Executive Summary

The third-party consumables industry produces toner cartridges for laser printers, ink cartridges for inkjet printers, and ribbons for dot matrix printers, as well as other products. Critical to any digital device’s printing process, ink, toner, and ribbon cartridges are purchased in high-frequency on markets around the world. According to Reportlinker, the Global Printer Market accounted for USD 42.35 billion in revenue for 2020. The pandemic has witnessed that people started stocking up on lockdown essentials. It is expected to reach USD 54.83 billion by 2026, registering a CAGR of 4.55% during 2021-2026. Demand for cartridges has softened over the past decade, but the global market will remain large despite experiencing single-digit declines through 2025.

 

Today, factories in Zhuhai, China, a port city on the Pearl River Delta in China’s southern Guangdong province, produce the majority of the world’s third-party cartridges. Towards the end of the 20th century, China’s first domestic third-party cartridge factories were established in Zhuhai, and since then the city has emerged as the hub of the country’s printer consumables industry. Today Zhuhai has become a global industrial cluster of office equipment and consumables. According to Yangcheng Evening News, there are more than 680 companies producing and selling printing consumables in Zhuhai, and their production of color ribbons, compatible inkjet cartridges, and recycled laser toner cartridges account for 90%, 70%, and 30% of the global market share, respectively, with an annual output value of more than 43.5 billion RMB.

 

Chinese factories producing third-party cartridges range in capacity from several thousand units per month to plants with a monthly capacity of millions of cartridges. The technological sophistication of these factories ranges from fully automated production lines to lines that rely exclusively on human labor.  As one might expect, the working conditions at China’s third-party cartridges factories also vary widely. Despite Chinese law, research conducted by China Labor Watch has found that labor rights protections are often ignored for the women and men staffing cartridge production lines at Zhuhai’s cartridge factories regardless of size. Likewise, the sub-standard industrial hygiene and adverse environment of these factories are often overlooked. 

 

As cartridge demand has fallen along with print volume in many major markets, Chinese third-party cartridge manufacturers have come under extreme pressure to remain profitable. The industry has consolidated and many companies have been radically reorganized and down-sized or they have been forced to go out of business altogether. As manufacturers desperately search for ways to cut production costs, working conditions in many of Zhuhai’s third-party cartridge production centers have deteriorated. In 2021, China Labor Watch released a report based on an investigation on three third-party printer consumable companies, Zhuhai National Resources, Jingjie Printing Technology factory, and Zhuhai Maetone Infotech factory, which found a shockingly large number of labor violations. There are also reports outside of China that certain firms in the third-party cartridge industry have violated environmental laws, including the industry giant Hubei Dinglong Corporation.

 

This time, China Labor Watch once again commissioned undercover investigator(s) to enter the two listed companies producing printer consumables in Zhuhai, hoping to further understand the status of labor rights and environmental impact of this industry. In total, investigator(s) interviewed nearly 60 factory employees during several weeks of undercover investigations at both factories. The investigation found the following serious violations in the areas of labor rights and environmental protection:

 

1. Illegal employment of underage workers and overt recruitment discrimination  

The two factories under investigation employ underaged workers illegally. Mingtu and Chaojun recruit underage workers who are over the age of 16. What’s common for these factories is that underage workers are treated no different from adult workers. Like regular workers, they were required to work overtime and night shifts. According to the National People’s Congress’s interpretation of the Labor Law, (an enterprises need to) generally implement practices to shorten the working day for workers under the age of 18, and must not arrange for underage workers to work overtime and night shifts. The behaviors of the two factories present clear violations against the law.

 

In addition to employing underaged workers, there exists overt ethnic discrimination in Mingtu’s recruitment process. The recruitment agency made it clear that it would not recruit from four groups of ethnic minorities, including Tibetans, Uyghurs, Hui, and Zhuang. Investigator(s) have also seen cases where the employment agencies refused to introduce jobs to middle-aged Uyghur men from Qinghai. This practice violates Article 12 of China’s Labor Law, which stipulates that “workers shall not be discriminated against in employment based on their ethnicity, race, gender, or religious belief.” 

 

2. Employment practices in violation of labor laws

During the undercover investigations and worker interviews in the two factories, the investigator(s) discovered a large number of employment practices that violated Chinese labor-related laws and regulations. These illegal practices adversely impacted the workers’ quality of life by denying them actual earned wages and social security benefits. The investigator(s) also found that workers faced  overworked conditions for extended periods of time. A worker reported: “This is the most tiring job I have ever done, and I have not slept enough for the past few days. I wish that I can take one day off a week and work (only) till seven or eight o’clock at night.” The specific labor violations are as follows:

 

2.1 Long-term overwork and unpaid overtime

The factories have extremely high production targets, and when the daily production targets were not met, workers must continue to work overtime to complete the targets without additional pay. This has led to the long-term illegal behavior of overwork and unpaid overtime in the factories.

 

The production targets of each assembly line in the investigated factories were different. On some product assembly lines, workers were required to produce 7,000 products a day. Mingtu required workers to work overtime if their daily production targets were not met, and overtime under such conditions were not paid; workers often worked 12-14 hours a day, sometimes even more than 15-16 hours, with one day off per week. Their monthly actual overtime hours exceeded 96 hours. For Chaojun, the average work hours are 13.5 hours per day, occasionally 15.5 hours, and there was no guarantee of even 10 hours of rest time per day. Only the hours worked after 10 p.m.were counted as paid overtime; There was only one day off a month, sometimes workers were not even offered a day of rest. It was difficult for workers to take a day off every 14 days. Overwork is very obvious, and the actual overtime hours per month exceeded 220 hours.

 

According to Article 41 and 44 of China’s Labor Law, if the total overtime of a given worker exceeds 36 hours per month, they are entitled for overtime pay. However, both factories under investigation have vastly exceeded the overtime threshold under the legal definition, yet have not paid the overtime according to the law. The overwork and overtime labor violations in these two factories were critical, and the workers were generally required to overwork with little additional pay, creating a high-stress work environment that may cause unknown negative health effects to the workers.

 

2.2 Lack social security protection for temporary workers

Both printer consumables companies did not purchase social security insurance for temporary workers (or hourly workers), despite it mandated by law. Some labor recruitment agencies required temporary workers to purchase commercial insurance on their own. The factories purchased social security insurance for formal workers. These workers were also paid according to the minimum legal standard, but neither companies paid for the legally-mandatory housing provident fund for any workers. According to the Chinese Labor Law, “Housing Provident Fund Management Regulations,” and other regulations, employers are required to provide five insurances and one housing fund for all workers who have established labor relations with the employers, and regarding this, there should be no difference between temporary workers or regular workers. However, neither companies investigated complied with legal standards.

 

2.3 Insufficient benefits such as paid annual leave/sick leave

Regarding sick leaves, the factories under investigation did not pay for sick leaves for temporary workers. Chaojun, specifically, did not pay for sick leaves even for its formal workers. Mingtu paid a certain percentage of wages for workers’ sick leave. In terms of paid annual leave, temporary workers were not entitled to any annual leaves in these factories, and only Chaojun claimed that formally contracted workers can enjoy annual leave.

 

It is generally difficult for workers to ask for a leave as it would lead to discrimination to some degree. Procedurally, it was not complicated to ask for a leave in either factories, but both factories require reporting and applying in advance in writing with the leaders of two to three levels superior to the workers. Workers generally did not dare to ask for leaves frequently. The factory assembly lines had a fixed production target and if workers frequently took leave, it would affect the production capacity and they would be regarded as having a bad attitude. They could also encounter verbal abuse from the upper management and the possibility of being transferred to other positions or directly fired.

 

2.4 Non-standardized procedure in the signing of labor contracts and the lack of contract for temporary workers

Formal workers in both factories signed labor contracts. However, many of the labor contracts signed by the workers of Mingtu and Chaojun were actually legally invalid as some sections were left blank in the body of the contract, and the contracts also lacked specific interests and obligations. Workers were required to sign the contract under the watchful eye of the HR, and were not given adequate time to read and understand the provisions of the contract. A copy of the contract was also not returned to the workers, an act that violates the labor contract and creates barriers for workers to file legal complaints when facing labor disputes. 

 

For the temporary workers who were introduced by labor agencies, neither companies signed legal labor contracts with these workers.

 

2.5 Lack of transparency in salary structure

Chaojun did not issue payrolls to any workers. However, even as Mingtu provided a slip of paper with workers’ monthly payroll, the calculation of workers’ piece-rate wages is not specified. Workers interviewed were not sure how wages are calculated. The lack of transparency in wage compositions made workers unaware of product rates and the related wage standards, making them more vulnerable to the company’s oppressive treatments. This practice also violates Article 6 of the Payment of Wages Tentative Provisions issued by the Chinese Labor department, which stipulates that “the employer shall provide the employee a payroll.”

 

3. Inadequate health and safety training and a good working environment

The investigation revealed that none of the two factories provided adequate safety training. According to Article 13 of the Provisions on Safety Training of Production and Operation Entities, safety training for new employees of production and business units shall not be less than 24 hours.

 

At Mingtu, no training on production safety was provided. Instead, the company directed the workers to spend a few minutes copying the answers to a safety training test. And after which workers were put to work immediately. The same happened in Chaojun. The workers did not receive any training, and after the investigator(s) entered the factory and signed the contract they were put to work immediately without even uniforms provided.

 

Our investigator(s) found the lack of training especially concerning because of the potential dangers workers faced. Both companies failed to provide workers with a safe work environment, and workers often had to work under potentially dangerous environments without adequate amounts of sleep and rest. 

 

Noise was a common issue. The workers at both factories generally reported that the noise on the production line in the workshops was as high as 100 decibels for extended periods of time, and the workers lacked corresponding noise-canceling protection gears; in order to ensure effective communications among the workers, management such as production line leaders or quality inspection would also require workers not to wear earplugs. 

 

Chaojun workers also reported that the temperature for the operating machines in the packaging workshop was as high as 100 degrees Celsius, creating a risk of burns. The above can have long-term health effects for the workers.

 

4. Practices such as workplace psychological abuse and “management via punishment”

According to the International Labour Organization, psychological violence can be defined as “the intentional use of power, including the threat of physical force, physical violence, against a person or persons that may cause physical, mental, spiritual, moral or social development. Harm includes verbal harm, bullying, mobbing, harassment and threats.”

 

We found evidence of workplace psychological abuse in both factories. When workers went through medical examinations for the purpose of entering their position, the medical staff were rude, and did not treat the workers well. They often yelled at or verbally abused the workers, and presented as impatient; workers were also often verbally abused by team leader or supervisor at the assembly line. The investigator(s) also experienced some of the scoldings. In Mingtu, the assembly line manager often made demands on workers over their posture, and they were also reported to be abusive and threatening. The Chaojun workers also often received verbal violence and insults from the management of their assembly line. Some workers were scolded by leaders for being “brainless” and “having problems with their brains,” and were even asked to work overtime alone until late at night as punishment; threats for dismissal were also made.

 

There are also harsh disciplinary practices among the factories under investigation. Mingtu had a list of different disciplinary items, including public notices of criticism, warnings, minor demerits, major demerits, and dismissal. If workers were late or violated regulations, they would be disciplined by line leaders and superiors. They could be assigned to marginalized positions and might even be forced to resign. Chaojun’s employee handbook also lists a number of disciplinary regulations, some of which were clear, while others ambiguous. For example, what constitutes “bad conduct and immorality” was never clearly defined under these regulations. This allows the factories to take unfair disciplinary action such as terminating workers without compensation for being involved in strikes.

 

5. Lack of worker representatives

According to Article 7 of China’s Labor Law, workers have the right to join or organize unions. But neither factories investigated had a union or an independent worker representative of any form; nor did they have an official channel to address workplace issues. Chaojun workers said that there is no labor union or worker representative in the factory, and they have never heard of the factory setting up a worker hotline. There was basically no way for workers to solve problems when they encountered them. The workers of Mingtu said that the factory had a “workers’ representative”, but when the investigator(s) asked about the representative, workers said that they were “just a display.” The representative’s only duty during their many years of employment was to report as a trade union representative when inspectors visit and inspect workplace issues. Mingtu also did not have a worker hotline.

 

6. The impact of the COVID pandemic on workers’ livelihoods

Under the Chinese government’s “zero-COVID” policy, the factories implemented strict COVID measures. Workers were required to wear masks throughout the workshops, and partitions were placed in the canteen. Health records such as health code and literacy codes were needed when entering and leaving the factory. Inspection of medical records has become the norm in the workplace.

 

Many restrictions on the factory’s recruitment process were added following the pandemic, including a requirement for workers to present a negative COVID test report done within 24-48 hours prior to interviewing for the job. Meanwhile, the itinerary health code could not carry an asterisk, which increases the cost of finding a job for the workers. These expensive measures cost the workers extra time and money for COVID testing, and this increases the cost of off-site accommodation before entering the factory. On the other hand, if the workers were unfortunate enough to have traveled through areas with COVID cases in the past 14 days, it becomes nearly impossible to find employment before their itinerary code becomes normal, prolonging  the periods of unemployment for the workers.

 

At work, the strict COVID measures – the factories often adjust their guideline to require workers to present a negative COVID test report daily based on the fluctuation of cases in the area – also meant that workers needed to spend more of their own rest time for testing in order to meet the factories’ COVID requirements. In addition, the pandemic has also cost workers negotiating power in the job market, and workers became more cautious. Even when they encountered unfair treatment, they were more inclined to endure, and are less likely to complain about poor working conditions or unfair work or choose to resign due to these issues.

 

7. Factory discharges and environmental pollutions

The main sources of pollutants in the printing consumables industry are in the wastewater, toner dust and solid waste generated during the production of ink and toner cartridges. During the investigation, the treatment and recycling facilities for toner dust and solid waste in the workshop were observed. Investigator(s) also evaluated  the impact of sewage pollution.

 

Based on the production, wastewater in the printing consumables industry was mainly generated when cleaning ink cartridges and old toner cartridges, and a large amount of organic matter visibly appeared to be present in the wastewater, which are environmental pollutants if left untreated. The emission of such wastewater must follow the Discharge Standard of Water Pollutants for Printing Ink Industry (GB25463-2010) issued by the Ministry of Ecology and Environment of the People’s Republic of China. According to the test results submitted by the investigator(s) to a professional testing facility, the wastewater discharged from Mingtu and Chaojun contained levels of chemical oxygen demand, five-day biochemical oxygen demand, suspended solids, petroleum, animal and vegetable oils, aniline compounds that far exceeds the discharge limit set by the state. In other words, the companies release pollutants into the environment. 

 

8. Summary and Recommendations

As mentioned, our investigation revealed numerous labor violations and illegal employment practices by two of the leading companies in the ink/printing consumable industry. These rights violations are listed in detail in the chart below. Moreover, Chinese workers were made even more vulnerable under the strict state and institutional COVID guidelines during the pandemic.The government’s supervision over illegal activities in production enterprises was proven to be insufficient, and the authoritarian management and exploitative labor practices made it difficult to protect the basic rights and interests of the workers. We therefore make the following four recommendations.

 

1. Through this report, we call for Zhuhai Mingtu Technology Co., Ltd., and Zhuhai Chaojun Co., Ltd. under Dinglong Co., Ltd. to fully abide by China’s labor law, and to provide all formally contracted and temporary workers labor contracts with all relevant terms and conditions that strictly follow legal guidelines, to voluntarily provide the worker with a copy of the contract, and to abide by all the terms stipulated in the labor contract. The company needs to give workers adequate paid annual leave and sick leave, provide adequate insurance and housing protections following the legal guidelines in full for each worker, and to provide payroll in order to establish a transparent salary structure. More importantly, both companies need to put an end to excessive overtime, to reimburse all workers for overtime pay that has been neglected over the past few years, and to provide statutory overtime pay for anything past the eight hours’ mark. Said companies must cease setting high production targets and forcing workers to perform large amounts of unpaid overtime.

1. Both companies should provide a friendlier, safer work environment where workers’ voices can be better represented. CLW calls for these companies to reflect on and to eliminate gender and ethnic discrimination in recruitment and frauds in safety training, to devise a real system to ensure workplace safety, and regularly provide workers with paid safety training on workplace hazards in order to ensure occupational safety and prevent work-related injuries. These factories must also put an end to workplace psychological abuse against workers and the “management by discipline” practice. They must also guarantee workers’ right to democratically elect worker representatives, provide anonymous channels for worker complaints, and improve communications between management and workers. Under the pandemic, the factory has the responsibility to bear the cost of COVID prevention. However, companies should also minimize the additional economic burden for their workers due to their testing requirements, and avoid taking up workers’ rest time for COVID testing.

1. Regarding the substandard test results found in the wastewater inspection over Mingtu and Chaojun, we call for the companies responsible to re-examine their wastewater recycling and treatment process and to invite a third-party agency to conduct independent testing, and to ensure that the test results are revealed to the public and community residents in a timely manner to prevent increase transparency and accountability. Both companies under investigation must pay close attention to the long-term impact of industrial wastewater, toner dust, and solid waste in the ink/printing consumables industry on the environment and to workers’ health and safety, increase and improve treatment facilities, and regularly publish monitoring results to the public.

1. Finally, we continue to call for the companies and online marketplaces that source printing supplies from these factories, including all contractors and subcontractors in the manufacturing process, to require their manufacturers and all businesses involved in the supply chain to strictly abide by labor standards and conduct regular inspections monitoring progress. Periodic undercover investigations and inspections must be performed to ensure timely corrections when labor and other relevant regulations are to be violated, with a real commitment to improving working conditions. Online marketplaces must strengthen regulation of companies that violate workers’ rights and prohibit repeat offenders from using their platforms for profit. We hope that the ink/printing supplies industry and major online retailers will join us and take these recommendations seriously as we all want to eliminate labor rights infringement in the industry supply chain. We also call for the Chinese government to strengthen the protection of the rights and interests of Chinese workers, strictly enforce labor laws, increase penalties for violations of labor laws, form a real deterrent to enterprises, and to strengthen industry supervision mechanisms.

Chart with Summary of Rights Violation 

 

	Mingtu	Chaojun
Gender/ethnic discrimination in hiring*	x
Illegal employment of students from vocational schools or underage workers*	x	x
Disrespecting workers’ will to choose their jobs	x
Disrespectful or bullying behavior towards workers	x	x
Harsh disciplinary actions	x	x
Excessive productivity targets	x	x
Excessive overtime*	x	x
Unpaid overtime*	x	x
Non-transparency over wage structure	x	x
Illegal contracts*	x	x
Lack of contract for temporary workers*	x	x
Workers’ lack of possession of a copy of their labor contract*	x	x
Unpaid wages under the conditions of “self resignation,” requiring application for resignation*	x	x
Lack of 24 hrs of safety training*	x	x
Lack of protection gears*		x
Failure in providing insurance in accordance to the law*	x	x
Difficulty in getting a leave*	x
Unpaid sick leaves*	x	x
The lack of or low numbers of paid annual leaves*	x
Lack of entertainment facilities	x	x
Bad workplace environment	Noise	Noise and heat
Lack of independent workers’ representative and organizing	x	x
Lack of effective channels for complaints	x	x
Failing inspections over industrial wastewater*	x	x

(Note: “*” represents a violation of China’s Labor Law and other relevant laws)