Unpicking the German Supply Chain Act: How the fashion industry is failing to address labor rights violations in Pakistan

National Trade Union Federation of Pakistan (NTUF),
European Center for Constitutional and Human Rights (ECCHR),
FEMNET
Report
2025

In spring 2023, the National Trade Union Federation (NTUF), with the support of the European Center for Constitutional and Human Rights (ECCHR) and FEMNET, carried out a survey of 350 workers in factories in Karachi, one of the main textile export hubs in Pakistan. The survey results were unambiguous: violations of domestic and international labor law were recorded across all the factories, including non-payment of minimum wages. 

Based on these survey results, we filed internal complaints with the grievance mechanisms of seven brands with supply chain links to these factories, highlighting their potential non-compliance with the LkSG. The outcome of this process, which encompassed more than a year of engagement with brands yet resulted in no tangible improvements at factory level, raises important questions on the extent to which the LkSG is so far being effectively implemented in the garment industry.  
By evaluating the responses of the brands in comparison to their legal due diligence obligations, the report identifies clear areas of potential non-compliance:

• Insufficient consultation with affected stakeholders.
• Overreliance on social audits.
• Failure to address purchasing practices.

The objective of the LkSG is to strengthen the protection of human rights in supply chains. Yet in practice, its implementation risks becoming another superficial corporate compliance exercise.