[70]Tu Le，？The Labour Code in the Life of Workers：Interview with Pham GiaThieu ì，Vietnamese Trade Union ，no.4，1994，p.7；Eva Hansson，Trade Unionsand Doi Moi ：The Changing Role of Trade Unions in the Era of Economic Liberalizationin Vietnam（Stockholm ：Department of Political Science，University of Stockholm，Fall 1994），p.22；Nguyen Tri Dung，？Minimum Working Age Fixed at 15ì，VietnamInvestment Review ，6-12June 1994；Lan Thanh，？National Assembly Debates LabourCodeì，Vietnam Investment Review，3-9January 1994，p.21.
[71]Anita Chan ，？The Emerging Patternsì，p.54.
[72]Tu Le，？The Labour Code in the Life of Workersì，notes that the ILOhad given advice in relation to the formulation of the labour law in Vietnam.Alsosee Vietnam ：Employment and the New Labour Law（Canberra：Department of ForeignAffairs and Trade [Australia]，Southeast Asia section ，Vietnam/Laos section ，October 1994），p.3.In China，the ILO office in Beijing has been actively promotingthe tripartite concept in China.（This information is based on interviews with theILO Beijing director in 1994and on ILO documents on China.）
[73]The Chinese law does not have an article on wage deductions，but China's ？Provisional Regulation on the Payment of Wagesìsets the maximum deductions at 20per cent of the monthly wage（issued by China's Ministry of Labour，December 1994）。
[74]Vietnam Investment Review，25April-1May 1994.
[75]Do Muoi's address to the congress of the VGCL，3November 1993（FBIS-EAS，12November 1993）。This was confirmed during visits to several enterprises inMarch 1996and from September to December 1996.
[76]The power relations of these institutions in the state enterprises aredelineated in the Enterprise Law that was passed in 1988（Renmin ribao，16April1988，p.2）。Our comments on how this relationship is working out in the statefirms are based on field observations and conversations with trade union officialsin 1995.A similar trend was noted by You Ji during his field research in 1992：see ？Dismantling Party/State Controls in China's State Enterprises ì，PhD dissertation，Australian National University，1993，pp.40-153.
[77]An interview with an ACFTU official in charge of organizational mattersin 1994provided a figure of 20-30per cent ，and the official thought that wasan under-estimate.In mid-1994a report provided a figure of 12per cent of 170，000foreign-funded firms as unionized.See Beijing Review ，vol.37，no.28（11-17July 1994），p.7.But in mid-1995，a year later ，a report stated that 10percent of the 100，000foreign firms that were in operation（out of 200，000thatwere registered ）had unions.Beijing Review ，vol.38，no.20（15-21May 1995），p.19.
[78]This was the scenario in the notorious case of the Zhili Toy Factory whichcaught fire ；84workers who had been locked in behind barred windows burned todeath.Yi Fu，？Feixushang de pingdiao：Shenzhen `11.19'teda huozai shigu jishiyu fanziì[Pondering at the ruins ：reflections and records of the Shenzhen November19th fire disaster]，Zhongguo gongren [Chinese worker]，no.5，1994，pp.4-8；also no.6，1994，pp.8-11.
[79]This is from a document we obtained that was circulated by the GuangdongProvince Trade Union Research Department，dated June 1993.
[80]Information based on 1995fieldwork in Shanghai.For details on how newtrade unions are being set up ，see Anita Chan ，？Labor Relations in Foreign-fundedVenturesì，in Gregory O'Leary （ed.），Adjusting to Capitalism：Chinese Workersand Their State （Armonk：M.E.Sharpe ，1987），pp.122-50.There are rare casesin China，though ，where a new union is formed through workers'demands.One oft-quotedcase is the Japanese-owned Garden Hotel in Shanghai.The new trade union and itschair emerged from a spontaneous industrial dispute ，and were recognized by theShanghai General Federation of Trade Unions.The new chairperson，taking his responsibilityseriously ，resigned from his middle-ranking managerial staff position so as todevote himself full-time to union work.Reportedly，genuine collective bargaininghas been taking place regularly at this hotel.Shanghai gongyun ，no.11，1994，pp.19-21.
[81]Vietnam Investment Review，18-24July 1994，p.12.
[82]Far Eastern Economic Review，25January 1996，p.22.
[83]This is based on Irene Ntrlund's field observations in 1996.
[84]Lao dong [Labour]，no.27/96（3March 1996）；no.33/96（17March 1996）。A year later the taxi drivers'union merged with other unions under the Ho ChiMinh City Federation of Labour.
[85]Information from the VGCL based on March 1996field research by Norlund.
[86]See Gerard Greenfield，？Strikes in Vietnam：Between Discipline and Dignityì，Asian Labour Update，August-October 1995，pp.25-7.Greenfield also notesthe emergence of labour associations，but the figure he cites is higher？700labourassociations by mid-1993.
[87]Also see Gareth Porter ，Vietnam：The Politics of Bureaucratic Socialism，p.92.
[88]Based on interviews in 1994with the national secretary and a member ofthe staff of the Australian Public Sector Union who went to Vietnam for the program.Also see an article written by a representative of the Trades and Labour Councilof Western Australia in Vietnamese Trade Union，no.1，1995，pp.19-20.
[89]Information from the VGCL，March 1996.
[90]Based on Chan's interview in Hanoi with the vice-president of this newunion in January 1998.
[91]Vietnamese Trade Union ，no.4，1997，p.8.
[92]This observation was made by the director of the ILO office in Beijingin 1995.Also ，in 1995a high-level official of the Shanghai General Trade Uniontold us that the time was not yet ripe to discuss strengthening of the industrialunions in China.See Gordon White ，Jude Howell and Shang Xiaoyuan ，In Searchof Civil Society：Market Reform and Social Change in Contemporary China（Oxford：Clarendon Press，1996），p.60.
[93]China Labour Bulletin，no.2，April 1994，pp.17-19；no.15，June1995，pp.7-8；no.24，March 1996，p.4.
[94]Nanyang gongbao [Southeast Asian workers'news]，4April 1996.
[95]In November 1996two young people were formally prosecuted for seditionafter been jailed for two years without trial for organizing a？Migrant Workers'Federationìand ？Migrant Workers'Friendship Clubì（China Labour Bulletin ，pressrelease ，12November 1996）。
[96]Information based on a telephone conversation in May 1996with the internationalofficer of the Australian Council of Trade Unions ，who thought this a significantdevelopment that was unimaginable three years back.
[97]The VGCL fought over several years to raise the minimum wage from US$35to US$50a month in Ho Chi Minh City，but without success.Vietnam Investment Review，23-29May 1994，p.5.Finally ，in 1996，it was increased to US$50a month.
[98]Vietnam Investment Review，21-27November 1994，p.6.
[99]This information was based on an interview with an ACFTU official in Beijingin 1992.
[100]Transcript of Australian Broadcast Corporation radio program，？Reportfrom Asia ì，31August 1996.Another example is the VGCL's willingness to workwith foreign NGOs to help expose Taiwanese and Korean managers'mistreatment ofVietnamese workers.（Based on a series of email communications in 1996and 1997with Thuyen Nguyen of the New-York based Vietnam Labour Watch.）
[101]Zhao Shunzhang，？Impressions of the Vietnamese Trade Union ：Observationsby the Shanghai Federation Delegation ì，Shanghai gongyun ，no.10，1995，pp.41-2.
VIETNAMESE AND CHINESE LABOUR REGIMES:ON THE ROAD TO
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