 CBAs in the export assembly sector covering 50,625 workers. Of these, 45,737 workers were employed in the garment export sector, accounting for 44% of the 105,000 garment workers in Honduras.19 This is one of the highest rates of unionization by independent unions in the global garment sector.

The dynamics of the interacting mechanisms in the case of Honduras are depicted in Figure 2. In the first phase, workers are blocked from pursuing their demands by management and the state is also inaccessible (see Figure 2, panel A). Workers then, with the support of allies such as the AFL-CIO, leverage CAFTA labor chapter and the grievance procedure of the EBA (FOTL Washington Agreement) (see Figure 2, panel B). The CAFTA complaint process results in pressure from the United States for state reforms, including the hiring of more labor inspectors and more substantial fines on violators. The EBA process, which had a more substantial impact, resulted in pressure on the FOTL headquarters and through them, pressure on factory management to respect the union, bargain in good faith, and not campaign against future organizing drives. The result was an ongoing process of collective bargaining and improvements in terms and conditions of employment in which external (top-down) pressure was displaced by a worker-controlled bargaining process (see Figure 2, panel C).

Figure 2. Interactive Mechanisms for Improving Terms and Conditions of Work in the Honduran-Apparel Labor Regime

Sources: Lead author, based on interviews; author’s database of Honduran CBAs; and Honduran Central Bank data on employment.

The time series impact of these dynamic interactions is depicted by the data in Figure 3. As anticipated by our argument, workers actively participated in the campaign to establish a labor governance mechanism, in this case, an EBA. They then leverage multiple mechanisms. However, this process involved a sequencing approach, where they began by leveraging the EBA, then utilized the CAFTA complaint process, and finally benefited from moderate changes in the labor and inspection process. Notably, the EBA focused on one company (albeit with multiple factories), whereas the CAFTA complaint and the labor reforms impacted the entire textile and apparel sector. This led to the next phase of the process, which involved unionization and collective bargaining, which grew substantially between 2016 and 2021 (see Figure 3). The final results included substantial wage increases that exceeded the inflation rate.

Figure 3. CBAs: Number and Coverage, Garment & Textile Sectors in Honduras (cumulative)

Importantly, CBAs significantly impacted the terms and conditions of employment and workers’ lives. Survey results indicate that, when compared to workers who do not have a CBA, Honduran garment workers with CBAs are 67% more likely to always have the choice as to whether or not work overtime, 82.1% more likely always to have a lunch subsidy, 93.6% more likely to have access to a company savings and loan account, 56.3% more likely to have free transportation to work, and 83.1% more likely to find that work intensity is not increasing over time. In addition, workers not covered by a CBA are 20.3% more likely to face verbal abuse, and female workers who are not covered by a CBA are 10.7% more likely to face sexual harassment on the job when compared to workers who are covered by a CBA. Notably, female workers covered by CBAs are 119.8% more likely to have a valid mechanism at work for addressing gender-based violence and harassment in the world of work. Most workers covered by CBAs also receive various maternity and paternity benefits, including extended leave time. Reflecting on these gains for workers, Honduran union leader, Daniel Durón, noted that the Washington Agreement was, “one of the best achievements in the last 30 years of organizing in Honduras and region.”20

Expanding collective bargaining has allowed unions to consolidate their power and extend their impact beyond unionized workplaces through national, tripartite bargaining with employer and government representatives.21 This included tripartite negotiations in which unions achieved significant minimum wage increases over five years for all maquila workers. As a result of the multiple-year minimum wage negotiations held in 2018, workers received a yearly wage increase of 7.5% to 8%. On top of this wage increase, workers covered by CBAs received an additional 6.5% wage premium. In 2021, this amounted to an average 14% wage increase for workers with CBAs (7.5% due to the union-negotiated minimum wage increase and an additional 6.5% through enterprise bargaining). This increase was significantly higher than the 2021 inflation rate of 4.48%,22 resulting in a substantial rise in real wages for workers.

One additional achievement of the EBA is that it has become less relevant over time. This outcome is because guaranteeing freedom of association rights and promoting good faith collective bargaining empowered Honduran workers to represent the interests of workers through collective-bargaining processes. As CBA coverage expanded, meetings of the EBA oversight committee became less frequent and important.23 This supports our argument that bottom-up mechanisms displaced top-down mechanisms.

Mexico

Mexican-Auto Labor Regime

Mexican export-oriented auto and auto part production rose from USD 18 million in 1970 to USD 242 million in the 1980s (Bennett and Sharpe 1985: 239). In 2021, Mexico became the seventh-largest vehicle producer in the world, up two spots from its position in 2010.24 And by 2023, autos and auto parts accounted for 22.3% of all Mexican exports, compared to less than 2% for textiles and apparel.25 Growth in the auto industry was driven by proximity to the US market and favorable trade agreements, as well as decades of state and employer labor control (La Botz 1999; Bensusán and Middlebrook 2020). Most unions are “official unions” that were historically tied to the governing PRI party with ties to employers in a systematic effort to block democratic and independent unions from representing workers (La Botz 1999; Chávez Becker and De León Calderón 2022). This is particularly true in the automotive sector, which, as noted, dominates the manufacturing export sector and has helped shape the labor regime. Middlebrook (1995: 4) referenced the “governing elite’s effective control over the means of coercion and the institutionalized capacity to regulate worker-employer relations and enforce legal restrictions on union formation, internal union activities, and strikes” as a defining component of the labor regime. In the late 1960s and 1970s, amid greater social mobilization of the period, there was a push for union democracy in the expanding auto sector. Yet, many of these gains were set back by the economic crisis of the 1980s (Middlebrook 1995).

Mobilizing for Domestic Labor Reforms in Mexico

Throughout Mexico’s long history of state-sanctioned employer-controlled labor unions, workers have sought to reform the labor regime (Cook 1996; La Botz 1999). Labor’s recent struggle for labor reforms has its roots in the 1990s and grew in the early 2000s (Bensusán and Middlebrook 2020). In 2009, several international and national unions filed a complaint to the ILO on violations of freedom of association rights (Convention 87). This began a series of reviews by the ILO, with the ILO’s Committee of Experts on the Application of Conventions and Recommendations (CEACR) calling on the Government of Mexico “to take all necessary legislative and practical measures without delay to find effective solutions to the obstacles to the exercise of freedom of association posed by the so-called protection trade unions and protection contracts” (CEACR 2017: 147).

In response to US union pressure, the US government raised similar concerns, noting that Mexican government bodies “did not adequately provide for inclusive worker representation and often perpetuated a bias against independent unions, in part due to intrinsic conflicts of interest within the structure of the boards exacerbated by the prevalence of representatives from ‘protection’ (unrepresentative, corporatist) unions” (U.S. Department of State 2016: 28). The US government placed considerable pressure on Mexico to reform its labor regime under the Obama administration during the 2015–2016 Transpacific Partnership trade negotiations.

US and Mexican labor’s pressure for reforms, in the view of Bensusán and Middlebrook, “caused Mexico to adopt a constitutional reform that significantly strengthened the legal basis for democratic worker rights” (Bensusán and Middlebrook 2020: 986). Constitutional reforms were followed by labor law reform when Andrés Manuel López Obrador of the progressive MORENA party took power in 2018. In 2019, the new government reformed its Federal Labor Law, requiring workers to have a choice over trade union representation, including the right to vote on initial collective-bargaining agreements (CBAs) and yearly revisions via universal, free, direct, and secret ballots. It also required gender representation on the executive board of trade unions to reflect the gender proportionality of the workforce. The reforms further established new institutions, notably a new labor court system and a federal decentralized institution (the Federal Center for Conciliation and Labor Registration) that is independent of the executive branch to register trade unions and resolve employment conflicts (Bensusán and Middlebrook 2020).

A critical part of these reforms included “legitimation votes,” a process by which workers in unionized workplaces voted on whether to approve (legitimize) or reject (vote down) existing CBAs. The process, which was largely completed in July 2023, was designed to address the issue of protection contracts signed by undemocratic trade unions on behalf of employers behind the backs of workers. The reforms thus represent an attempted rupture with the corporatist model of labor governance. Following the reforms, the state thus provided an additional top-down mechanism that could facilitate the bottom-up mechanisms of independent union formation and collective bargaining.26 It is the interaction of public labor governance mechanisms with the labor governance mechanisms of the USMCA that allows independent unionism to grow, bargain, and improve terms and conditions of work.

USMCA Rapid Response Labor Mechanism

Discontent with the labor chapter of CAFTA motivated the US labor movement, in coordination with Mexican unions, to pressure the US government to establish an effective labor enforcement mechanism when it re-negotiated NAFTA. As part of this process, Cathy Feingold, Director of the AFL-CIO International Department, in representation of 55 national unions and 12.5 million members, testified before the US House Ways and Means Committee, stating:

The effective enforcement of Mexico’s new labor laws will be key to ensuring that the new NAFTA can actually benefit workers. … The labor obligations proposed in the new NAFTA must also be supported by an independent enforcement mechanism with innovative tools and penalties to change the culture and promote a strong commitment to the protection of worker rights.27

The testimony reflects an awareness of the interaction among labor mechanisms, with national labor law reinforced by strong labor obligations in interstate trade agreements. Partly as a result of such political pressure, the US government negotiated with Mexico to establish the United States-Mexico Facility-Specific Rapid Response Labor Mechanism (RRLM) within the USMCA (the revised NAFTA agreement), which took effect in 2020.

Under the RRLM, any party can initiate an enforcement action based on a complaint that workers at a covered facility are being denied freedom of association rights. If the respondent party determines there is a denial of rights, a series of time-bound obligations must be fulfilled to keep the process moving forward. The final stages involve a panel review. If the panel determines there has been a denial of rights, the complainant party may impose remedies, including suspending preferential tariffs or penalties on goods manufactured at the covered facility. After repeated violations, a firm’s products or services may be denied entry into the United States (Polaski 2022). In summary, the RRLM provides a binding, cross-border labor governance mechanism that, in conjunction with public governance mechanisms, can facilitate worker organization and, subsequently, collective bargaining.

Worker Organizing, Leveraging Labor Mechanisms, and Outcomes in Mexico

Process tracing of workers’ efforts to organize at the General Motors (GM) facility in Silao, the first major RRLM case, reflects the sequencing of top-down and bottom-up mechanisms outlined in our argument. Workers at the 6,500-employee facility28 had been attempting to establish an independent and democratic union for years yet faced considerable opposition from the official union and the employers (Gómez Zuppa 2022). The labor reforms requiring a “legitimation vote” presented workers with an opportunity to vote against the official union protection contract. However, during the vote held on April 20–21, 2021, the official union destroyed ballots to prevent a loss of their control. In response, workers filed a complaint with the state Attorney General’s office.29 Yet, when an inspector from the government office attempted to enter the factory, they were denied access.

Having failed to resolve their demands solely through domestic mechanisms, workers spoke out about the labor violations in the Mexican and international press and provided testimony to representatives of US labor advocacy groups who amplified their concerns to the US government.30 In response, the US government requested “Mexico to review whether workers at a General Motors (GM) facility are being denied the right of free association and collective bargaining.”31 The United States based its request on violations of Mexico’s reform labor law. Mexico reviewed the request, agreed with the concerns, and developed a remediation plan with the US government that included a new contract legitimation vote. The union then began campaigning for worker support to vote down the CTM (Confederation of Mexican Workers) protection contract. International labor solidarity played a crucial role in the campaign, with unionists from both South and North America visiting Mexico to express their support to the workers at GM Silao.

The protection contract was voted down, and in February 2022, the independent union secured representation rights, and subsequently successfully negotiated an 8.5% wage increase with the company. Without the need to petition the government or re-engage the RRLM complaint process, the union bargained a second time with GM and, in March 2024, secured a 9.2% wage increase, thereby illustrating the transition from top-down to bottom-up governance mechanisms. The GM case is not unique. Since 2021, workers organized, leveraged the reformed labor laws of Mexico, and petitioned the Rapid Response Labor Mechanism of the USMCA to address worker rights violations. The majority of these cases involve the auto and the auto parts sector. All these cases involved some degree of dynamic, interacting labor governance mechanisms. Most cases follow a similar pattern. 1) Workers face blockage at the workplace level to resolve an issue (hold an election, form a union, bargain) (Figure 4, panel A). 2) Workers and their union leverage newly formed government regulations and institutions and, with the support of allies and in a boomerang pattern, leverage the RRLM, which in turn leverages the state and employers (Figure 4, panel B). 3) Workers, their union, and management begin an ongoing process of collective bargaining that dissipates the need for top-down pressure (see Figure 4, panel C).

Figure 4. Interactive Mechanisms for Improving Terms and Conditions of Labor in the Mexican-Auto Labor Regime

Sources: Authors, based on USTR data, press releases, and interviews with stakeholders.

Another prominent case is the 2022 case of Panasonic Automotive Systems of Mexico, which produced audio/video equipment for vehicles. An independent union organized and won the right to represent workers in the company’s Reynosa facility in the northeastern border region with the US. The problem emerged when the company refused to bargain with the independent union, dismissed 50 workers associated with the independent union, and began bargaining with the company union. In 2022, the independent union, in coordination with the US labor advocacy group, Rethink Trade, filed a complaint under the RRLM.32 The US government requested that the Mexican government review the violations, which it did. During the review process, Panasonic changed course and negotiated with the independent union a 9.5% wage increase, a 3.5% bonus payment, and re-instatement of dismissed workers.33

At the Goodyear tire factory in San Luis Potosi (SLP), management had negotiated an enterprise collective-bargaining agreement with a company union to provide workers higher pay and better benefits offered by a national sectoral CBA in the rubber sector, a violation of Article 417 of the Mexican labor law. With support from the US United Steelworkers union, on April 20, 2023, an independent union filed an RRLM petition based on the company’s failure to apply the sectoral contract to the sector. As the petition was under review, the factory held its legitimation vote on April 23–24, 2023. During the vote, union representatives of the official union stole the ballot box in apparent collusion with Goodyear security personnel with the evident goal of stuffing the ballot box. The incident was denounced by the independent union and captured on security video. This led to a new vote, in which 71% of workers voted against the protection contract.

On May 22, the United States requested that Mexico review whether workers at the facility were being denied their rights by not abiding by the terms of the agreement. Mexico accepted the U.S. Trade Representative (USTR) complaint, investigated, and, on July 19, together with the United States, announced a course of remediation that required Goodyear to apply the sectoral agreement and clauses in the enterprise agreement that were superior to the terms of the sectoral contract. The independent union then negotiated with Goodyear regarding the application of the sectoral agreement to the Goodyear facility. As a result of the interaction of strong labor organizing, international union support, Mexican government action, and the leveraging of the RRLM, Goodyear SLP workers achieved an independent union and earned a 30% salary increase. They also enjoy a larger savings fund, as well as Christmas and vacation bonuses.

Other cases following similar patterns include Tridonex (auto parts production in Matamoros), Teksid Hierro (auto parts, Coahuila), and Saint Gobain (car windows, Morelos).34 By the end of 2024, unions had combined organizing, leveraging state institutions, and using the RRLM in 20 auto sector cases, resulting in 8 major collective-bargaining agreements covering 20,527 workers (see Figure 5). At a time when the annual inflation rate was 5.5%,35 these CBAs increased combined wages and benefits annually, in most cases, by more than 10%. (See Appendix 2 for details of Mexican auto cases.) The RRLM also resulted in the payment of millions of dollars in back pay and benefits to workers who were wrongfully terminated.36 The crisscrossing dynamic is not reflected in the aggregate data. However, it can be gleaned from the factory cases: After successfully leveraging the RRLM and state mechanisms, the effort to improve wages and benefits shifted to union-led collective bargaining.

Figure 5. RRLM Auto Cases and Collective-Bargaining Agreements Impact, Independent Unions (cumulative)

Importantly, a significant number of cases were unsuccessful, and many are still pending. For example, despite considerable organizing efforts, state leverage, and two RRLM petitions, workers at the VU Manufacturas facility were unable to bargain a new CBA. The company preferred to close the factory rather than bargain with an independent union, resulting in the loss of 250 jobs. The case began as specified in our model: Workers formed an independent union, which then filed two worker rights complaints with the local Labor Court but received no response. The union subsequently filed a complaint with the RRLM, and the Mexican state ruled in favor of the union. Nonetheless, those efforts did not prevent the company from closing.

Discussion

We have argued that workers at the bottom of global supply chains continue to face chronic low wages and inadequate working conditions, despite the presence of a plethora of labor governance mechanisms. This circumstance is because most of these governance mechanisms, even when interacting, lack the leverage needed to fundamentally alter supply chain power asymmetries that are conducive to poor working conditions. By contrast, the interaction of labor mechanisms with sanctioning power—notably, domestic states, binding trade agreement clauses, and enforceable brand agreements—are more conducive to improvements in the conditions of labor because they have the leverage needed (most especially when they interact) to alter power relations, allow for union formation and collective bargaining, and ultimately to improve wages and benefits significantly.

Of course, this approach is not the only way to improve labor conditions. Strong, populist states throughout history have decreed significant increases in minimum wages and mandatory benefits. Getúlio Vargas in Brazil is a notable example (Collier and Collier 1991; Levitsky 2003). Nevertheless, such approaches often fail to empower independent unionism and are susceptible to democratic backsliding as populist leaders may turn autocratic and repress labor (Drake 1996). This article has argued that a more sustainable approach, precisely because it empowers independent worker organizations, is one in which top-down labor mechanisms facilitate the bottom-up labor mechanism of factory-level union formation and collective bargaining.

An important component of these dynamics is the role played by allies. Allies, most notably domestic and international labor solidarity and advocacy organizations, have worked with unions to reform labor laws, negotiate EBAs, and establish labor provisions in trade agreements. These relationships are not without contradictions. Inherent structural power imbalances occur within labor solidarity networks based on economic resources, language, and access to government and business leaders. There are also varying objectives among unions in different locations, with better-positioned unions caught between the desire to protect their members from potential job loss and the principle of international labor solidarity (Franz 2010). The United Automobile Workers union (UAW) in the United States has collaborated with most of the campaigns to organize auto workers in Mexico. It also has favored some tariffs on Mexico to protect US jobs. UAW president, Shawn Fain, noted in April 2025: “We support the use of some tariffs on automotive manufacturing and similar industries. We do not support tariffs for political games about immigration or fentanyl. We do not support reckless tariffs on all countries at crazy rates.”37

Finally, while Honduras and Mexico provide illustrative examples of what successful interacting labor mechanisms can look like, this does not mean that such outcomes are common across all countries and sectors. Even in these two cases, continued success is far from guaranteed. In Honduras, rising costs, the lingering impact of COVID-19 supply chain disruptions, and, more recently, the imposition of export tariffs by the Trump administration have led to factory closures and a loss of some of the gains outlined above.38 In Mexico, new tariffs on the auto sector have led to production cutbacks and pressure to reduce real wages. Moreover, Trump administration cuts to USAID and the U.S. Department of Labor have resulted in the termination of support for allied labor advocacy groups, notably the Solidarity Center.

Following the analysis above, other countries and sectors will face unique opportunities and challenges. Organizing workers in agricultural supply chains, such as the coffee sector, is particularly hard due to the geographic spread of production, cyclical production cycles, and low value added. These challenges are compounded in repressive national regimes, such as the Bukele government in El Salvador (2019–present). By contrast, metalworkers in Brazil (including auto workers) have had significant success during periods of strong pro-labor governments, notably the first term of Luiz Inácio Lula da Silva (“Lula”) (2003–2011). This accomplishment is attributable to the concentration of high-value added production in large factories, innovative worker organizing, and supportive labor laws and institutions (Martin 1997).

Conclusions

Scholarship on workers’ rights in global production has focused on public and private labor governance as providing mechanisms for addressing labor abuses (Bartley 2014; Bair and Palpacuer 2015; Gereffi and Lee 2016), with scholars increasingly emphasizing how governance mechanisms interact to form hybrid or synergistic forms of labor governance (Amengual 2010; Mayer 2014; Alford and Visser 2024). This article builds on this literature by arguing that public and private labor governance mechanisms are interactive and dynamic, and that in successful cases (understood as sustained improvements to work terms and conditions), top-down mechanisms are displaced by bottom-up labor-driven processes, notably union organization and collective bargaining. We examine this argument by analyzing the cases of the Honduran apparel labor regime and the Mexican auto labor regime.

Through these case studies, our study has shown that the relative importance of each mechanism and the dynamics of each case vary considerably. In Honduras, labor organizing and a global campaign contributed to an Enforceable Brand Agreement (EBA) with the Fruit of the Loom company that includes a neutrality agreement and gave the union access to workplaces to conduct training. Within a few years, unionization and bargaining spread to all FOTL facilities in the country. During this period, labor and its international allies presented a CAFTA labor complaint, which, although slow to move forward, contributed to some limited labor reforms that created additional space for labor organizing. By 2020, 46% of garment export workers were unionized and covered by collective-bargaining agreements. External governance mechanisms became less important in the process as bottom-up labor governance mechanisms prevailed. In the case of Mexico, labor unions did not campaign for an EBA. Instead, there was a concerted effort to implement substantial labor reforms and a labor complaint process in the USMCA trade agreement via the RRLM. With constant labor organizing and support from international labor and other allies, three years after the enactment of the RRLM, approximately 20,000 workers were represented by independent and democratic labor unions that collectively bargained to substantially improve benefits and wage levels well above the inflation rate.

The article also shows that these interactions remain dynamic and highly impacted by myriad factors affecting labor regimes, including the 2025 tariff regimes imposed by the US Trump administration, which have caused considerable economic uncertainty and downward pressure on labor in Honduras and Mexico. Nonetheless, it is possible that the organizational gains in Mexico and Honduras enable workers to better weather these challenges compared to workers elsewhere with lower levels of collective representation, highlighting the particular importance of bottom-up mechanisms during times of crisis.

Funding Information

This work was supported by two grants provided by the Solidarity Center (1945J HO NED Supply Chain, IL-38905-22-75-K; Mexico grant number: 104754. Honduras grant number: 100472) administered through Penn State University.

ORCID iD

Mark Anner https://orcid.org/0000-0002-6822-2166

Footnotes

This article is part of the ILR Review’s Special Issue on Public, Private, and Social Labor Governance in Global Production: Connections, Intersections, and Spillovers across Arenas and Issue Fields.

The authors do not have an institutional affiliation with the Solidarity Center or any other potential competing interest to declare. The survey of Honduran workers received Institutional Review Board approval at Penn State. Segments of the Honduras case study draw on a report by one of the authors, “Bargaining for Decent Work and Beyond,” which was posted on the Center for Global Workers’ Rights website. See https://ler.la.psu.edu/wp-content/uploads/sites/26/2022/06/Honduras-maquila-report.pdf.

1 The term “mechanism” is used in this article to denote a set of processes that include governance instruments and regulatory institutions. It follows the use of the term by Richard Locke, who references corporate “self-governance mechanisms” and “monitoring mechanisms” (Locke 2013), and the International Labour Organization, which references “social governance mechanisms” and “public governance mechanisms” (ILO 2016).

2 The term “independent union” refers to unions that are independent of state and employer control.

3 A “strong” union is understood here as one that is independent of the state and the employers and has significant membership and membership commitment to mobilize workers and effectively place demands on employers.

4 Honduras exports 51% of its goods to the United States, and Mexico exports 77% of its goods to the United States (Observatory of Economic Complexity [OEC], https://oec.world/en, accessed August 22, 2024).

5 Observatory of Economic Complexity (OEC), https://oec.world/en (accessed August 22, 2024).

6 INEGI: https://www.inegi.org.mx/contenidos/saladeprensa/boletines/2023/balcom_o/balcom_o2023_12.pdf (accessed August 22, 2024).

7 Space limitations do not allow for a detailed explanation of these workshops. That information can be found in Anner (2024).

8 More on this process can be found in Anner (2022).

9 Data from the Honduran Central Bank and Honduran Maquiladora Association (association of mostly garment assembly-plant exporters, known regionally as “maquiladoras”).

10 Actively employed in the sector and of legal age to answer survey.

11 Of the survey respondents, 51% were women and 49% were men, which reflects the current composition of the workforce in the country. In the survey sample, 26.6% of the workers were 18 to 25; 52.2% were 26 to 39, and 24.3% were 40 or older, reflecting an appropriate distribution by age when compared to the ages of workers in the industry. Of the surveyed workers, 205 (53%) were covered by CBAs and 185 (47%) were not covered by CBAs. This research project was reviewed and approved by the Penn State Office of Research Protections (Study ID: “Study00018671”).

12 Honduran Maquiladora Association (AMH). See http://www.ahm-honduras.com/?page_id=1331 (accessed April 13, 2024).

13 See International Trade Administration, https://www.trade.gov/summary-cafta-fta-textiles (accessed April 13, 2024).

14 See Banco Central de Honduras, https://www.bch.hn/estadisticos/EME/_layouts/15/WopiFrame.aspx?sourcedoc=%7B38EC98FB-645C-426A-A922-B4AD391A86B3%7D&file=Exportaciones%20FOB%20Bienes%20para%20Transformaci%C3%B3n%20trimestral.xlsx&action=default.

15 Freedom House Honduras, https://freedomhouse.org/country/honduras.

16 See https://nwlaborpress.org/2005/5-6-05Cafta.html.

17 First author’s interview with union activists in Honduras and the United States, October–November 2021.

18 Interview with first author, November 1, 2021, Tegucigalpa.

19 CBAs cover workers in factories owned by multinationals as well as those employed at factories owned by Hondurans.

20 Interview with author, November 1, 2021, Tegucigalpa.

21 Eva Argueta, interview with author, October 25, 2021, San Pedro Sula.

22 World Development Indicators, World Bank: https://databank.worldbank.org/source/world-development-indicators (accessed October 5, 2024).

23 Author interviews with union leaders in San Pedro Sula and with oversight committee members by phone and Zoom, October 2021–March 2022.

24 See https://www.amia.com.mx/indicadores-internacionales-relacionados1/.

25 See OEC, https://oec.world/en/profile/country/mex?depthSelector1=HS2Depth (accessed April 13, 2024).

26 As we will see, however, state institutions are also a space for contestation and the dynamic nature of interacting governance because employers and their allies in official union structures can also use the state to leverage against the gains of independent unions.

27 See https://www.congress.gov/event/116th-congress/house-event/109703 for full testimony.

28 See https://gmauthority.com/blog/2024/03/gm-silao-plant-workers-get-9-2-percent-raise/.

29 Maquila Solidarity Center, summary of case. See https://www.maquilasolidarity.org/en/what-have-rapid-response-labour-mechanism-complaints-achieved.

30 Author interviews.

31 See https://ustr.gov/about-us/policy-offices/press-office/press-releases/2021/may/united-states-seeks-mexicos-review-alleged-workers-rights-denial-auto-manufacturing-facility-0.

32 Maquila Solidarity Center (MSN), summary of case.

33 See https://ustr.gov/about-us/policy-offices/press-office/press-releases/2022/july/united-states-announces-successful-resolution-rapid-response-labor-mechanism-matter-panasonic-auto and MSN summary of case.

34 In the case of Saint Gobain, the union and its allies filed a petition under the RRLM mechanism, and the issue was resolved before the US government could rule on the case.

35 See World Bank, https://data.worldbank.org/indicator/FP.CPI.TOTL.ZG?locations=MX (accessed October 26, 2024).

36 Authors correspondence with representatives of the U.S. Department of Labor.

37 Neal Boudette, “Autoworkers Union Chief Gives Trump’s Tariffs a Mixed Review,”New York Times, April 10, 2025, https://www.nytimes.com/2025/04/10/business/uaw-shawn-fain-trump.html.

38 See https://www.business-humanrights.org/en/latest-news/honduras-gildan-confirms-shuttering-of-honduran-factory-following-killing-of-union-leaders/ (accessed October 19, 2024), and https://gildancorp.com/media/uploads/reports/b2023_report_to_shareholders_-_gildan.pdf (accessed October 19, 2024).