A. Introduction

The soccer ball industry of Pakistan, principally concentrated in the city of Sialkot, has been under scrutiny in recent years for employing child workers. Manyreports describe children stitching soccer balls in small rural workshops or in homes. ¹ The widespread coverage of children stitching soccer balls galvanized consumers,labor and religious groups and government officials to call for a stop to this practice.In June 1996, the U. S. Secretary of Labor and members of Congress helped launch the FoulBall campaign to ensure that soccer balls used by American children arestitched by adults and not children. ²

The public attention led U. S. importers to enter into an agreement with Paki-stani manufacturers, the ILO and UNICEF to stop using child labor. ³ More recently, public attention has focused on the use of child labor in India's soccer ball industry, leading to negotiations between Indian soccer ball manufacturers, exporters, NGOsand international organizations to develop a code of conduct prohibiting child labor.

In addition, individual companies have taken steps to assure consumers thattheir products are not made by children. They have done so by revising their production process or creating child labor labels. For instance, Reebok has centralized all its soccer ball production in a new factory. ⁴ Nike also changed its manufacturing process in Pakistan by creating new stitching centers in order to better ensure chil-dren are not stitching Nike soccer balls. ⁵ Some U. S. importers, including Reebok and Baden Sports, have begun to label their soccer balls as produced without child labor. These labeling programs are the primary focus of this chapter. Information about labeling programs has been obtained from the companies using labels, from surveys of U. S. importers and retailers, and from field visits to India, Pakistan and China by Department of Labor officials. Section B of this chapter presents an overview of the industry and the market for soccer balls in the United States. Section C examines the role children play in the production of soccer balls around the world. Section D describes various labelingprograms. Finally, Section E reports responses of U. S.- based soccer ball importers and retailers to the child labor issue, based on a voluntary survey.

B. Industry Profile

Soccer, or "football" as it is known in most countries, is the world's mostpopular sport. ⁶ Although soccer gained popularity slowly in the United States, enthusiasm for the sport has grown in recent years. ⁷ In 1980, there were fewer than 1 million youths registered to play soccer; by 1996 this figure had tripled to over 3 million. ⁸

Growth in the volume of U. S. imports of soccer balls reflects this trend. AsTable IV- 1 illustrates, in 1989, U. S. soccer ball imports were valued at $15.7 million;by 1996, the comparable figure was $34.2 million, a growth of 118 percent. ⁹ FigureIV- 1 lists U. S. imports of soccer balls by country and value. Some 71 percent ofthose imports came from Pakistan, 19 percent from China, 5 percent from Indonesia,1 percent from India, and the remaining 4 percent from other countries. ¹⁰ Soccerballs are not produced in the United States. ¹¹

Soccer balls generally consist of a number of synthetic leather panels stitchedtogether in geometric patterns on the outside with an inflatable bladder inside. ¹² Panels in high quality balls are hand- stitched for durability. ¹³ Hand- stitching these panels together is a very labor- intensive process and is where children have been found working.

Figure IV- 2 illustrates the chain of production within the international soccerball industry. This schematic also highlights relationships among the various entitiesresponsible for production. The key actors can be described as follows: ¹⁴

• Retailers typically sell a wide range of sporting goods, including soccer balls. They are not normally direct soccer balls importers; instead, they order the balls from brand name merchandisers. Retail outlets selling soccer balls include nationwide sporting goods or soccer specialty stores, independent sporting goods stores, department stores, mass-merchandisers, and toy stores.
• Importers/ Design and Marketing Firms/ Merchandisers develop ball specifications and marketing strategies to promote their particular brand. They do not own the factories producing the balls, but contract with foreign manufacturers who produce the made-to-order balls. Some merchandisers have their own retail outlets for the sale of soccer balls and other products.
• Contractors are foreign manufacturers who produce soccer balls for U. S. importers/ design and marketing firms/ merchandisers. They may produce soccer balls for several different buyers. Contractors usually do some of the production in their factories (e. g., cutting and packing), and outsource stitching and other tasks to subcontractors.

Table IV-1
U.S. Soccer Ball Imports, 1989-1996,
Top 10 Suppliers
(in thousands of U.S. dollars)

Note: In 1989, Korea was the largest supplier of soccer balls to the United States, followed by Pakistan. As of 1996, Korea no longer produced soccer balls for the U.S. market.

Source: Official Statistics of the U.S. Department of Commerce

• Subcontractors are individuals who function as middlemen between the  contractor and village stitchers. ¹⁵ Subcontractors typically deliver soccer ball kits to workers in surrounding villages. After the stitching is completed, the subcontractor pays the stitchers and returns the completed kits to the contractor.
• Stitchers sew together the panels of a soccer ball and glue in the inflatable bladder. They are employed by subcontractors, typically on a piece rate basis, and may work in a stitching center, small village workshop, or in homes.

C. Child Labor in the Soccer Ball Industry

The use of child labor in the production of soccer balls has been documentedprimarily in Pakistan and India. ¹⁶ Soccer balls are also made in China and Indonesia, but there are no known allegations of child labor in the soccer ball industries of these countries.

The manufacture of soccer balls is controlled from the city but decentralized to homes and small workshops in surrounding villages. At the city factories or warehouses, the designs are printed and the pieces are cut. These are then packed into sacks and handed over to middlemen or subcontractors who distribute them in villages to families and workshops, where stitching traditionally is done both by adults and children. Subcontractors provide soccer ball kits to village workshops and/or households, where workers hand-stitch individual pieces together, glue the bladder to the material, and sew in the final piece. Some of the larger subcontractors in Pakistan have up to 300 stitchers working for them. ¹⁷ In some instances, there may be two or more tiers of subcontractors, with the balls passing through many hands on the way from the stitcher to the manufacturer. Once completed, the stitched soccer balls are then brought back by the middlemen to the factories for packing andshipment.

Pakistan

Nearly all soccer balls are made in and around Sialkot, Pakistan — a regionfamous as a soccer ball producing hub for at least 80 years. ¹⁸ Seventy-five percent of the world's soccer balls were produced in Sialkot in 1996. ¹⁹ It is estimated that there are about 10,000 urban workers and 30,000 rural workers in the 1,450 surrounding villages of Sialkot involved in
the production of soccer balls. ²⁰

As recently as 1995, Pakistani soccer ball manufacturers denied that children were stitching soccer balls. The Human Rights Commission of Pakistan noted that when they visited Sialkot in 1995, manufacturers seemed to have instructed their contractors not to talk about child labor, and taken the contractors to task, "not so much for employing child labor as for letting it become visible." ²¹ At the time, theCommission reported that they found many children working in the soccer ball industry, despite the local industry's best efforts to conceal the children from view. ²²

In 1996, an ILO study in the Sialkot region estimated that more than 7,000 Pakistani children between the ages of 5 and 14 stitched balls on a regular, full- time basis. ²³ In addition, large numbers of children worked part-time outside of school hours. The great majority of these children were boys.

More than 90 percent of the children stitching soccer balls are between theages of 10 and 14. ²⁴ Most work in small shops or at home. ²⁵ Seventy percent of the children work 8 to 9 hours a day; others work 10 to 11 hours per day. ²⁶ It is estimated that 19 percent of the boys and 36 percent of the girls have never attended school. ²⁷ Twenty-two percent of the boys and 25 percent of the girls attend school and work. ²⁸ Although most of the child workers can read and write, many havedropped out of school because of uninteresting curricula, unsympathetic teachers and an uncomfortable school environment. ²⁹

A recent study conducted for the Soccer Industry Council of America (SICA)found that stitchers make between 20 to 30 Pakistani rupees, or approximately $0.50 to $0.75, per ball. ³⁰ On average, children are paid 20 to 22 Pakistani rupees per ball, or about $0.50 to $0.55. Payment tends to vary according to ball quality. ³¹ Most high quality balls are stitched by adults at stitching centers. The ILO reports that children are not likely to stitch high quality balls because they are not strong enough to make the required stitches. The wages for high quality balls are almost double than thosefor lower quality balls. ³² Depending upon skill and experience, a person is reportedly able to stitch between 1 and 5 balls a day. ³³

There have been allegations of debt servitude in the soccer ball industry in Pakistan, ³⁴ charges denied by Pakistani manufacturers ³⁵ and a recent Save the Children-UK report. ³⁶ However, the study commissioned by the Soccer Industry Council of America (SICA), the Save the Children report and a study conducted jointly by the ILO and the Punjab Department of Labor acknowledge that many families in thesoccer ball industry take loans or advances from subcontractors. ³⁷ The advances are generally repaid through a deduction in the amount paid to the stitchers. ³⁸ Most reports, however, are careful to note that intergenerational debt-bondage is not prevalent in the soccer ball industry.

India

India's sporting goods industry has its roots in Sialkot, Pakistan. When India was partitioned at independence in 1947, many of Sialkot's skilled Hindi craftsmen migrated across the border into the Punjab, settling in Jalandhar, where the Indian sporting goods industry is now based. ³⁹ The Indian sporting goods industry has expanded to include the areas of Meerut, Uttar Pradesh, and Gurgaon, Haryana. Most of India's sporting goods, including soccer balls, are exported to the United Kingdom. Allegations of child labor in India's soccer ball industry have appeared since 1994. ⁴⁰ Although these allegations were initially repudiated by some members of the Indian Sports Goods Export Promotion Council, recent public statements by members of the industry are more qualified, denying that child labor is used inmembers' factories, but acknowledging that the practice may occur through the process of contracting out to homeworkers. ⁴¹ About 300,000 persons work in the sporting goods industry producing over 200 different products. ⁴² It is estimated that about 10 percent of this work force, or 25,000 to 30,000 workers, are children. ⁴³

Soccer ball production in India is similar to that in Pakistan: middlemen distribute soccer ball kits provided by large factories to small workshops and homes in surrounding villages, where soccer balls are stitched and returned. A 1997 study by Christian Aid, a British NGO, found children as young as seven stitching soccerballs in their homes. ⁴⁴ The report described children working in small workshops orat home in urban slum areas and remote villages. ⁴⁵ They work for many hours stitching the soccer balls while sitting in a hunched, squatting position. Some of thechildren go to school as well as work. ⁴⁶ The report quotes the director of a Jalandhar soccer ball company as saying, "the football industry uses children at the age of 10or 12. The quantity of footballs exported is too much to employ all the people we need in factories. Women and children do it in their houses whenever they get freetime." ⁴⁷

As in Pakistan, stitchers are paid per completed ball. One major exporter stated that stitchers average 13 to 14 Indian rupees per ball ($ 0.37 - $0.39) for the low quality soccer balls, and between 20 and 22 Indian rupees per ball ($ 0.56-$0.62cents) for the most commonly produced medium quality balls. Some Indian children reportedly earn as little as 7 Indian rupees per ball, or about $0.20. ⁴⁸

D. Consumer Labeling Programs in the Soccer Ball Industry

1. Introduction

Adverse publicity in the United States and Europe about children stitchingsoccer balls prompted some importers to adopt labels informing consumers that their products have been produced in a child labor-free environment. In some cases, these programs are accompanied by changes in production processes to prevent theemployment of children.

Although some individual companies have developed labels for their soccer balls, the majority of the soccer ball industry has opted instead to implement avariety of different codes of conduct to prohibit and prevent child labor. At a November 1996 meeting of the World Federation of the Sporting Goods Industry (WFSGI), companies rejected the possibility of labeling products, concluding that "our ownindustrial brand names were statements of quality and ethics in their own rights and any disclaimer put on a separate label would only weaken that statement and the perception of the brand." ⁴⁹ They emphasized that by labeling only some balls, unlabeled balls might unfairly be thought to be made by children. ⁵⁰ On the other hand, the President of the WFSGI commented that over time, it might be conceivable that products would carry a stamp indicating membership in WFSGI. Since the WFSGI isan endorser of the Pakistan Partners' Agreement, such a stamp would imply that aball made in Pakistan fulfilled the no child labor requirements of this agreement. ⁵¹ In making this proposal, the President noted that for such a stamp to be credible, it must be backed up by a strong and transparent monitoring system in addition to an enforcement mechanism capable of denying the use of the stamp or expelling members found violating the agreement. ⁵²

Notwithstanding the WFSGI policy, recent evidence shows that child labor labeling is becoming more common in the soccer ball industry. For example, both Reebok and Baden Sports recently began selling soccer balls with a label stating that the balls are not made by children. The Reebok balls are made in Pakistan, while the Baden balls are made in China. The retail chain Dunkin' Donuts sold promotional soccer balls with a no child labor label during the 1997 summer months. Additionally, in response to a Department of Labor survey, the Kmart Corporation provided letters from their suppliers indicating that their balls are, or will be, labeled child labor-free. These labeling programs are described in the next few pages.

2. Reebok

a. Program Overview

Reebok International Ltd. (Reebok) is a leading designer, marketer and worldwide distributor of sports, fitness and casual footwear, apparel, and sporting equipment. Total sales for 1996 were approximately $3.5 billion. ⁵³ Reebok, a publicly held corporation, issued a code of conduct known as the Reebok Human Rights Production Standards in 1992. Among other things, the code of conduct bars the use of child labor in making Reebok products.

Recognizing the high incidence of child workers in the Pakistani soccer ball industry, in June 1996 Reebok officials said they were planning to buy Pakistani-made soccer balls that they "knew with certainty" were not made with child labor. ⁵⁴ Reebok contracted with Moltex Sporting Goods (Pvt.) Ltd., a Pakistani soccer and rugby ball manufacturer, and Reed and Associates, a French company specializing inresearch and development, sourcing and manufacturing of high quality soccer and rugby balls, to build a soccer ball manufacturing plant. The new facility, located in Sialkot, has been making Reebok balls since March 1997.

Soccer balls produced for Reebok by Moltex bear the following label on one of the panels: "Guarantee: Manufactured without child labor." According to company officials, the use of the label allows Reebok to communicate their policy to consumers and stakeholders interested in ending exploitative child labor. Reebok's decision to label soccer balls was based on two factors: (1) increasing concern by consumers about children stitching soccer balls; ⁵⁵ and (2) Reebok's desire to distinguish itself from other brands by centralizing stitching and all other production processes in a single factory and requiring rigorous external monitoring of the facility. Reebok officials state they will be able to place their label on Reebok balls "with absolute confidence. Our consumers will know that Reebok balls are, without any doubt, child labor-free." ⁵⁶

b. Program Structure

The three major elements of Reebok's program include: ⁵⁷

• containment of all production inside a new facility in which all work on Reebok balls is performed, including stitching. All workers must be age 15 or older;
• external monitoring to ensure that: a) children are not entering the workplace, and b) soccer ball panels are not leaving the factory where the risk exists that they may be stitched by children in stitching centers or in homes; and
• support of education and/ or vocational education training for children in the  soccer ball manufacturing region or Pakistan.

Reebok officials acknowledge that there are additional costs associated with creating a new facility that will house all production processes. According to Peter Moore, Senior Vice President of the Global Soccer/ Rugby Division, this shift in manufacturing processes will cost Reebok approximately 15 percent more. ⁵⁸ Reebok saysthese additional costs — associated with pensions, health insurance and transportation for workers at the new factory — will be absorbed by the company; the salesprice of Reebok soccer balls will remain the same. ⁵⁹

c. Program Implementation

According to Reebok, the Sialkot facility began making soccer balls in March1997. Reebok hired three independent monitors to check the effectiveness of the program. Two of the monitors are associated with human rights organizations, ⁶⁰ and the third is a Lahore-based affiliate of a major U. S. accounting firm. ⁶¹ The two human rights monitors were asked to monitor the factory, interview workers, maintain ties to the local community, and visit surrounding villages to be sure no Reebok panels are stitched outside the factory. Each monitor has the right to inspect the facility on an announced or unannounced basis. ⁶² The third monitor was hired to audit factory records in order to correlate the number of balls produced with the number of stitchers in the factory. ⁶³ Reebok intends to make monitoring reports publicly available upon request. ⁶⁴

Reebok says the auditing firm conducted a test audit in March 1997. ⁶⁵ A representative of the auditing firm acknowledged they visited the plant and recommended that a number of accounting measures be implemented so that the firm could begin auditing records by August 1997. ⁶⁶ Reebok notes that because other soccer balls are also being made by Moltex, the auditing process is very difficult.Reebok plans to reassess the value of engaging the outside auditing firm in addition to the human rights monitors. ⁶⁷

Reebok issued the human rights monitors' first report on August 14, 1997, summarizing their findings from March through July 1997. ⁶⁸ During the first five months of the project, the monitors visited the Moltex facility nine times to determine if children were present; three of the visits were unannounced. As of June 4, the monitors had found 236 workers in the factory, including 176 stitchers; 179 artisans working on a contract basis were also present. No children were found at the Moltex facility.

During an April 29 visit, the human rights monitors observed balls being made at Moltex for another major buyer. ⁶⁹ The factory management said these balls were being sent out of the factory for stitching, but were not Reebok balls. In August, Reebok stated it had given Moltex a large enough order to fill up the company's manufacturing capacity, and non-Reebok balls would be out of the factory by September 30. ⁷⁰

The monitors recommended that a plan be devised to clearly assure them that Reebok balls were not being stitched outside the factory. In May, Reebok authorized the human rights monitors to hire a guard to stand at the factory gate tomake sure no Reebok ball panels are commingled with panels for other buyers as they leave the factory to be stitched elsewhere. The guard, who reports directly to the human rights monitors, was hired in June. He has been instructed to make sure that no Reebok panels leave the factory, and that no completed Reebok balls are coming in from the villages or outside stitching centers where children might bepresent. As of the end of July, the monitors informed Reebok that the guard has not observed any problems with Reebok balls entering or leaving the factory.

Reebok has commented on the monitors' report, stating that a number of health and safety concerns in the factory had been communicated to Moltex. ⁷¹ In response, large posters with Reebok's human rights production standards translated into Urdu are being sent to Pakistan. Finally, Reebok acknowledges that a number of record keeping procedures
are not yet complete, such as establishing personnel records with historical data and creating worker identification cards.

In addition to its new ball factory and monitoring project, Reebok is planning an educational project. ⁷² The company has a three-year plan to improve educational opportunities for children in villages in the Sialkot area, specifically targeting displaced child workers. Reebok is working with the Society for Advancement of Education in Sialkot to implement the plan.

3. Baden Sports

a. Program Overview

Baden Sports, Inc. is a family- owned athletic ball manufacturer. Founded eighteen years ago, Baden sells baseballs, basketballs, broom balls, footballs, soccer balls,volleyballs and water polo balls.


Baden now imports soccer balls directly from one manufacturer in China. Baden recently shifted suppliers from Pakistan to China due to "complications facing the industry in solving this [the child labor] problem," ⁷³ and because they "never found the manufacturers in Pakistan to be reliable or trustworthy, and our experience is that you cannot inspect with confidence or expect that the Pakistani companies will adhere to any monitoring programs." ⁷⁴ Recent consumer inquiries, combined with market research indicating great consumer interest in the elimination ofchild labor, are Baden's primary reasons for changing its supplier and production practices.

Baden claims that by switching suppliers to China, it has ensured elimination of child labor in its production of soccer balls: "With our newly automated manufacturing process for patent-pending stitched balls, we can now guarantee, and certifyon the ball itself, that no child or slave labor has been used in the production of oursoccer balls." ⁷⁵ A Baden representative also stated that the shift to China coincided with a corporate decision to produce machine-sewn balls. ⁷⁶

Soccer balls imported by Baden bear the label: "Certified: No Child or Slave Labor Used on this Ball." Baden also intends to produce packaging and advertisements stating that no child labor is used in the production of their soccer balls.

Baden began marketing soccer balls bearing the child labor-free label in 1997. ⁷⁷ In a press release announcing the availability of the product, Baden CEO E. C.Schindler stated "it is our goal to ensure that soccer is played by children, not made by children. We are so sure of the integrity and quality of our products, we certify it." ⁷⁸

b. Program Structure

Baden soccer balls are stitched in China using sewing machines, leaving only the last patch to be hand-stitched after the ball is turned right side out and the bladder inserted. ⁷⁹ This process is done entirely at a factory run by Kuan Ho Sporting Goods Company Ltd., a manufacturing facility located in Dongguan, Guangdong Province, China. ⁸⁰ Baden believes that through machine stitching it can obtain better quality and greater production volume using fewer workers. Baden claims that it can produce soccer balls 50 percent faster using sewing machines than stitching the balls by hand. ⁸¹

Kuan Ho's manager explained the plant's recruitment policy to visiting Department of Labor officials. Under China's labor laws, no one under 16 years of age is permitted to work. About 400 of the 2,400 workers at the factory produce soccer balls. ⁸² According to Kuan Ho's manager, most of the workers are female, earning about 60 to 70 percent above the local minimum wage of 500 yuan ($ 60) a month, or up to 900 yuan ($ 108). ⁸³ The work force is made up almost entirely of migrants from other provinces within China; according to the Kuan Ho manager, they have a stable workforce due to fairly liberal benefits, which include vacations and the possibility of returning home once a year. ⁸⁴

Baden requires written certification from the manufacturer that child labor is not used in the manufacture of Baden products. According to Baden's Asia representative, the company also requires Kuan Ho to allow access to personnel records.

c. Program Implementation

Baden management states that the company's factory representative monitors the Kuan Ho facility weekly. The factory representative explained that he visits the plant to check for quality, design and child labor but did not indicate the frequency of his visits. ⁸⁵ A form verifying the absence of child labor in the production of soccer balls is to be filled out during each visit and signed by Baden's factory representative and an officer of Kuan Ho. ⁸⁶

Baden management states that, in addition to the procedures noted above, it requires its representatives to verify the no child labor statements and representations made by Kuan Ho officials. The factory representative told U. S. Department of Labor officials that during his factory visits, he accepts the word of the plant manager that they are not employing child labor. ⁸⁷ In addition, Baden management stated that a representative from Baden's headquarters occasionally accompanies the factory representative on site visits to verify company policies are being carried out correctly.

The Department of Labor team received a copy of Baden's inspection report of Kuan Ho that certifies no child labor (i.e., no workers under sixteen) was being used in the production of soccer balls. ⁸⁸ The copy of the inspection report itself had been prepared but not yet signed by the Baden representative or the Kuan Homanager. ⁸⁹

Baden has no set policy to deal with the discovery of a child worker. ⁹⁰ KuanHo's plant manager was aware of Baden's child labor concerns even though Baden does not have a written corporate policy on human rights or a special training program that covers this topic. ⁹¹ Workers at Kuan Ho were not aware of the purpose of Baden's labeling program. ⁹² The
firm's management believes that workers do not need to know about such a program, although human resource managers — who are responsible for the hiring — do. ⁹³

Baden states that the price of its soccer balls will likely increase slightly as a result of the new manufacturing and monitoring process.

4. Other Child Labor Consumer Labels

More and more soccer ball companies are promoting child labor labels —particularly since the February 14, 1997 signing of the Partners' Agreement to Eliminate Child Labor in the Soccer Ball Industry in Pakistan ( see Section E. 1). The Department of Labor has received information on seven such labels. All the labelspromise that the soccer balls are not made by children. Only one of the labeling programs, sponsored by Dunkin' Donuts, has a monitoring and certification component. Four of these labels are associated with brand-name soccer balls that are soldin retail outlets. The other two labels are produced both for retail outlets and youth soccer leagues/clubs in the United States.

a. Dunkin' Donuts Promotion

The spread of child labor-free labels for soccer ballsis illustrated by a soccer ball promotion conducted by Dunkin'Donuts franchise outlets in New England during the 1997summer season. ⁹⁴ With any purchase, a customer could buy for $9.99 a hand-stitched soccer ball bearing three logos: the Dunkin' Donuts logo; that of the New England Revolution, the region's professional soccer team; and the statement "Produced Without Child Labor." Posters with a photo of Alexi Lalas, one of the star players of the New England Revolution, were placed in participating Dunkin' Donut stores; many of the posters stated "Ball Produced Without Child Labor" in their right bottom corner. ⁹⁵ The promotion was originally intended to run during the months of June and July but was extended until all the balls in stock are sold.

The idea to put child labor-free labels on the promotional soccer balls came from Dunkin' Donuts New England franchisees, who expressed concern about child labor being used in the production of soccer balls made in Pakistan. ⁹⁶ In response, letters from the U. S. Sporting Goods Manufacturers Association (SGMA) and Talon Sports ⁹⁷ (the Pakistani
manufacturer) were sent to Dunkin' Donuts stating that the balls would not be made by children. A committee of Dunkin' Donuts franchisees was uncomfortable relying solely on the promises of the manufacturer and the trade association. They agreed to approve the campaign only if the balls were certified "child labor-free" by an independent organization.

As a result of the franchisees' concern about the credibility of a "no child labor" guarantee, Dunkin' Donuts, working through a sports marketing consultant in charge of the campaign (Sports Team), requested that a Washington, DC- based NGO— the International Labor Rights Fund (ILRF) — serve as an independent monitor. Consequently, ILRF designed a monitoring program to ensure that soccer balls produced by Talon in Pakistan for Dunkin' Donuts were child labor-free. A six- month agreement between Sports Team and ILRF granted ILRF monitors total access to all Talon facilities, including its factories and stitching centers. Talon provided the ILRF with a map of the 43 stitching centers, a list of the names of all workers, and all of its records. Talon also consented to unannounced visits by the monitors, granting them access to all facilities and the ability to talk to workers without the presence ofsupervisory personnel. ⁹⁸ ILRF monitors reported that they did not find any instances of illegal child labor.

At the end of the summer, Dunkin' Donuts representatives were to evaluatethe soccer ball promotion program and determine whether to launch a spring campaign and whether it should be expanded beyond New England. ⁹⁹

b. Individual Company Labels

Another example of new labels informing consumers that a soccer ball ismade without child labor is that of individual companies promising that their balls are made only by adults. In response to the Department of Labor's voluntary survey, the Kmart Corporation provided the Department with letters from Seneca Sports,Inc., Franklin Sports, Inc., Molten U. S. A. and Spalding Sports Worldwide stating thatthey have or are planning to have a labeling program for soccer balls sold in Kmart stores. All four of the companies have endorsed the Partners' Agreement to Eliminate Child Labour in the Soccer Ball Industry in Pakistan and seem to base some of their no child labor assurances solely on this agreement. The following is some brief information about the claims made by each company to Kmart.

 

• In its letter to Kmart dated February 18, 1997, Seneca Sports, Inc. certified that its manufacturing facility in Pakistan "prohibits inhumane conditions, violations of human rights and the use of child labor." The letter further states that "our packaging will certify that no child labor was used in the manufacturing of Seneca Soccer Balls." ¹⁰⁰ The package containing the Seneca ball states, "Seneca® balls are certified as free from child labor." The box also states "Seneca Sports® Certified." A Seneca official informed the Department of Labor that in the past year it has been asking its Pakistani supplier, Awan Sports, for assurances that soccer balls produced for Seneca are child labor- free. The Seneca representative further stated that Awan Sports has consolidated all its soccer ball production into one facility, preventing the outsourcing of stitching operations, and thereby minimizing the chance of child labor. Both Seneca and Awan Sports endorse the Partners' Agreement. ¹⁰¹
   
• Franklin Sports, Inc. informed Kmart on February 18, 1997 that it is a member of the Partners' Agreement, noting that a monitoring system had been implemented to ensure compliance with the Agreement. ¹⁰² In addition, Franklin stated it will independently assure that: 1) factories manufacturing Franklin soccer balls will be monitored by an independent contractor on a quarterly basis, with reports available for review by Kmart management; 2) factories will use only factory managed labor in the production of soccer balls, eliminating any possibility that child labor could be used in a cottage industry environment; and 3) Franklin will include a visible mark/logo on packaging and/ or product stating clearly that no child labor has been used in the production of the product, no later than July 1, 1997. ¹⁰³

The president of Franklin Sports explained that placing a child  labor-free label on the balls "is a visible way to tell people that we are in compliance with the Partners' Agreement. Also, retailers want assurances that our balls were not made by children." ¹⁰⁴

In a follow-up interview with the Department of Labor, Franklin confirmed that effective July 1, 1997, a label reading "Manufactured Without Child Labor" is being printed on balls made in Pakistan and exported to the United States. Franklin believes that stitching centers are being set up to centralize production and better manage who stitches the soccer balls. Franklin notes that they are relying solely on the Partners'Agreement to monitor production. Franklin requires all its Pakistani manufacturers to be members of the Partners' Agreement. ¹⁰⁵
 

• Molten U. S. A., in a letter to Kmart dated February 21, 1997, stated that "we can now guarantee that no child labor will be used in any phase of the production of soccer balls supplied to Kmart Corporation." The letter further states that Molten U. S. A. "will begin to include a sticker on the cosmetic package referencing the child labor issue as soon as the stickers are produced. This should be no later than March 15." A representative of Molten explained that its soccer balls are made in Pakistan, India and China, although the labels described in their letter to Kmart refer only to balls made in Pakistan. The representative stated that both Molten and their Pakistani supplier, Sublime Sports, are members of the Partners' Agreement. As of mid-August, however, Molten had not put "no child labor" labels on its Pakistani-made soccer balls. The company maintains that it is in the process of investigating the issue of child labor in Pakistan, and wants to ensure that any child labor- free guarantee made by Molten is absolutely credible. ¹⁰⁶
   
• Spalding Sports Worldwide stated in a February 21, 1997 letter to Kmart that all Spalding soccer ball manufacturers comply with the industry criteria and Spalding's Worldwide Labor Policy. The letter further states that Spalding is a member of the Partners' Agreement. Finally, the letter states that Spalding has added the following logo to all its soccer packages: "No Child Labor Used to Produce This Product." A representative of Spalding explained that Spalding sources 75 percent of its soccer balls from Pakistan; the remaining balls are made in China, but are molded and not hand- stitched. Spalding's two Pakistani manufacturers, Recto Sports ¹⁰⁷ and Taj Mahal, are members of the Partners' Agreement. Spalding requires its manufacturers to certify Spalding balls have been produced without the use of child labor. Additionally, Spalding says that its quality control personnel visit the Pakistani facilities frequently and ensure that no child labor is used. ¹⁰⁸
   

c. Child Labor Labeled Soccer Balls Provided to Youth Soccer Leagues

In addition to the five companies listed above, other companies selling ballsdirectly to youth soccer leagues are making no child labor" claims. While there maybe a number of companies supplying labeled balls to youth soccer leagues, the following two have come to the attention of the Department of Labor.

 

• The Department of Labor obtained a soccer ball used at "The 1997 Virginian Tournament," held in Springfield, Virginia, which carries the label "No Child Labor Involved: Adult Sewn Product." According to the information printed on the ball, it was made in Pakistan and imported by American Challenge, a U. S. importer of soccer balls. American Challenge officials informed the Department of Labor that its Challenge soccer balls are manufactured exclusively by JSD Sports (Pvt.) Ltd. in Sialkot, Pakistan. ¹⁰⁹ American Challenge has provided the Department of Labor with a letter from the Assistant Director of Labour Welfare, Government of the Punjab, stating that the mentioned manufacturer "is abiding by all the by-laws in relation with employment of 'child labor' and there is no worker in the factory below the age of fifteen years. It is further certified that all workers/employees are free to leave the job and no bonded labour is involved in the manufacturing of products of the said concern." ¹¹⁰ American Challenge stated that the company has been producing soccer balls with a "no child labor" label since January 1997. The soccer balls are sold to various dealers and individuals. ¹¹¹
   
• The American Soccer Company supplies soccer balls to ADULT youth soccer leagues, soccer clubs, and stores under thebrand name SCORE. In the past year, the American Soccer Company began to distribute SCORE soccer balls with a PRODUCT label stating, "Adult Sewn Product." A SCORE representative said that placing the labels on the balls coincided with the signing of the Partners' Agreement, of which they are a member. SCORE requires that its Pakistani manufacturers be members of the Partners' Agreement as well. One of SCORE's suppliers in Pakistan is Talon Sports. Talon has provided letters to SCORE assuring that they do not use child labor in the production of their soccer balls. SCORE hopes to send company representatives to Pakistan at the end of the year to visit Talon and verify the no child labor assurances are accurate. ¹¹²

The two major organizations that sponsor and regulate youth soccer leagues in the United States, the United States Youth Soccer Association, Inc. (USYSA), andthe American Youth Soccer Organization (AYSO), have both publicly condemned the use of child labor in the manufacturing of soccer balls. ¹¹³ The official equipmentsupplier of the USYSA, the larger of the two groups, is Adidas, which does not place labels on its balls. The official ball of the AYSO is Spalding, which is placing child labor-free labels on AYSO sanctioned balls (see above). The AYSO states that is has obtained a guarantee from Spalding that its manufacturers do not engage in violation of children's rights, and that no child labor is used in the manufacturing of any of its products. Prior to this year, the official ball of the AYSO was SCORE, which is now placing no child labor labels on some of its balls.

E. Codes of Conduct in the Soccer Ball Industry

In addition to the increase in child labor labels in the soccer ball industry, voluntary codes of conduct prohibiting child labor are also becoming more common. Such codes have been adopted by soccer organizations, sporting goods manufacturers, importers and retailers of soccer balls.

This section first describes codes adopted by national and international organizations. The section then discusses the implementation of codes of conduct by individual U. S. importers and retailers of soccer balls, based on responses to a U. S. Department of Labor survey, other information gathered during the research for this report, and field visits by U. S. Department of Labor officials.

1. Partners' Agreement to Eliminate Child Labor in the Soccer Ball Industry in Pakistan

On February 14, 1997, in Atlanta, Georgia, representatives of the Sialkot Cham-ber of Commerce and Industry (SCCI), ¹¹⁴ the International Labor Organization (ILO) and the United Nations Children's Fund (UNICEF) signed the Partners' Agreement toEliminate Child Labour in the Soccer Industry in Pakistan. ¹¹⁵ The goals of the Partners' Agreement are the elimination of child labor in soccer ball production and the eventual elimination of child labor in other industries in the Sialkot area. This will beaccomplished through the creation of new opportunities for children with an emphasis on education and training. The Partners' Agreement has two basic programelements: a prevention and monitoring program and a social protection program. A Coordinating Committee comprised of the Partners and NGOs will administer theproject. ¹¹⁶ Both segments of the Partnership Agreement are due to begin in late 1997.

Companies endorsing the agreement "agree to source balls made in Pakistanexclusively from manufacturers who indicate their commitment to act responsibly toensure that children are not utilized to make soccer balls by participating in the voluntary industry program." ¹¹⁷ In all, 55 soccer ball companies have endorsed the Partners' Agreement. ¹¹⁸

a. Prevention and Monitoring Program

The prevention and monitoring program will set up a registry and internaland external monitoring systems and replace home-based production with village-based stitching centers. The program will be managed by the ILO. The objective ofthe program is to have the factories and stitching units of at least 22 manufacturersand their subcontractors free of child labor within 18 months: ¹¹⁹

• Internal monitoring: In order to determine whether soccer ball manufacturers are complying with the Partners' Agreement, a registry of personnel and production sites will be established. This registry is the core of the internal monitoring system. Manufacturers participating in the program must provide the following information to the ILO by January 1, 1998.
  
  i) registration of the names and contact information of all subcontractors;
  
  ii) registration of the names, addresses and ages of all stitchers working for the subcontractors and identification of child workers under the age of 14 to be removed and placed in social protection programs;
  
  iii) a reasonable estimate of the annual target capacity of soccer balls to be produced by the manufacturer and a reasonable estimate of the number of stitchers to produce this amount;
  
  iv) registration of all stitching units no less than 25 percent of the annual target capacity; and
  
  v) registration of names and contact information of new subcontractors, and names, addresses and ages of new stitchers.
  
  The manufacturers are required to update the list of new subcontractors and stitchers every six months, and to have registered all the stitching units representing one-hundred percent of the annual target capacity by January 1999.
   
• External monitoring: The accuracy of the internal monitoring system will be checked by establishing an external monitoring system. The ILO will hire and train independent monitors to visit the stitching centers on an unannounced basis to verify the information provided by the internal monitoring system. The monitors will have free access to all stitching centers operated by manufacturers and subcontractors. Weekly and monthly monitoring reports will be made available to the ILO; reports of violations of the Agreement will be given to the Coordinating Committee on a monthly basis or whenever requested.

b. Social Protection Program

At the same time that a system is being put into place to phase children out of the soccer ball industry, a program will be established to provide the children with education and rehabilitation. The program includes a campaign to change community attitudes toward child labor in the soccer ball industry. Children and families identified by the internal monitoring program will receive non-formal education, counseling, health services, training in income generation for adults, provision of credit/savings facility for adults and pre-vocational training. Younger children will be mainstreamed to formal schools. A number of village education and action centers (VEA centers) will be set up to provide these services. The centers will be run by the Bunyad Literacy Community Council, a Pakistani NGO focusing on basic education, and the Pakistan Bait-ul-Mal, a social welfare agency set up by the Prime Minister'soffice.

2. Sportsgoods Manufacturers and Exporters Association (India)

As programs to eliminate child labor in the Pakistani soccer ball industrygained momentum and attention this year, representatives of the sporting goods industry in India also have begun deliberations about combating child labor. In April1997, members of the Indian Sportsgoods Manufacturers and Exporters Associationjoined representatives of NGOs, government, trade unions and international organizations in the First National Consultation on Child Labor in the Sports Goods Industry, organized by the Indian human rights group South Asian Coalition on Child Servitude (SACCS). The purpose of the meeting was to discuss the problem of child labor in the industry and create a plan of action for the elimination of child labor. Among the coalition's recommendations was to establish an ethical code of conductand an independent, professional and credible monitoring system to ensure the absence of child labor. ¹²⁰ The Joint Committee on Child Labor in the Sporting Goods Industry was created, consisting of 8 industry representatives, 3 NGO representatives, the Sports Goods Export Promotion Council (a governmental body), the ILO and UNICEF.

At the same time that the Joint Committee was being established by SACCS,members of the Sportsgoods Manufacturers and Exporters Association of India ¹²¹ held a special meeting to discuss child labor in May 1997. The meeting, attended by 25 of the largest soccer ball manufacturers and exporters in India, the ILO and the World Federation of Sporting Goods Industry, ¹²² was called in response to a May 1997 Christian Aid report on child labor in the Indian sporting goods industry and recent negative media coverage in the United Kingdom. ¹²³

In a declaration prior to the May meeting, the Indian Sportsgoods Manufac-turers and Exporters Association stated its opposition to child labor. Similar to the industry leaders in Pakistan, the Indian association explained that there are no children producing soccer balls in the factories themselves, ¹²⁴ but that subcontractors could be distributing work to village shops and homes where child labor is more likely to be found. ¹²⁵ To deal with this problem, the Association adopted a self-monitoring system consisting of the following elements:

• the industry will: (1) identify stitchers and prepare lists of their names, address, ages, sex, address of workplace, etc.; (2) identify children working in homes or in factories; and (3) cross check the lists of stitchers with the number of stitched balls, and/ or other goods exported annually from India;
   
•  the first monitoring of the lists will be conducted by the Sportsgoods Manufacturers and Exporters Association, Jalandhar;
   
• a second monitoring will be conducted by the Sports Good Export Promotion Council; and
   
• the third monitoring will be done by an outside agency such as the Indian Labor Department or the ILO. ¹²⁶

At a June 1997 meeting, the chairman of the Sportsgoods Manufacturers and Exporters Association asked that all members fill out forms "to identify child labour" ¹²⁷ employed directly or indirectly in the production of soccer balls. While the Association deems the monitoring system as self-certifying, it acknowledges that some form of independent monitoring is necessary for the system to be credible. ¹²⁸ Whether an Indian government agency is considered to be independent for purposes of monitoring is open to question. The Sportsgoods Manufacturers and Exporters Associationhas also encouraged members to work with the Punjabi state government, which will reportedly provide assistance if members are interested in setting up centralizedstitching centers in lieu of using individual subcontractors. ¹²⁹

On September 13, 1997, the Sportsgoods Manufacturers and Exporters Association reported that 27 exporting companies have provided information on their stitchers. Eighteen of these companies have obtained lists of stitchers from their contractors. ¹³⁰

3. FIFA

The International Federation of Football Associations (FIFA) ¹³¹ authorizes the use of its logo on soccer balls that meet international matchball standards. On September 3, 1996, FIFA announced an agreement with three international unions ¹³² on a Code of Labor Practice for all goods bearing its logo. ¹³³  Use of the FIFA logo bya licensee would signify that production was carried out in compliance with ILO Conventions banning child labor and forced labor, ensuring non-discrimination in employment, guaranteeing the right of workers to form and join trade unions and to bargain collectively, and ensuring payment of a minimum wage. ¹³⁴ These commitments would be binding not only on the licensees, but also on each contractor and subcontractor in the production and distribution of FIFA- licensed products. ¹³⁵ The FIFA Code of Labour Practice has not been embraced by soccer ball manufacturers or importers. In the year since the Code of Labor Practice was announced, FIFA has endorsed the Partners' Agreement but has not issued any information on the implementation of the FIFA code. ¹³⁶

4. Survey Results

In addition to endorsing the Partners' Agreement, some U. S. importers of soccer balls have issued their own codes of conduct that prohibit the use of child labor. Some retailers have also adopted similar codes of conduct.

In order to gather information on the extent and implementation of codes of conduct and labeling programs regarding child labor in the soccer ball industry, the U. S. Department of Labor conducted a voluntary survey of 7 importers and 3 retailersof soccer balls. ¹³⁷ ( See Box IV- 1 for a list of the companies surveyed and Appendix B for the Company Questionnaire). Nine companies responded to the survey: Adidas, Baden Sports, Brine, Kmart, Nike, Pentland (Mitre), Reebok, Umbro, and Wal-Mart.

The respondents indicated they import soccer balls either directly from foreign manufacturers in China, Indonesia or Pakistan, or through a U. S.- based purchasing agent.

• Six of the seven importers source their soccer balls directly from a foreign manufacturer; one firm (Pentland) also sources its balls through a purchasing agent. The seventh, Adidas, currently imports its soccer balls through a licensee, Molten, U. S. A. None of the seven importers own foreign manufacturing facilities. However, Reebok and Nike have invested in special facilities being built by their Pakistani producers in order to meet their child labor-free production policies.
   
• The two retailers responding to the survey use U. S. licensees or purchasing agents to obtain soccer balls. Kmart, for example, purchases soccer balls from Seneca Sports, Franklin Sports, Molten U. S. A., and Spalding Sports ( see Section D. 4. b. above).

Seven of the companies responding to the survey indicated they have a written corporate policy prohibiting child labor. The written policies take the form of a code of conduct, vendor agreement, purchase order, or statement of principles.In cases where the company purchases and/or sells numerous products, the code applies to all the products, not just soccer balls. Copies of the policies are reproduced in Appendix C.

All seven importers (Adidas, Baden Sports, Brine, Nike, Pentland (Mitre), Reebok and Umbro) have endorsed the Partners' Agreement in addition to their individual corporate policies against child labor.

• Brine stated that it has no written policy prohibiting child labor, although it is a member of the Partners' Agreement and has always made it clear to suppliers that child labor is unacceptable. However, this policy is not included in their purchase orders or vendor agreements.
   
• Adidas' licensing agreement requires its licensees and manufacturers to comply with all applicable laws, including those prohibiting child labor. Manufacturers are also required to ensure that subcontractors comply with these standards. Failure to comply may be a basis for terminating the agreement.
   
• Although Baden has no written code of conduct prohibiting child labor, they  require their factory representatives to verify that no children are engaged in making their products.
   
• Nike's code of conduct prohibits the use of child labor. Child labor is defined as a person under the age of 15, unless national law states that the minimum age for work is fourteen — or — the age at which compulsory schooling has ended, whichever is greater.

TABLE IV-2
Type of Policy Prohibiting Child Labor
(Based on Responses to Department of Labor Questionnaire)

* Company participates in the Partners' Agreement to Eliminate Child Labour in the Soccer Ball industry in Pakistan

^a Company has its own labeling program

^b Company has a formal code of conduct, statement of principals or compliance certificate

^c Company has a purchase order, letter of credit, or buying agent agreement, which contains a specific prohibition on child labor in overseas production.

• Pentland's letter of credit requires suppliers to certify that items were not mined, produced, manufactured, assembled or packed by the use of child labor as defined by national law.
   
• Kmart's Workplace Code of Conduct is applicable to all suppliers and the suppliers' subcontractors in the United States and abroad. Kmart's code requires suppliers and their contractors to comply with local child labor laws and regulations. Children under the local legal age should not be employed by the supplier.
   
• Reebok's code of conduct states that it will not work with business partners that use child labor. Reebok defines child labor as work performed by a person under 14, or younger than the age for compulsory schooling, whichever is higher.
   
• Umbro requires its suppliers to sign a pledge every year certifying that they are observing national child labor laws.
   
• Wal-Mart's Standards for Vendor Partners declares that Wal- Mart will not tolerate the use of child labor in the manufacture of products it sells. The standard applies to vendor partners as well as to their contractors, subcontractors or any other entity with whom they have a relationship for the manufacture of products sold by Wal-Mart. Wal-Mart defines child labor as work by a person younger than 15 (or 14 if so designated by national law) or younger than the age for completing compulsory education if that age is higher than 15.

Only three respondents — all importers — indicated that they communicatetheir no child labor policy directly to consumers. The remaining importers and retailers report either that they have no method to inform consumers that no childlabor is used in the foreign production of soccer balls, or that their suppliers label the balls.

• Reebok and Baden have adopted labels to inform consumers that their soccer balls are made without child labor ( see Section D above). Reebok's code of conduct is reproduced on its internet website.
   
• Nike said that consumers can learn about their no child labor policy on its internet website or by calling a toll- free number set up by the Soccer Industry Council of America that lists the names of companies participating in the Partner's Agreement.
   
• Kmart noted that their four suppliers (Seneca Sports, Franklin Sports, Molten U. S. A., and Spalding Sports) have submitted letters indicating that they would label the balls child labor- free. Three of the four suppliers (Seneca Sports, Franklin Sports, and Spalding Sports) are now selling labeled balls to Kmart ( see Section D. 4. b. above for a more detailed discussion).
   
• Brine noted that they do not have a separate mechanism for informing consumers that a soccer ball is not made by children, as their brand name alone should stand for not using child labor. Brine raised the concern that creating a special "not made with child labor" designation will lead to exploitation of the situation, and that smaller manufacturers that are financially unable to mount a large no child labor public relations campaign are bound to suffer even if they do have a no child labor commitment.

The companies surveyed indicated that they utilize a variety of means to monitor that their codes of conduct or policies on child labor are respected by their suppliers. Details of Reebok, Baden, and Kmart's monitoring procedures are found in Section D above. Table
IV- 3 illustrates the type of monitoring the respondents employ.

Seven of the nine respondents (Adidas, Baden, Brine, Kmart, Nike, Reebokand Wal- Mart) stated that they use contractual monitoring, i. e., they require their suppliers, through contractual agreements, to certify that their soccer balls are not made by children. The two retailers (Kmart and Wal- Mart) use only contractual monitoring to ensure their policy is being properly implemented.

Seven of the nine respondents (Adidas, Baden, Brine, Nike, Pentland, Reebok and Umbro) send company staff, buyer agents or other parties to inspect facilities to verify that suppliers are actually implementing their code of conduct. Nike andReebok indicated that, in addition to contractual and internal monitoring, they use external accounting, auditing, testing or consulting firms, and/ or NGOs to monitor labor practices. In response to the Department's survey, some respondents submit-ted letters from the local Pakistani Labor Department certifying that a factory manufacturing soccer balls is free of child labor.

Adidas, Brine, Nike, Pentland, Reebok and Umbro explained that they relyon the system established by the Partners' Agreement to monitor their child labor policy — in addition to any monitoring they might conduct on their own. Companies that support the Partners' Agreement pledge only to do business with Pakistani manufacturers who participate in the Agreement and consent to internal and external monitoring. As indicated above, however, the internal and external monitoring programs established by the Agreement have not yet been fully implemented.

TABLE IV-3
Monitoring Strategies for Compliance with
International Child Labor Policies
(Based on Responses to Department of Labor Questionnaire)

^a Company relies on guarantees made by suppliers through contractual documents or certificates that they are adhering to the company's policies.

^b Company uses site visits and inspections by company staff, buyer agents, or other parties to verify that suppliers are actually implementing the codes of conduct.

^c Company uses external accounting, auditing, testing or consulting firms, NGOs, or international organizations to monitor labor practices.

• Local and quality control personnel employed by Adidas regularly visit manufacturers facilities. Adidas submitted a letter from the Punjabi Directorate of Labour Welfare attesting that children have never been found in the factory of their supplier, Sublime Sports.
   
• Kmart's code of conduct requires suppliers and their subcontractors to allow full access to their facilities at all times for inspections by Kmart representatives or independent firms retained by Kmart. Kmart states that it has never found any child labor in the production of soccer balls. ¹³⁸
  
  It is not clear whether Kmart's monitoring system specifically applies to the soccer balls sold in their stores. However, in February 1997, Kmart received letters from four soccer ball suppliers assuring the retailer that the balls were not made by children. The suppliers' letters informed Kmart that each company is participating in the Partners' Agreement.
   
• Nike imports soccer balls from SAGA Sports in Sialkot. Nike and SAGA  determined jointly that the best way to eliminate child labor was to create village stitching centers where it would be easier to monitor the ages of the stitchers. By mid-1997, three stitching centers were operating with two additional centers scheduled to be completed by September 1997. ¹³⁹ One of the centers is exclusively for women. Nike states that it monitors its code of conduct in Pakistan through its own internal procedures, and by using a Pakistani affiliate of Grant Thornton as an external monitor.
   
• Pentland's soccer ball product managers visit their production facilities about three times a year to monitor compliance with their child labor policy. Pentland noted, however, that it is difficult to monitor for child labor since children are seldom found in the factories, but stitch soccer balls in homes and small workshops in the rural areas.

Over the next two years, Pentland plans to implement a China- specific monitoring plan in response to their concern about the use of child labor in China's soccer ball industry. The policy will have three components: 1) better factory control of home working situations; 2) documenting the age of young factory workers; and 3) protecting older working children (14, 15, 16 and 17 year olds) by restricting overtime and identifying areas of potential hazard where they should not be working.

• Umbro personnel make spot- checks at suppliers' factories in 4- 8 week cycles. Umbro stated that although they conduct spot checks on "external stitching facilities," they can never be completely certain that no child labor is being used.

F. Conclusion

There has been significant public attention focused on the use of child laborin the soccer ball industry. ¹⁴⁰ Most reports describe Pakistani children sitting forhours a day in small workshops stitching soccer balls. Other more recent reportsdescribe a similar situation in India's soccer ball industry. Soccer balls are also madein China and Indonesia, but the Department is not aware of any child labor allegations in the soccer ball industries of these countries. One company surveyed for this report, however, plans to implement an internal monitoring system in China due to concerns of child labor.

Children stitch soccer balls in small workshops or homes, many times inremote rural areas. It is rare for a child to be found working in a large soccer ball factory. In Pakistan and India, child labor laws prohibit children from working in factories, but not in the type of subcontracting or homework arrangements common to the soccer ball industry. Some of the children work full-time. Others work during non-school hours. Many work for up to nine or ten hours a day.

The international soccer ball industry has responded to the child labor accusations by creating codes of conduct and monitoring systems. In February 1997,Pakistani manufacturers signed an agreement (Partners'Agreement) with the ILO andUNICEF to phase children out of the industry, to provide education and other services to them, and to participate in internal and external monitoring programs. Over 50 U. S. and Pakistani companies pledged to support the agreement. By the time this report was written, the Partners' Agreement was not yet fully operational. In India,the industry is moving toward an agreement to stop the use of child labor. Discussions are underway between representatives of the industry, ILO, UNICEF, NGOs,trade unions and government to determine how best to accomplish this goal.

Some individual companies are responding to public pressure by placingchild labor-free labels on their balls. The Department of Labor has identified eight companies that are using such labels. Reebok and Baden are both changing their production processes and implementing monitoring systems to support the use ofthe label. Reebok has hired independent human rights monitors to verify that no children stitch Reebok balls. Dunkin' Donuts sold promotional soccer balls duringthe 1997 summer months bearing a child labor-free label. Dunkin's Donuts asked a U.S.-based NGO to monitor the production of these balls and certify that they were not made by children. The other companies are making their no child labor claimsbased upon their participation in the Partners' Agreement. It is premature, however,to make such a claim because the monitoring components of the Partners' Agreement have not yet been fully implemented.

Other companies are changing their production processes to prevent the use of child labor. For instance, Reebok has centralized all soccer production in one factory. Nike has created stitching centers in order to better monitor where production takes place. Baden has changed from Pakistani to Chinese suppliers and mecha-nized the stitching process.

Although some individual companies have developed labels for their soccer balls, the majority of the soccer ball industry has opted instead to implement a variety of different codes of conduct to prohibit and prevent child labor. All companies responding to a Department of Labor survey on codes of conduct and labeling programs indicated that they have some type of corporate policy prohibiting child labor. Not all these policies are in writing, and very few are enforced through a rigorous monitoring system.

This report was produced by the staff of the International Child Labor Program and is published by the U.S. Department of Labor, Bureau of International Labor Affairs.

Acknowledgements