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。Www.11665.COm[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.
[19]status of labour ？employment in vietnam（hanoi ：ministry of labour ，invalids and social affairs ，statistical publishing house ，1997），table c3.3.0.01.
[20]the figure can only be approximate.the 1993data from the ministry oflabour showed total unemployment of 8.3million.in china ，the registered unemploymentrate is low ，only about 3per cent，but the number of workers who are not paidfull wages or have to stay home is large，reaching 18per cent of soe workers.the situation in vietnam is quite similar.many workers continue to stay in thestate enterprises even though they are employed only part-time or are without work.so long as they are not formally laid off they are counted as employed.in somecities this figure is as high as 20per cent.in recent years ，though ，therehas been a falling unemployment rate.seestatistical yearbook，1995（hanoi ：general statistical office，1996），p.39；vietnam economic commentary and analysis，no.6，1994，p.29.
[21]vietnamese news，14may 1996，p.4.according to the labour survey of1996，unemployment decreased considerably from 1994to 1996，down to 4per cent.unemployment declined especially in the newly expanding cities and special economiczones ，whereas it increased in other urban areas.status of labour？employmentin vietnam，pp.66-7.
[22]vietnamese investment review ，24-30october 1994，p.18.
[23]irene ntrlund，？vietnamese industry in transition ：changes in the textilesectorì，in irene ntrlund ，carolyn l.gates and vu ca dam （eds ），vietnamin a changing world （richmond：curzon press ，1995），p.138.
[24]this information was gained from six weeks of visits to footwear factoriesin shanghai and beijing in 1995and 1996.in addition ，a series of interviewswas conducted with a variety of government officials and trade union cadres whosework is related to the leather goods industry.
[25]no government department has figures on the exact number of footwear factoriesin the country.keen competition was felt by almost all of the factories visited.even those which had been making steady yearly profits up till 1993saw profitsdecline.in vietnam ，because of the competition from foreign goods，there isalso a sense of ？over-production ì。see norlund，？vietnamese industry in transitionì，p.143.
[26]information from 1995fieldwork in beijing.
[27]more often than not，in the older state enterprises the ratio of retireesto employees can be as high as 1：2.since under the chinese system the work unititself has to support the entire range of welfare of its own staff and workers，this has become a heavy burden on financially troubled firms.the government's recentpolicy is to replace this system with an entirely new one whereby all welfare servicesare centralized at the city level ，thus evening out welfare responsibilities amongall enterprises.but state enterprises which are in the red lack the funds to participatein the new program，and thus remain trapped in a vicious cycle.
[28]in the textile industry，for instance ，state-sector workers have beenmade to work at very fast rates for long hours.see zhao minghua and theo nichols，？management control of labour in state-owned enterprises：cases from the textileindustryì，the china journal，no.36（july 1996），pp.1-21.
[29]dorothy solinger ，？the chinese work unit and transient labor in the transitionfrom socialismì，modern china ，vol.21，no.2（april 1995），pp.155-85.ourfield research in shanghai in 1995also indicated that this is an increasing trend.
[30]china labour bulletin [hong kong]，no.3，may 1994，pp.8-9.
[31]globe and mail [canada]，18july 1997；china labour bulletin，no.37，july/august 1997，pp.13-14.
[32]anita chan ，？the emerging patterns of industrial relations in china andthe rise of two new labour movementsì，china information，vol.ix，no.4（spring1995），p.58.
[33]institute of labour science and social affairs of the ministry of labour，july 1994.
[34]vietnamese investment review ，22-29november 1993；70strikes were recordedin 1992-93.also see？vietnam labour law fails to halt strikesì（hanoi ：agencefrance presse ，9july 1995）；and vietnamese trade union ，no.3，1995，pp.27-8.
[35]communication from the committee for the defence of workers'rights invietnam ，france and associated press，hanoi，25september 1997，referring toa union inspection report in vietnam.
[36]according to a survey carried out by the guangdong provincial general tradeunion in 1994，34.5per cent of the workers interviewed said there was no extrapay for overtime work ；and 32per cent were paid below the minimum wage （yuegangxinxi shibao [guangdong-hong kong information newspaper]，2april 1994）。a surveyin vietnam revealed that 15per cent of foreign-funded enterprises paid employeesless than the official minimum wage of us$35per month set for hanoi and ho chiminh city （vietnam investment review ，9-15january 1995，p.25）。
[37]for example，for violations of labour laws by taiwanese and korean-ownedfactories that make nike shoes，see lao dong [labour]，19november 1997；forviolations by such factories in china ，see the asia monitor research centre report，？conditions of workers in the shoe industry in chinaì，november 1995.this doesnot apply in china and vietnam to some of the large capital-intensive ，high-techenterprises that are owned by western firms ，which operate on a management philosophythat is softer on workers.see anita chan ，？the emerging patterns ì，esp.pp.45-8.
[38]the information on china comes from interviews in 1994at beijing's acftuheadquarters；information on vietnam came from the denmark interviews of 1995.talks with trade unionists from indonesia and with australian business consultantslend support to this observation，as does a report in the far eastern economicreview，22august 1996，p.63.
[39]taiwanese capital began to flow into vietnam earlier than from other countries.taiwan was the major investor in vietnam until 1997，when singapore became thelargest ，followed by taiwan ，hong kong，japan and south korea.the largestinvestor in the mainland of china is hong kong，followed by taiwan.
[40]gongren ribao，21may 1996，p.5.
[41]beijing review ，vol.38，no.20（15-21may 1995），p.18.the reportingon labour disturbances in foreign-funded firms has become more forthright.in the1980s the party specifically banned such news from the press（information from ashanghai researcher on labour issues）。
[42]gongren ribao，11november 1993.two cases were cited in this article.in one，a manager in a garment factory hired a police officer to be deputy managerwith the express purpose of controlling the workers.when the workers could no longerstand the protracted hours of overtime work ，several of them launched a protest.the policeman-turned-manager first fired the？trouble-makersì，then got his colleaguesin the police station to arrest them.they were released after the interventionof the local union.another case involved a foreign manager who ，just before firinga batch of workers，called in the police.as each of the names of the unfortunateworkers was called，they were？accompanied ìto the gate by a policeman.in anothercase，when some workers started complaining after being owed wages for 7-8months，police were sent into the dormitory to beat up the workers'representatives （zhuhailaodong bao [zhuhai labour news]，24october 1994）。the use of police and privatesecurity guards with connections to the police is very prevalent in south china（based on field findings in january 1996）。one taiwanese joint-venture firmin south china employed 100security guards for only 2，700workers （gongren ribao，17april 1996，p.7）。
