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  • On 21 December 2025, China Labor Watch filed a BAFA complaint against Apple, alleging forced labour at supplier Foxconn’s Zhengzhou facility, under the German Supply Chain Due Diligence Act (LkSG). 
  • China Labor Watch first submitted an internal complaint directly to Apple, but received no response. 
  • The full complaint has not been published, however. A September 2025 investigative report on Foxconn Zhengzhou appears to form the basis. 
  • The investigation was conducted on the ground by investigators working inside the factory and speaking with other workers. 
  • The report outlines extensive allegations of labour rights violations, including exclusion of Uyghur, Tibetan, Hui and Yi workers. Since the Zhengzhou facilities are located in Henan province rather than XUAR, this is unlikely to concern XUAR state-sponsored forced labour. This alert is limited to allegations linked to ILO forced labour indicators.

Key forced labour allegations in the report

  • Excessive overtime – Overtime consistently exceeded legal limits, reaching 65–130 hours during peak season.
  • Worker surveillance – Invasive bag checks, confiscation and inspection of personal electronics with identity and fingerprint recording and online monitoring. 
  • Bullying/harassment – Sexist harassment and stalking reported by women workers; supervisors verbally abused workers and denied overtime as punishment.
  • Dormitory conditions – Dormitories were overcrowded, poorly maintained and balconies were sealed to prevent suicide attempts.

Additional context

  • Separately, China Labor Watch has announced plans to submit a BAFA complaint against Chinese automobile tyre manufacturer Linglong for forced labour allegations in its Serbian operations, following a US Withhold Release Order issued on 18 December.
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