Conclusion
In spite of starting from a very similar base ，the VGCL has succeeded in gainingsomewhat greater autonomy from the Party and government than has its Chinese counterpart.It cannot be said that the VGCL is independent，but at least it has begun to developa two-way ？transmission belt ì。There are signs that the Vietnamese governmentis genuinely interested in establishing a more clear-cut demarcation between managementand trade unions.The ACFTU ，in contrast，remains essentially a belt for one-waytop-down traffic.
We have traced the historical reasons that have contributed to this difference.Because of Vietnam's wars ，the Vietnamese Communist Party's control was neveras far-reaching as the Chinese Party's.Although Vietnam introduced economic reformslater than China，once it had commenced the VGCL was quickly able to manoeuvrefor increased space to defend workers'interests.The difference in attitude betweenthe two nations'parties toward their respective trade unions has been crucial.Field observations indicate that the VCP is more supportive of the trade unionsthan of foreign management.
Once the VGCL was allowed the space to act more independently ，a sequenceof events helped to consolidate its position.As seen ，the VGCL was able openlyto debate the drafts of the trade-union and labour laws ，and these contained severalimportant rights：to organize，to strike，to change its internal structure ，to join the international labour community，and so on.Of critical importance ispermission to initiate new non-government-sponsored labour groups and an organizationalstructure for the official unions that shifts the initiative increasingly towardsectoral industrial unions rather than unions based on locality.The ongoing publicdebate between the VGCL and the government over the issue of a minimum wage maywell be a prelude to future peak-level collective bargaining.The right to strikeis a big step forward ，although it is undermined by lengthy ，cumbersome strikeprocedural rules that effectively rendered all of the strikes that broke out in1995technically illegal.To gain further space to protect labour rights，Vietnameseworkers and the VGCL will have to continue to fight for better pro-labour industrialarbitration and strike procedures and to press for serious enforcement of the labourlaws.
Two reports illustrate well our conclusion that the two countries'labour regimesare following diverging paths.In 1996，after public outcry in Vietnam over a spateof media reports about Korean and Taiwanese managers'physical maltreatment of workers，Lao dong，the VGCL's official paper，took to task a Taiwanese supervisor who hadbeen known to beat workers.In defence of his violent management style，the supervisorwas quoted as saying，？before coming to Vietnam he had spent six years workingin China where he claimed it was normal to beat workers ì。[100]The second report，published in Shanghai gongyun [Shanghai labour movement]，was written by the headof the International Liaison Department of the Shanghai General Trade Union ，aftervisiting Vietnam in mid-1995.In the article he betrayed unmistakable envy.Lookat the circumstances of the Vietnamese trade unions ，he wrote.Their law guaranteesthe right to strike ；the VGCL's newspaper ，Lao dong ，can use front-page headlinesto criticize the government and individual officials；the Vietnamese Party informsthe VGCL of all major policies；the Party supports the VGCL in its work；whenthe trade union and the government have contradictions，the Party usually sideswith the trade union；the government consults with the VGCL prior to adjustingprices；and，above all，trade union chairs at enterprises receive their pay andduty assignments from the upper levels of the trade union （rather than the enterprise）。That is why ？to a large extent they dare to speak up and work on behalf of theworkers ì。[101]
He and the rest of the Chinese delegation may have been too starry-eyed ，andthe VGCL may have gone to great lengths to impress them ，but as fellow trade unionistsfrom the same Communist stock ，their sensitivity to the differences cannot easilybe dismissed.At least some Chinese trade unionists look enviously toward the Vietnamesefor inspiration.
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[1]In the first four decades of Party rule ，Chinese workers expressed massdissatisfaction several times ，but at none of these times did they turn to theunion for assistance.During the Maoist period the contention was largely over politicalcontrol rather than control over the labour process.In Vietnam during these samedecades ，the workers did not challenge the state in the same fashion because thenation's attention was focused on the war.
[2]Thanks to Melinda Tria Kerkvliet for providing us with this information.
[3]This information was obtained from a group interview we conducted with twentytrade union officials who were undergoing training in Denmark with the General Worker'sUnion in June 1995（henceforth referred to as the 1995Denmark interview）。
[4]Boris Kagarlitsky and Renfrey Clarke，？Russia's Trade Union Movement ：Bureaucrats and Militants in the Epoch of Capitalist Restorationì，Links，no.1，April-June 1994，pp.19-28.According to SID labour organizer Sten Pedersen，whohas carried out training courses for many Eastern European unions since the collapseof communism in their countries ，the former official unions in all these post-Communistcountries have outlasted the new alternative unions.Even in Poland the former officialunion continues to have a much larger membership than Solidarity.
[5]Elizabeth Perry ，？Labour's Battle for Political Space ：The Role of WorkerAssociations in Contemporary Chinaì，in Deborah Davis ，Richard Kraus，BarryNaughton and Elizabeth Perry（eds ），Urban Space in Contemporary China：The Potentialfor Autonomy and Community in Post-Mao China（Cambridge ：University of CambridgePress ，1995），pp.302-25.Also see Anita Chan ，？Revolution or Corporatism ？Workers and Trade Unions in Post-Mao Chinaì，Australian Journal of Chinese Affairs，no.29（January 1993），pp.31-5.
[6]Gabriel Kolko ，？Vietnam Since 1975：Winning a War and Losing the Peaceì，Journal of Contemporary Asia ，vol.25，no.1（1995），pp.4，6.
[7]Andrew Walder ，Communist Neo-Traditionalism ：Work and Authority in ChineseIndustry（Berkeley：University of California Press ，1986），ch.6.
[8]See Trinh Quang Quy ，The Labour Movement in Vietnam （publisher unknown，1970），pp.41，117-18.We are grateful to Melinda Tria Kerkvliet for drawing ourattention to this book.
[9]See ，for example，David Wurfel ，？Doi Moi in Comparative Perspectiveì，in William S.Turley and Mark Selden （eds ），Reinventing Vietnamese Socialism：Doi Moi in Comparative Perspective （Boulder ：Westview Press ，1993），p.47.
[10]Andrew G.Walder and Gong Xiaoxia，？Workers in the Tiananmen Protests：The Politics of the Beijing Workers'Autonomous Federation ì，Australian Journalof Chinese Affairs，no.29（June 1993），pp.1-29.
[11]Japan Economic Newswire，27October 1994；Zhongguo tongji [China's statistics]，no.1，1996，p.27；and Reuters，Beijing，23June 1997.
[12]Japan Economic Newswire，27October 1994.
[13]Zhongguo laodong bao [China labour news]，13June 1996.
[14]Gongren ribao [Workers'daily]，30November 1995.
[15]Nanfang gongbao [Southern workers'news]，29April 1997.
[16]Gongren ribao，7March 1996.
[17]Tran Hoang Kim ，Economy of Vietnam ：Review and Statistics（Hanoi ：Statistical Publishing House，1994），p.146.The number for 1992is a littlehigher（695，000）。See Statistical Yearbook of Labour ，Invalids and SocialAffairs 1993（Hanoi ：National Political Publishing House，1994），p.45.Alsosee Dang Duc Dam，Vietnam's Economy 1886-95（Hanoi ：Gioi Publishers，1995）。In Vietnamese statistics the industrial labour force is not divided into urban andrural.However，unlike China ，very few of the state enterprises are located outsidethe cities.
[18]Only 11-12per cent of Vietnam's workforce was employed in the industrialsector，of which 30per cent worked in the central state sector as of 1985.SeeMelanie Beresford ，？The North Vietnamese State-Owned Industrial Sector：Continuityand Changeì，The Journal of Communist Studies and Transition Politics ，vol.11，no.1（March 1995）p.56.By 1993this had dropped to a little over 10per cent ofthe manufacturing labour force.See Statistical Yearbook of Labour，1993，p.45.Also see Irene Ntrlund，？The Labour Market in Vietnam：Between State Incorporationand Autonomyì，in J.D.Schmidt ，Niels Fold and Jacques Hersh （eds ），SocialChange in Southeast Asia（Harlow：Addison Wesley Longman ，1998），pp.155-82.
VIETNAMESE AND CHINESE LABOUR REGIMES:ON THE ROAD TO
VIETNAMESE AND CHINESE LABOUR REGIMES:ON THE ROAD TO