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Revisiting Labour and Gender Issues in Export Processing Zones: Cases of South Korea, Bangladesh and India

This essay re-evaluates the historical trajectories and outstanding labour and gender issues of Export Processing Zones/Special Economic Zones on the basis of the experiences of South Korea, Bangladesh and India. The findings suggest the necessity of enlarging our analytical scope with regard to epzs/sezs, which are inextricably connected with external employment structures. Further, the study calls for an immediate and comprehensive review of the labour and gender conditions in Indian sezs where workers are in a disadvantageous position not only against capital but also in comparison with workers in South Korean and Bangladeshi epzs/sezs.


Revisiting Labour and Gender Issues in Export Processing Zones: Cases of South Korea, Bangladesh and India

Mayumi Murayama, Nobuko Yokota

This essay re-evaluates the historical trajectories and outstanding labour and gender issues of Export Processing Zones/Special Economic Zones on the basis of the experiences of South Korea, Bangladesh and India. The findings suggest the necessity of enlarging our analytical scope with regard to EPZs/SEZs, which are inextricably connected with external employment structures. Further, the study calls for an immediate and comprehensive review of the labour and gender conditions in Indian SEZs where workers are in a disadvantageous position not only against capital but also in comparison with workers in South Korean and Bangladeshi EPZS/SEZs.

Mayumi Murayama ( is at the Institute of Developing Economies, Japan and currently a visiting researcher at the Institute of Economic Growth, Delhi and Nobuko Yokota (ynobuko@ is at the Yamaguchi University, Japan.

n Export Processing Zone (EPZ)1 is a zone in which imported raw materials and components are processed to be exported without paying duties and with a minimum of customs regulations. It has been 50 years since the first EPZ was established. Today, in some countries, EPZs are no longer a topic of interest whereas in others such as India, the advent of Special Economic Zones (SEZs, a variant of EPZs) has stirred fresh interest among academics and the public. It should be noted, however, that over the last 50 years, whether met with protests or indifference, EPZs and similar institutions have continued to proliferate. Does the expansion of EPZs signify any consensus regarding their efficacy as an instrument of economic development? Discussion of EPZs has produced a large volume of scholarly literature, both theoretical and empirical. In particular, EPZ labour issues, including women’s employment, have been critically evaluated in the context of the theory of exploitation. But the discussion of these issues tends to be over-simplistic and static as regards the nature of EPZs. In this paper, we reflect on the role of EPZs and its implications over a longer span of time and space, including the issue whether the exploitation theory still holds true. We also examine what the outstanding research issues may be.

We analyse the cases of South Korea, Bangladesh and India, India being by far the largest of these three economies. In terms of length of EPZ experience, South Korea is one of the firstgeneration economies where an EPZ was introduced in the early 1970s while the first EPZ in Bangladesh appeared more than a decade later. India’s case is unique. Although it was the first country in Asia to establish an EPZ, the efficacy of EPZs did not receive much attention until the late 1980s. After a gap of 35 years, a Special Economic Zones Act, which also incorporated the older EPZs, was introduced.

Economic and Labour Issues of EPZs

The concept of the EPZ is said to have originated from free-trade zones established in major ports. EPZs differ from free-trade zones in two main ways. First, EPZs were adopted as a means of initiating export-oriented industrialisation, and second, the location of an EPZ is not immediately bound by its closeness to a port (Wong and Chu 1984: 1). The concept of the EPZ has also broadened in ways that have overcome the physically closed nature of such an enclave. Today, single-factory zones, such as the exportoriented units in India or the bonded warehouses in Bangladesh are sometimes counted as EPZs. Also the activities carried out in

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EPZs extend from earlier assembly and simple processing to h i-tech science parks, logistics centres and even tourist resorts. International Labour Organisation (ILO) statistics include the newer types in a grand total of EPZs that following a period of continuous proliferation, has now reached 3,500, spread over 130 countries. The total employment is estimated at approximately 66 million, of whom 40 million are in China (Boyenge 2007). As for enclave-type EPZs, one source claims that there are 12 countries that have large zones with resident populations, including the Chinese SEZs and new cities, and 126 countries with smaller zones that are generally smaller than 1,000 hectares, normally surrounded by some kind of fence.2

The first EPZ was set up at Shannon airport in Ireland in 1959. Shannon EPZ is regarded as the prototype for all subsequent EPZs and is acclaimed for its successful development of an exportbased industrial sector (Currie 1979: 2). Puerto Rico (in 1962) and India (in 1965) were the first two developing countries to adopt the EPZ strategy. They were soon followed by Taiwan, the Philippines, Dominican Republic, Mexico and Brazil, all during the period between 1966 and 1970. During the 1970s, the number of EPZs increased greatly. Many countries in Asia, including South Korea and Sri Lanka, and in the Latin American and Caribbean region and a few African and west Asian countries took up the EPZ approach. In 1979, China established its first four SEZs. Throughout the 1970s and 1980s, the older countries added new EPZs while latecomers such as Bangladesh and Pakistan established EPZs for the first time. In the 1990s, while several African countries tried the EPZ approach, variants of the EPZ began to appear. These included the Export Processing Firm (EPF), an initiative that has become increasingly popular (Madani 1999).

What accounts for the increasing popularity of the EPZ strategy? Although the role assigned to EPZs has differed from country to country, there is an overall consensus on the primary goals of an EPZ. These include the earning of foreign exchange through increased exports, employment creation, the attraction of foreign direct investment (FDI) to the host country, technology transfer and generating linkage effects beyond the EPZ. With these broad objectives forming the context, a large number of studies have been made regarding the impacts of EPZs on individual economies.3 However, there have not been any solid conclusions regarding the costs and benefits of EPZs for host countries, partly due to the absence of agreed methodologies and sufficient data, and due to differences among countries as well as changes in conditions related to each EPZ over time.

It is over labour and gender issues that the efficacy of EPZs has most often been called into question. An enclave-type EPZ, the creation of which requires substantial resources, has an intrinsic limitation even though employment growth within an EPZ may be considerably stronger than outside it. Unless new EPZs are c reated continuously throughout the country, the employment contribution tends to be limited as a quantitative solution to the country’s unemployment problems. Moreover, as the labour market tightens and labour costs rise, it is likely that EPZs will lose competitiveness in terms of labour costs, and that employment generation will diminish. As we will see, South Korea is an example of this kind of trend.

It is in respect of the qualitative dimension of employment that the role of EPZs has been most widely criticised. Many observers have concluded that employment in EPZs means low wages, high work intensity, unsafe working conditions and suppression of labour rights. While narratives of workers’ plights are abundant, lack of clarity in the assessment criteria do not allow us to measure the extent of benefit, if any, that the labour force derives from working in an EPZ.

In the early 1980s, an ILO study edited by Lee (1984) stated that assertions of “super-exploitation” regarding the nature of EPZ employment rest on two assumptions, namely, a level of work intensity beyond the normal mental and physical capacity of workers, and a level of wages that is below the physical subsistence level. Both these assumptions, according to Lee, are difficult to substantiate on the basis of the available evidence. What is clear is that in terms of both work intensity and the wages they receive, workers in EPZs are far worse off than those doing similar jobs in industrialised countries (Lee 1984: 16, 18). That said, whether EPZ workers are worse off compared with their rural and urban counterparts is another question. A comparison of wage levels would be the least disputable kind of assessment, if appropriately made. While it is generally agreed that wages in EPZs are higher than those available in rural areas of the same country, especially for women, it is not always the case that wages in EPZs are higher than those for comparable work outside them.

Available studies suggest two tendencies regarding relative wage levels of EPZ workers vis-à-vis non-EPZ workers engaged in comparable work. First, the relative wage levels of EPZs differ from country to country. In the late 1970s and early 1980s, wages in Bataan EPZ (the Philippines) and Masan EPZ (South Korea) were lower than those outside, while export zones in Malaysia and Sri Lanka provided marginally higher wages than factories outside (Edgren 1984). According to Edgren, two factors, the supply of fresh workers from the main recruitment areas and alternative sources of employment outside the EPZs, determine the relative wage levels within EPZs. Since the factors mentioned by Edgren change over time, so do the relative wage levels of EPZs, as we will see in greater detail in the case of South Korea.

Assuming that wages and working conditions in EPZs become relatively better than those outside, what are the remaining issues concerning EPZ employment? A salient feature of EPZ employment vis-à-vis non-EPZ employment is the restrictions on trade union movements. Not all the countries with EPZs have taken a negative stance towards trade union activity within EPZs but on the whole, governments that have adopted the EPZ strategy have tended to act against labour movement activities within the zones. The various restrictions on labour movements include a total or partial ban on trade union activities within EPZs, restriction of the scope of collective bargaining, and bans on trade union organisers entering the zones (ILO 1998). Some governments while enforcing strict control on labour movements require employers to abide by government regulations on working conditions. Shoesmith (1986: 111), however, alleges that while this practice would seem to be to the advantage of workers, it limits the ability of workers to independently organise or press for better working conditions than those laid down by the state. Moreover,

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in countries where labour inspectorates are weak, it is difficult to see how legislation on working conditions can be enforced.

EPZs in South Korea

During South Korea’s “developmental era” from the 1960s to the 1980s, the economy achieved remarkably high rates of growth led by an export-oriented industrialisation strategy.4 A development dictatorship promoted exports of labour-intensive products utilising cheap labour with the aim of earning foreign exchange and attracting FDI, while simultaneously laying emphasis on the development of heavy and chemical industries to build up core varieties of manufacturing. The export dependency of the economy increased from 15.6% during the 1970s to 40.1% in 1987. EPZs5 were established in Masan in 1970 and in Iri in 1973 with a focus on labour-intensive industries such as electrical and electronic products, and textile and garment manufacture. In line with a general expansion of exports, bonded processing and e xports accounted for about 20% of South Korea’s exports from the latter half of the 1960s to the mid-1980s.

This situation, however, changed when the military dictatorship ended on 29 June 1987. Labour disputes proliferated all over the country in what is generally called the “great labour struggle”. Through this struggle, South Korean workers have gained basic legal rights of labour, the power of trade unions has increased dramatically, and working conditions have been improved considerably. This has resulted in a substantial increase in wages, with the result that export industries have lost their comparative advantage in terms of cheap labour. Export dependency stagnated at slightly less than 20% from the late 1980s to 1998 when the “IMF crisis” occurred. Bonded processing, by the mid-1990s, accounted for less than 5% of total exports.

South Korea’s “IMF crisis”, which was triggered by the Asian financial crisis, constituted another turning point in the history of the country’s EPZs. The government responded to the crisis by accelerating the process of economic globalisation through upgrading of the industrial structure. In other words, an exportoriented strategy was re-adopted, but this time with a focus on hi-tech industries such as the information technology (IT) industry, and in an attempt to achieve this objective, FDI became an important component. The policy shift has marked the beginning of a new phase of economic development in South Korea. After 1998, export dependency increased more rapidly than during the “developmental era”, reaching 47.6% in 2007 from less than 30% in the 1990s. In line with rapid export increase has been a steep increase in FDI.

Since 2000, Free Trade Zones (FTZs) have been established one after another in an attempt to provide centres for FDI. In addition to conventional EPZs such as Masan and Iri, production-centred FTZs have been constructed in Kunsan, Taebul, Tonghae and Yulchon. Since 2003, FTZs that function as logistics hubs have been set up in Pusan Port, Kwangyang Port, Incheon Port and Incheon International Airport (Park 2008: 37). It should be noted that the motives of today’s foreign investors differ completely from those of investors during the “developmental era”. According to a survey made by Korea Labour Institute in 2004, 81.6% of the surveyed companies referred to South Korea as a new market

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while only 6.1% of the respondents mentioned utilisation of cheap labour (Bae 2005: 51). We can conclude that the role of EPZs or production-oriented FTZs as bonded processing and exporting zones with low-cost labour has come to an end in South Korea.

Employment, Labour and Gender Issues in Korean EPZs

Masan EPZ, established in 1970, was South Korea’s first EPZ and is the largest in terms of employment, number of firms and amount of foreign trade and FDI. The first FDI venture arrived in the zone in 1971. During the 1970s, more than 90% of the firms were foreign owned. The proportion remained at 80% throughout the 1980s. The majority of them were small- and medium-scale companies from Japan for whom location in South Korea was attractive because of geographical proximity.6 These foreign companies came to Masan EPZ in search of good quality, cheap labour assuming the existence within the EPZ of strong labour restrictions or even complete suppression of the basic legal rights of labour, as promised by the South Korean government by way of the 1970 Act on the Designation and Operation of Export Free Zones. The majority of the small and medium Japanese enterprises that came to Masan were in labour-intensive electrical goods and electronics industries that were finding it difficult to survive in Japan because of the high labour costs there.7 After the steep rise in wages, however, many small foreign-owned companies left the zone from the 1990s onwards. Together with the entry of domestic investors, this trend has led to a shift in the industrial structure of Masan EPZ towards technology and capital-intensive industries. The “IMF crisis” further accelerated the change (Park 2008: 38; Choi 2003: 74).

Figure 1 (p 76) shows the trend of employment by gender in Masan EPZ. Along with the expansion of bonded processing and exports, employment increased rapidly, reaching a peak of 36,411 workers in 1987. Throughout the 1970s and 1980s, female workers constituted more than 75% of total employment and that about 90% of them were unmarried young workers under the age of 20 (Kang 1986: 36; Kang 1996a: 73). During the period, the wage levels of female workers were between 41% and 46% those of male w orkers (Korea Institute for Industrial Economics and Trade 1990: 121) and did not cover minimum living expenses.8

The great labour struggle of 1987 had important repercussions for Masan EPZ. The number of trade unions in the zone increased from 22 in 1987 to 43 in 1989 and labour disputes frequently erupted between 1987 and 1990 (Masan Free Trade Zone Corporate Association 2002: 6). It is generally considered that the great labour struggle was guided by male production workers engaged in heavy and chemical industries in which the employers were large corporations (Yokota 1994: 64). But the main actors in the labour movement in Masan EPZ were young female workers (Kang 1996b).

Labour disputes led to rapid wage increases for all workers and a substantial improvement in working conditions. The average wages of male and female workers were 3,67,588 won (approximately $427) and 1,57,954 won ($183), respectively in 1986. They were subsequently raised to 7,34,000 won ($1,080) and 4,14,000 won ($609) in 1989. This meant a 199.7% and 262.1% increase for males and females, respectively, over three years (Korea Institute for Industrial Economics and Trade 1990: 121). The rapid wage increase was accompanied by a decrease in the gender-based wage gap. By 1989, the average wage of women workers had i ncreased to 56% that of male workers.

For Masan EPZ, the change of environment in favour of workers implied that it was becoming considerably less attractive to foreign investors. Firms responded to the changed investment environment in a number of ways. These included freezing further investment, disinvestment, lay-offs and outsourcing some of the processing to small and medium units outside the zone (Kang 1996b: 21). The decline in employment was further accelerated by upgrading of the industrial structure. As Figure 1 shows, in the four years between 1987 and 1990, employment in Masan EPZ dropped from 36,411 to 19,616. The decline was chiefly caused by a sharp decrease in the number of women workers. The decline continued in the 1990s among both male and female workers. However, the rate of decline among female workers was higher than that among male workers and the trend resulted in a fall in the proportion of women workers, from more than 75% during the “developmental era” to 61.5% in 2001.

Figure 1: Employment Changes in Masan Export Processing Zone










Female Male Total

0 1972 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 1994 1997

Source: Administration Office, Masan Free Export Zone (2002).

After 1987, Masan EPZ, an earlier bonded processing and exports base drawing on the cheap labour of young women workers, was transformed into a production centre that aimed to attract domestic and foreign investment in high technology and capital-intensive industries. The changes were evident in the employment structure of Masan EPZ in 2001. The average lengths of service of male and female manufacturing workers in Masan EPZ were 12.5 years and 7.8 years, respectively. These periods of employment were much longer than the national averages of 6.4 years and 4.0 years, respectively. Moreover, the share of nonregular workers, at 17.9%, was also conspicuously lower than the national average of 51% (Masan Free Trade Zone Corporate A ssociation 2002: 10-11). These facts are indicative of the employment security and higher skills of workers in Masan EPZ. Accordingly, average monthly wages of male and female workers in 2001 were also higher, at 2,418,000 won ($1,823) and 15,78,000 won ($1,190), respectively, than the national averages of 24,04,000 won ($1,813) and 13,15,000 won ($992) (Masan Free Trade Zone Corporate Association 2002: 12). The wage level of women w orkers, in particular, was 20% higher than the national average.

76 This reflects the displacement of cheap labour by skilled workers e ngaged in high technology and capital-intensive industries p roducing high value added goods.

Whereas working conditions in Masan EPZ have improved, the decrease in the number of young women workers, who were main actors in the labour movement, has led to a decline in the number of labour disputes. On average, there were 10 labour disputes a year between 1991 and 1995, but the incidence fell to four cases between 1996 and 2000 and two cases in 2001 (Masan Free Trade Zone Corporate Association 2002: 6). The women’s labour movement in Masan EPZ, which started with the great labour struggle of 1987, seems to be on the brink of extinction.

What has happened to the labour-intensive processes that used to engage young women workers? Some processes are now subcontracted out to firms that are located outside the zone. According to some case studies, subcontracting firms outside the zone are mostly medium- or small-scale units with between 10 and 100 workers (Kang 1996b: 22; Cho 1990: 45-46; Masan Free Trade Zone Corporate Association 2002: 12). In firms such as these, married women are employed at low wages as non-regular workers and their average wages are less than half those of women workers in Masan EPZ. Home-based industries which constitute the urban informal sector are also integrated into the chain of subcontracting and married women who make up the core of the labour force are paid low wages. In 2001, there were 258 non-EPZ subcontacting firms of this kind around Masan, Changwon and Pusan, employing 4,567 workers. The workers in these enterprises are not organised, and thus tend to be left outside legal and institutional jurisdictions.

Some of the domestic as well as foreign companies which pulled out of Masan EPZ have moved to EPZs in less developed countries that can still offer the comparative advantage of cheap labour. For instance, a Japanese company manufacturing electrical goods, which made an initial investment in Masan EPZ in 1972, shifted its labour-intensive section to Thailand in 1990 and to China in 1999, while retaining the high technology and capital-intensive sections, with its skilled workers, in South Korea. The wage levels of those countries were between a third and oneseventh of those in South Korea (Masan Free Trade Zone Corporate Association 2002: 18).

As globalisation intensifies, South Korean EPZs are changing in character, and are becoming industrial hubs for capital-intensive and technology-intensive industries. At the same time, they are creating a new structure of subcontracting and informal sector employment that is beyond the reach of legal and institutional protection. It should be emphasised that in this latter respect, it is mostly women’s labour that sustains low-waged work, and thus a new gender regime has been constructed.

EPZs in Bangladesh

Bangladesh, which achieved independence in 1971, initially took the course of a public sector-led import-substituting industrial regime. In the mid-1970s, a gradual policy shift began as the result of a worsening economic situation and a change in political leadership. The first EPZ, established in Chittagong, became operational in 1983 and it was followed by Dhaka EPZ in 1993.

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Subsequently six more EPZs were set Figure 2: Annual Investment and Employment in Bangladesh’s (Bhattacharya 1998: 11). The trend EPZs, 1983-2006

up and currently two are at the imple- continued and even intensified dur-

Investment (in $ million)

0 20 40 60 80 100 120 140 160

mentation stage.9 The government in ing the latter half of the 1990s. A

Investment Employment


1996 enacted a law allowing the establishment of EPZs by the private sector


as well.10 As of March 2008, some 276 units were located in EPZs and cumu-1987-88 lative investment and employment fig


ures had reached $1,374.73 million and 2,11,829 persons, respectively. Among 1991-92 the units in operation, 60% are wholly


foreign owned while joint ventures and local ventures account for 17% and


23%, respectively. The largest source


of investment is South Korea, followed by Bangladesh, Japan and China, in


cluding Hong Kong. So far, as types of manufacturing are concerned, 179 2001-02 (64.9%) of the EPZ units make gar


ments, textiles and related products, and in terms of investment and em-2005-06ployment, this sector accounts for

0 5000 10000 15000 20000

74.8% and 86%, respectively.

Employment (in persons)

The objectives of establishing EPZs Source: BEPZA data. in Bangladesh were no different from those behind EPZ formation in other countries and were equally comprehensive. In addition to generous incentives offered by EPZs, firms operating in EPZs can avail themselves of a Generalised System of Preferences (GSP) facility that Bangladesh enjoys towards several countries and regions. As for the performance of EPZs, Bhattacharya (1998) concluded that as of the mid-1990s they were making a modest contribution to the economy in terms of investment generation, job creation and export earnings, but were definitely demonstrating more dynamism than the rest of the economy. He also estimated the net overall welfare effect of EPZs in Bangladesh was a positive one even after taking into account public loss in terms of capital and administrative costs. At about the same time, Dowla (1997) evaluated the performance of Bangladesh EPZs in the light of their stated objectives, namely, foreign exchange earnings, employment generation and technology transfer, and found that they were successful in terms of the first two criteria.

As Figure 2 shows, despite some fluctuations, investment and employment in EPZs expanded substantially throughout the 1990s and have continued to grow up to the present time.11 Between 1994-95 and 2006-07, exports from EPZs increased at an annual rate of 20%, or almost twice the rate of increase of national exports (11%) over the same period. As a result of this trend, the contribution of EPZs to total national exports rose from 6.6% in 1994-95 to 17.4% in 2006-07.

Labour and Gender Issues in Bangladesh EPZs

Employment generation is one of the core performance indicators of an EPZ. During the first five years of the 1990s, the rate of job creation in EPZs in Bangladesh was faster than that in

o rganised manufacturing units in the domestic tariff area (DTA)

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rough calculation made on the basis of data from the Census of Manufacturing Industries indicates that formal manufacturing employment, both in EPZs and the DTA, increased at an annual rate of approximately 7.2% between 1995-96 and 1999-2000 whereas that within EPZs expanded at about 21.5% per annum.12 Although there are no comparable recent data available, between 1999-2000 and 2002-03 the annual growth rate of EPZ employment (11.1%) was much higher than that of total national manufacturing employment (5.2%).13

Female workers currently account for 64% of total EPZ employment, considerably higher than the 39.3% female share in total manufacturing


employment (Bangladesh Bureau of Statistics 2004). The high female share in EPZ employment is attri

butable to the primacy of garment manufacturing units in EPZs. Bhattacharya (1998) found that 10 years ago, female workers were mostly production workers, and were largely underrepresented among technical and salaried employees. He also found that the presence of female workers was higher in fully foreign-owned enterprises (75%) than in joint ventures (51.7%) and local companies (48.6%).

Although EPZs have attracted several foreign investors in garment manufacturing, they account for only a small part of the country’s garment industry as a whole. Since the early 1980s, various policy concessions have been given to export-oriented garment factories. An important one has been the bonded warehouse facility, which allows duty-free import of inputs relating to the manufacture of fabrics and other garment-related products. This is said to have created the equivalent of an EPZ at each garment factory location in Bangladesh (Quddus and Rashid 2000: 75). Presently, there are about 6,000 export-oriented garment factories in Bangladesh. Nevertheless, the EPZ garment factories have some distinctive characteristics. First, they are larger than their counterparts outside the EPZs and make a disproportionately large contribution to exports. According to Bangladesh Export Processing Zones Authority (BEPZA) information, garment factories, including knitwear manufacturers, in EPZs contribute 20.4% of the total garment and knitwear exports of Bangladesh. Employment in the EPZ clusters of garment-making factories, at 8% of total national employment in the sector, is higher than one might expect. Thus, in terms of size of operations, exports and number employed, EPZ units make a significant contribution.

The second feature of EPZ garment units is that a high proportion of them are foreign owned. Among the 119 registered g arment enterprises in EPZs, fully foreign-owned companies a ccount for 53.8% followed by local firms (27.7%) and joint v entures (18.5%). Although there is no relevant information available concerning the entire garment sector of Bangladesh, it is commonly acknowledged that the overwhelming majority of the garment firms in the country are locally owned.14

Comparisons of wages and working conditions in EPZ and non-EPZ garment units show that employment conditions in EPZs tend to be far superior (Bhattacharya 1998; Kabeer and Mahmud 2004). The reasons for this are twofold. First, EPZ factories tend to be larger and equipped with a better physical infrastructure than non-EPZ factories. Even though the non-EPZ factories include recently built establishments that are similar to those in EPZs, many of the others are smaller enterprises in which employment conditions are relatively backward.

Second, because of the enclave nature of EPZs, the duties of the BEPZA, which is vested with the responsibility of monitoring l abour conditions in all its member firms, can be more easily c arried out. As we will see, until recently trade unions were t otally banned from operating in Bangladesh’s EPZs. In the a bsence of collective bargaining, the BEPZA operates a minimum wage policy, separate from the one that applies to the rest of the country. Minimum wage rates in EPZs are higher than the statutory minimum for Bangladesh as a whole and higher than those paid by comparable non-EPZ factories.15

The relatively better wages and working conditions in EPZs, however, should not be taken to imply the absence of labour problems. The BEPZA Act of 1980 contains a provision whereby the government may, by notification in the official gazette, exempt an EPZ from the application of all or any of the legal provisions that are in force elsewhere in the country. In the initial years of EPZ operation, there was no official ban on trade unions, and it was not until a dispute in a Terry Towel factory, in 1986, that the government declared the inapplicability of the labour laws to EPZs.16 As mentioned earlier, governments in many countries have taken a hostile attitude towards trade union activities being carried out in EPZs, but even so, there have been very few countries that have openly and officially excluded EPZs from national labour legislation and from national systems of labour-management r elations (ILO 1998). In the absence of trade unions, the BEPZA’s Industrial Relations Department was entrusted with the task of handling labour disputes. According to Bhattacharya (1998), this procedure worked well, although it left much room for improvement. Dowla (1997) takes a more critical view of the BEPZA-controlled procedure, and points out that the Industrial Relations Department has been accused of creating work-related problems with the aim of collecting bribes from investors.

External pressure for allowing trade unions into the EPZs came mainly from the US and the ILO. It was the US government that finally pushed the Bangladesh government into reviewing its policy. In 1991, the US, the largest single-country market for Bangladesh’s garment exports, granted Dhaka duty-free access to its market for certain export items under a GSP. In the same year, the American Federation of Labour and Congress of Industrial Organisation (AFL-CIO) filed a petition with the US Trade Representative (USTR) concerning the Bangladesh government’s denial of freedom of association and other core ILO standards in EPZs.

In 2001, Bangladesh was granted a three-year extension of the GSP on the understanding that it would allow trade unions to operate in EPZs from 1 January 2004. Meanwhile, major foreign investors, including Japanese and South Korean firms, protested strongly against the move to allow trade unionism in EPZs. In January 2004, AFL-CIO called upon the USTR to withdraw the GSP benefits because Bangladesh had failed to implement its commitments. Caught between two conflicting pressures, in July 2004, the government enacted the EPZ Workers Association and Industrial Relations Act, which allowed the formation of a transitory organ, the Workers Representation and Welfare Committee (WRWC) with elected representatives to interact with management on different issues pertaining to the welfare of workers. The Act stipulated that the WRWC would cease to exist as soon as a Workers’ Association was formed in a unit after November 2006.

In line with the said schedule, in March 2008, “trade unions” in the name of Workers’ Associations were formed in 69 industrial units in the Dhaka and Chittagong EPZs. The main difference between the WRWCs and Workers’ Associations is that the latter can negotiate with the management on wages, hours of work, and other terms and conditions of employment. To have a Workers’ Association or not is a question that is resolved by way of a referendum held among the eligible workers. The workers of 22 units have voted against having a Workers’ Association at least another year. It is reported that despite the reluctance of owners, the BEPZA pushed for referendums to be held, in response partly to mounting pressure from a US labour group.17 While the government appeased the pro-trade union groups by passing legislation, the Act imposed certain restrictions on the operation of Workers’ Associations. Important among these was the prohibition of links with political parties and a moratorium on strikes or lockouts u ntil October 2008. In April 2008, the government decided to extend the ban on strikes and lockouts for two more years.

It should be noted that an abhorrence of trade unions, and a reluctance to accept them, are attitudes rooted in the widespread perception that trade unions in Bangladesh are highly politicised. It is widely believed that the fragmented trade unions affiliated to different political parties do little to advance the interests of workers and are not concerned with the establishment of sound industrial relations. On the whole, the garment industry has been relatively “free” from conventional trade unions because it is an industry dominated by young and mostly migrant female labour whose bargaining position vis-à-vis management is severely constrained. In that sense, the EPZ experience of having officially endorsed “trade unions”, however limited they may be, will offer an important test case as to whether Bangladesh can develop effective labour activism in the coming years. An increasing incidence of labour unrest began in the garment factories of Dhaka EPZ in May 2006. What is now needed is a rigorous examination of how alternative mechanisms such as the WRWCs and Workers’ Associations have fared in facilitating industrial relations.

EPZs/SEZs in India

India was the first country in Asia to set up an EPZ, in Kandla (Gujarat) in 1965. Despite its early engagement with the EPZ c oncept, India, unlike South Korea and Taiwan, has not been a

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notable example of “successful” EPZs in Asia. It is often argued that India failed to attract foreign investment because of strict government controls. The situation improved slightly with the e stablishment of Santa Cruz Electronics EPZ (Maharashtra) in 1974, which has contributed to the country’s exports of electronic products (Wong and Chu 1984: 5-7, 11; Rondinelli 1987: 94).18

Kundra (2000: 26, 41, 65) states that Indian EPZs lacked clear objectives until 1988 when it was decided that their main role was to provide an internationally competitive environment for the manufacture of exports. In 1980, a committee, widely known as the Tandon Committee, was set up to formulate policy measures for accelerating the progress of free trade zones and 100% export-oriented units. By that time, the performance of Kandla and Mumbai EPZs had substantially improved and the committee recommended establishing six or seven EPZs to provide a fillip to the country’s export promotion efforts. The New Electronics Policy initiated in 1984 under the then Prime Minister Indira Gandhi also considered the increased use of EPZs to promote electronics exports and technology transfer (Girdner 1987: 1193). Subsequently, four EPZs, Cochin, Madras, Falta and Noida, were approved and became operational during 1985-86. Visakhapatnam EPZ was approved in 1989 and was commissioned in 1994. I nitially, EPZs could be set up and managed only by the central government, and state governments had no role in their administration. Investment approvals were centralised until 1991 (Kundra 2000: 42). In 1994, the policy was changed to enable state g overnments, autonomous agencies and the private sector to d evelop infrastructure for new zones and strengthen infrastructure in the existing zones. Surat SEZ was established in 2000 as the first private EPZ in India.

India’s renewed interest in EPZs has become more conspicuous in recent years. In 2000, the Special Economic Zones Policy was announced and was followed by the Special Economic Zones Act, 2005, which came into effect on 10 February 2006. The seven EPZs established by the central government and Surat EPZ were converted into SEZs along with 11 state/private SEZs notified b etween 2000 and 2005. In addition, in line with the Act, 250 new SEZs were notified as of 11 August 2008.19 In August 2008, 1,897 units were in operation in SEZs. Of these, 1,141 units were in SEZs that were established prior to the Act coming into force. They provide direct employment to nearly 3,50,000 persons, of whom 1,99,000 are employed in the seven central EPZs-turned-SEZs. The share of female workers is about 30%. Although the share of SEZs in national exports had stagnated at around 5% for some time, it has begun to record higher growth with the establishment of new SEZs. In 2007-08, the total exports of seven c entral EPZs-turned-SEZs, 12 state and private EPZs-turned-SEZs and 39 new SEZs were Rs 66,638 crore, accounting for about 10% of the country’s total exports. In 2008-09, SEZ exports are estimated to grow further to reach Rs 90,000 crore.20 Sector-wise exports show the more diversified nature of Indian SEZs compared with Bangladesh EPZs (Table 1). The largest contribution is by gems and jewellery followed by trading and service, and electronics hardware. The share of textiles and garments, which a ccounted for 8.4% in the years 2002-05 (Aggarwal 2007: 17), has declined to 2%.

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Table 1: Sector-wise Break-up of Physical Exports from SEZs in India



Exports Share

Exports Share (Rs in crore) (%) (Rs in crore) (%)

Biotech 159.45 0.2 33.4 0.1

Computer/electronic software 3985.26 6.0 2597.29 7.5

Electronics hardware 11121.327 16.7 3846.342 11.1

Electronics 518.71 0.8 0.13 0.0

Engineering 1651.68 2.5 1389.17 4.0

Gems and jewellery 23006.065 34.5 16068.84 46.4

Chemicals and pharmaceuticals 1423.05 2.1 1106.29 3.2

Handicrafts 30.33 0.0 6.49 0.0

Plastic and rubber 657.66 1.0 393.22 1.1

Leather, footwear and sports goods 237.02 0.4 168.47 0.5

Ceramics 24 0.0 22.78 0.1

Food and agro industry 645.58 1.0 573.08 1.7

Non-conventional energy 126.01 0.2 0.0

Trading and service 20866.97 31.3 2370.16 6.8

Textiles and garments 1316.61 2.0 1333.87 3.9

Tobacco related products 18.48 0.0 3.17 0.0

Misc 849.48 1.3 4701.89 13.6

Total 66637.682 100.0 34614.592 100.0

Source: Compiled from Department of Commerce data (

India’s seemingly sudden enthusiasm for SEZs after a lull of more than three decades has been explained as a manifestation of the neoliberal discourse (Sampat 2008). A more down to earth explanation is given by Aggarwal (2006), who argues that the government reverted to EPZs in the expectation of separating them from the rest of the economy and making them engines of growth. The “successful” example of China was a major inducement for the change in government policy. The main difference between an SEZ and EPZ is that the former is an integrated township with a fully developed infrastructure. An EPZ is just an industrial enclave.21 This difference has become the subject of heated argument because SEZs by their very nature need a far greater amount of land than EPZs. The official web sites of Indian SEZs however lay stress on employment creation while insisting that the land requirement for all the SEZs approved, so far, constitutes a negligible share of India’s total area of agricultural land.

Labour and Gender Issues in Indian EPZs/SEZs

The SEZ Act 2005 sets creation of employment opportunities as one of the guidelines for notifying SEZs. Earlier, and in contrast to EPZ policy in countries with smaller economies, employment generation was not a key EPZ objective in India, as the impact of the additional employment created by EPZs was not very significant (Currie 1979: 14; Kundra 2000: 78). The shift in focus is very likely a reflection of the state’s concern with “jobless growth”. Notwithstanding, the actual potential of SEZs for employment generation is another matter, and one that needs thorough examination. At present, it is still too early to investigate the employment creation capacity of the newly created SEZs which are assumed to be distinctively different from the earlier EPZs. Here we review the performance of the seven central EPZ-turned-SEZs on the basis of the available literature.

As Table 2 (p 80) indicates, in March 2008, SEZs in India and Bangladesh provided employment for about 2,00,000 people in each country.22 An obvious difference between the two countries is the smaller size of employment per unit in Indian SEZs.23 As regards the size distribution of units, a study of Noida SEZ states that a small number of relatively larger units have a disproportionately high share of exports and employment, and that most of the units are small, a situation that is much the same in other I ndian SEZs (Mazumdar 2001: 167; Neetha and Varma 2004: 21). A possible reason for the smaller size of the average unit in Indian SEZs may be connected with the fact that Indian SEZs contain representatives of various types of manufacturing, whereas those of Bangladesh concentrate mainly on the garment industry. Moreover, most of the garment units that exist in Noida SEZ are small ones. Thus, nine out of Noida’s 16 units employed less than 100 workers (Neetha and Varma 2004: 30).

Table 2: Employment Generation of EPZs/SEZs in India and Bangladesh

(as on March 2008)

No of Units2 Employment (persons) Share of Women Workers (%)
India1 1,122 1,93,474 37
Bangladesh 276 2,11,829 64
  • (1) The figures for India covers only seven central government EPZ-turned SEZs.
  • (2) For India, the figure is the number of approved units while for Bangladesh, it is the number of operating units. Source: BEPZA presentation, May 2008; accessed on 20 August 2008.
  • Another feature is that the proportion of women workers in Indian SEZs is markedly lower than that in Bangladesh EPZs, and lower than in the EPZs of many other countries. The low concentration of female workers in Indian SEZs is attributable to the availability of male workers willing to work under the conditions offered by investors and also reflects regional sociocultural gender norms which act as a deterrent against female employment (Mazumdar 2001: 165; Neetha and Varma 2004: 26). The proportion of female workers varies among the seven EPZs/SEZs, between the 57% of Madras SEZ (the highest) and the 18% of Noida SEZ (the lowest). Of the seven SEZs, only in two, Madras SEZ and Falta SEZ (West Bengal), do women outnumber men. It cannot be denied that SEZs have offered employment to a number of women in the Indian context (Mazumdar 2001: 166; Ghosh 2002: 47) and that it has led to some economic empowerment (Aggarwal 2007: 21-22). But a broad decline has occurred in the percentage of women working in Indian SEZs. Thus, whereas women accounted for 48% of the SEZs labour force in the early 1990s (Mazmudar 2001: 165), by 2008, the proportion had dropped to 37%.24 In the case of Noida SEZ, too, the proportion of women in the workforce has fallen to 18% from between 21% and 25% in the latter half of the 1990s.25 Because time-series data are not available, it is impossible to elucidate the precise causes of the decline. According to Mazumdar (2001), industrial sickness is rather high in Indian SEZs. Along with fluctuations in export markets, this has resulted in job losses, especially among women.

    Neetha and Varma (2004: 28) found that in 2002, the decrease in the proportion of women employed was due a fall in employment in the garment industry which employs a relatively large number of women. As is the case of other countries, segmentation of work on the basis of gender can be seen in all industries in India. A notable feature of the garment units in Noida SEZ, w itnessed by Neetha and Varma (2004: 45-46), was that tailoring or sewing were almost exclusively the domain of men while women were mostly employed in trimming, checking, packing or as helpers.26 The pattern, however, does not hold true in garment factories in the south, in places such as Bangalore and Tiruppur where women are predominantly engaged as tailors (Murayama 2008). The shift of garment factories from north to south India in recent years may have contributed at least partly to the decline of employment in garment manufacture in Noida SEZ. Another possible reason for decline in female employment could be that an increasing number



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    may 30, 2009 vol xliv no 22

    of women are employed as casual or c ontract workers and they do not appear on company records (Pratap 2009).

    So far as wages and other working conditions are concerned, there are opposing views. In a survey carried out by Kundra (2000: 79-80), more than 75% of the respondents felt that wage rates were equal to or higher than those in the DTA. He concluded that the wage structure in SEZs more or less conforms to prevailing market rates. Working conditions were also seen as between good and very good by more than 70% of the respondents. In contrast, Mazumdar (2001: 205) asserts that 80% of Noida SEZ workers receive less than the minimum wage. Moreover, widespread malpractices have been detected, including the existence of a substantial number of unrecorded workers on company payrolls, non-availability of health insurance or workers’ provident funds, and denial of leave even for periods stipulated by the law. Neetha and Varma (2004: 57) found that in terms of employment practices and wage levels, units in Noida SEZ operate in conditions which closely approximate to those prevailing in the urban informal sector of the economy. Another study, of Madras SEZ, concluded that young women who constitute the bulk of the workforce receive pay that is far below the minimum wage (PRIA 1999: 18). A study by Aggarwal (2007: 24) of three SEZs, Noida, Santa Cruz and Madras, does not support the argument that a substantial proportion of SEZ labour receives less than minimum wages but says zone wages are not higher than non-zone wages. Aggarwal also finds working conditions differ among the SEZs in terms of working hours, overtime practices, overtime compensation, night shifts and the provision of leave and other facilities (2007: 25-29). Pratap (2009) has examined working conditions in Noida SEZ and Apache SEZ, a newly established private SEZ in Andhra Pradesh.27 Conditions in Apache SEZ were better with workers getting paid weekly holidays and one earned leave every 20 days. However, if workers take more leave than they are entitled to, they lose not only wages but also some other monthly allowances. Besides, compulsory overtime is a regular practice due to high production targets. In the absence of a comprehensive survey of wages in Indian SEZs, it is impossible to come to firm conclusions about levels of pay. Nevertheless, it is clear that in contrast to South Korea and Bangladesh, the wage levels of workers in SEZs are not much higher than those outside them and that breaches of labour laws, including minimum wage laws, are not uncommon.

    Under India’s labour laws, trade unions can be formed and registered inside SEZs. Although the original SEZ bill contained provisions to exempt SEZs from existing labour laws, they were dropped due to the opposition of mainly the left parties (Pratap 2009). However, in practice, it is reported that attempts to organise the workers are discouraged by investors as well as by zone authorities (PRIA 1999; Mazumdar 2001 and Pratap 2009). Companies in SEZs in India have been granted public utility s tatus by the respective state governments under the Industrial Disputes Act of 1947, which prohibits recourse to strikes without conciliation. Moreover, other rights available to workers are often subject to a series of restrictive practices. It has been pointed out that the responsibility for industrial dispute resolution within each zone now rests with a development commissioner,

    Economic & Political Weekly

    may 30, 2009 vol xliv no 22

    an executive chief appointed by the central government’s Ministry of Commerce, and that this arrangement tends to function u nfavourably against workers’ interests (Mazumdar 2001).28

    There are reports of labour movements in SEZs. The Centre of Indian Trade Unions (CITU) organised workers in Madras SEZ in 1995 to raise demands related to minimum wage, social security and child labour and was successful in negotiating with the g overnment and managements (Mansingh 2008: 254). The CITU also organised an All-India Convention of SEZ/EPZ workers in 2002 at Visakhapatnam. The All India Trade Union Congress (AITUC) is organising workers in garment units in Noida SEZ. Available reports indicate that working conditions in Noida SEZ are worse off than in other SEZs. The main concerns of the workers in Noida SEZ are related to appointment letters, working hours, holidays and wages. So far, however, unionisation of workers has been slow with managements and the zone authority exercising strict control over workers establishing contacts with outside trade unions.29


    In spite of significant reservations that have been made about their mixed record of economic and welfare benefits, EPZs, i ncluding SEZs and other similar types of arrangement, continue to proliferate in a large number of countries. Yet, at the same time, it appears that overall interest in EPZs, especially from the employment and gender perspectives, has lost its earlier vigour. On the basis of three countries’ experiences with EPZs, some findings are delineated.

    In countries such as South Korea, EPZs are no longer the focus of labour and gender concerns. As we have pointed out, contention over the use of labour has not ceased, but has moved outside the EPZs, one to parts of the country where increasing use is being made of subcontracting and non-regular workers and the other to less developed countries such as Bangladesh. South Korean investors are most active not only as investors but also as a developers of private EPZs in Bangladesh. Other countries such as Malaysia and Mauritius, where labour markets have tightened, are importing migrant workers (ILO 2003: 6).

    Second, as far as South Korea and Bangladesh are concerned, wage levels and working conditions in the EPZs are better than those in comparable jobs outside them, although of course it r emains open to question whether the same contrast obtains in EPZs elsewhere in the world. Whereas in South Korea, better f acilities have been earned through labour activism and a r esultant restructuring, in Bangladesh, EPZs from the beginning have been accorded a separate welfare framework by the state. In Bangladesh, better minimum conditions are set by the a uthorities in lieu of permitting trade unions to operate within the zones.

    The South Korean and Bangladesh cases, in which EPZ firms fare better than non-EPZs firms in terms of wages, raise two points of serious concern. One is the disparities that exist between units that are located inside and outside EPZs. Promoting domestic linkages is deemed to be one of the objectives of EPZ projects. Although the objective per se is no doubt admirable, it suffers from an innate contradiction from the perspective of the overall welfare of workers. Extended use of outsourcing may contribute to employment generation but since it is done to achieve lower operation of the EPZ where all the labour laws applicable to costs of production, the most likely response of subcontractors is public utilities are supposed to operate. It is more alarming that to squeeze labour costs. Unfortunately, wages and working con-the overall performance of EPZ firms in India was not satisditions in subcontracting units, and the remuneration and work-factory with a substantial number of closed and sick units despite ing conditions of individuals engaged in home-based work often various fiscal incentives and improvements in the infrastrucfall outside the analytical scope of studies on the impact of EPZs. ture. Exports began to pick up only recently mainly due to the Another concern is the suppression of labour activism. In Bangla-opening of new SEZs.30 While the generation of employment desh, EPZs prohibited trade union activity for about 20 years and opportunities is included among the objectives of SEZs, there is an alternative form of organisation has been worked out only re-still no sign of a critical assessment of what type of employment cently. It remains to be seen to what extent this new arrangement has been created so far by the EPZs/SEZs and, more importantly, will work for the benefit of workers within EPZs and how it will what the nature and quality of the new jobs may be in the new affect non-EPZs workers, especially in the garment industry, SEZs. It calls for an urgent, massive exercise to be undertaken in where the majority of the workers are not unionised. Both these India where there is wider diversity among firms in individual questions show that EPZs cannot be dealt with in isolation from SEZs and among different SEZs than in South Korea and the rest of the domestic economy and society. Bangladesh. And the exercise should be carried out taking into

    In the light of the South Korean and Bangladesh experiences the account the wider contexts inside and outside SEZs as the of EPZs, workers in the Indian EPZs seem to be largely deprived experiences of South Korea and Bangladesh show. Lastly, as far of protection from abuses by employers, apart from the limited as the present analysis is concerned, a further relaxation in guarantees offered by the authorities, and workers’ initiatives labour laws must be seen as detrimental to workers who are have also been limited in scope. Findings that workers in Noida already in a more disadvantageous position vis-à-vis manage-EPZ earn wages similar to those in the urban informal sector, ment and state agencies compared to South Korean and rather than the formal sector, suggests significant biases in the Bangladeshi EPZ workers.31


    1 Different names such as EPZ, FTZ, SEZ and maquiladora are used in different countries to refer to similar institutions. In this paper, EPZ is used interchangeably with other terms unless specified otherwise. The different characteristics of various types of EPZs are delineated in Boyenge (2007).

    2 World Economic Processing Zones Association (WEPZA) data (; accessed on 12 June 2008).

    3 Madani (1999) divided the literature on the effects of EPZs into three schools, namely neoclassical, cost-benefit and new growth theory.

    4 In the 1950s, South Korea pursued import-substitution industrialisation with the aim of achieving self-reliance. However, it did not last long because of the limited size of the domestic market and dependency on

    The e rt

    . T alisation of the 1960s differed from the exportoriented industrialisation strategy. While the export sector was expected to lead economic growth, the government simultaneously continued importsubstitution in the production of capital and production goods to be supplied to export industries. Thus both strategies were implemented in parallel.

    5 EPZs were called “Export Free Zones” in South Korea in those days. It is, however, clear that an Export Free Zone in South Korea was equivalent to an EPZ.

    6 Of 76 units in 1986, 56 were run by Japanese companies (Kang 1986: 33; Kang 1996b: 14; Cho 1990: 24).

    7 Of 76 operating units in 1986, 24 (the largest single category) were electrical goods and electronics factories. The same industrial category accounted for 62.6% (21,379 persons) of total employment (34,141 persons) (Kang 1986: 34-35). In 1990, the industry accounted for 70.6% of total investment (Kang 1996a: 69).

    8 According to estimates made by the Federation of Korean Trade Unions, minimum living expenses per female in 1986 amounted to 200,684 won (approximately $233) (Korea Labour Institute 2000: 109) whereas the average per capita wage of female manufacturing workers in Masan EPZ was 157,954 won ($183) (Cho 1990: 31).

    9 According to a presentation given by the BEPZA executive chairman in May 2008, six EPZs, Mongla, Comilla, Ishwardi, Uttara, Adamjee and Karnaphuli, are in operation while two more, Feni and Meghna (Munshiganj), are in the implementation stage.

    10 Beginning in 1999, a Korean firm, Youngone Corporation, has invested in the construction of a private EPZ in Chittagong. However, the issuance of an operating licence was suspended until the caretaker government looked into the matter in May 2007 in exchange for Bangladesh signing a Memorandum of Understanding with South Korea on manpower exports. In April 2008, the government granted a 10-year tax holiday to the KKo


    the K

    rean EPZ. Youngone began production in 1978 and has become one of the largest garment manufacturers in Bangladesh.

    11 Although there is a need for a more detailed examination, the years in which investment in EPZs dropped coincide with the years preceding general elections. Thus, political uncertainty could be the most plausible of the reasons for lower investment.

    12 The Census of Manufacturing Industries covers manufacturing establishments with 10 or more workers. The survey includes all units registered with the Chief Inspector of Factories under the Factories Act 1934 as well as those that have not yet been registered.

    13 Calculated on the basis of Bangladesh Bureau of Statistics (2004) data.

    14 Although we were unable to confirm the exact dates, FDI in the garment sector was at one time allowed only within EPZs (The Daily Star, 5 July 2004).

    15 The minimum wages in the EPZs, applicable irrespective of sectors, range between $22 and $63 according to different categories. Moreover, other benefits such as conveyance allowance, house rent, medical allowance, maternity benefit, festival bonus and overtime have to be paid. On the other hand, the statutory minimum wages for garment workers was raised in October 2006 for the first time in 12 years. These range from 1,200 taka (approximately $18) to 5,140 taka ($75), including not only basic salary but also house rent and other allowances.

    16 An interview with the then BEPZA executive chairman in August 2005. 17 The Daily Star, 23 March 2008.

    18 Aggarwal (2006) states that Santa Cruz EPZ also laid the foundations for the development of the modern jewellery industry in India.

    19 Figures have been obtained from the official web site of the Department of Commerce, Ministry of Commerce and Industry ( welcome.htm).

    20 The Economic Times, 17 March 2009.

    21 Additional concessions given to SEZs over EPZs include (1) no restriction on FDI excepting for industries reserved for the public sector and indus

    tries for which industrial licensing is compulsory;

    (2) unlimited sales to the domestic tariff area on payment of duty

    ; (; (
    ) n) n) n
    e re re r
    d fd fd f
    r mr mr m
    ufacturing items reserved for the small-scale sector; (4) no requirement of minimum net foreign exchange earnings; (5) the units shall have rights to get job work done from DTA units and also undertake job work of units in DTA; (6) subcontracting of part of the production abroad permitted; and (7) all the import-export operations to be through self-certification procedures, unless specifically stated otherwise (Mazumdar 2001: 176; Arunachalam 2008: 64-65).

    22 The employment data of India cover only direct employment. Therefore, if contract workers or those not entered on the company record books are included, the number may be much higher.

    23 The figure for India is the number of units approved. Therefore the units in operation may be fewer. For example, the number of operating units in Noida SEZ was 141 (; accessed on 20 August 2008) while the number of units approved, according to the official figure in March 2008, was 200. Nevertheless, the figures suggest that per unit employment in Bangladesh EPZs is higher that in Indian SEZs, and probably by a large margin.

    24 Figures for the 1990s are from Mazumdar 2001. 25 The figures for the 1990s are based on Neetha and Varma 2004.

    26 Mazumdar (2001) found that in the Noida garment industry, mechanisation of processes along with the introduction of the line system and de-skilling

    may 30, 2009 vol xliv no 22

    in tailoring began to lead to an increasein the employment of women.

    27 Apache SEZ, established by the Taiwan-based Apache group, is an authorised manufacturer for multinational Adidas.It started its operations in November 2006. In 2007-08, only one footwear manufacturing unit was approved, employing 4,750 workers, including 1,900 females. Exports in the same year were Rs 46 crore (figures from

    28 In India, labour law administration basically falls within the purview of state governments. For EPZs, however, the authority was shifted to the development commissioners by 2001 (Mazumdar 2001).

    29 Some workers in two garment units in Noida SEZ were suspended from their jobs because of their involvement in trade union activities. The case has been going on for a year. Interview with D L Sachdev, Secretary, All India Trade Union Congress, on 3 April 2009.

    30 According to Neetha and Varma (2004: 31-33), 68 units in Noida SEZ have been closed over the last 10 years chiefly due to export market problems, not labour problems.

    31 Although the central government stipulates that all labour laws are applicable to SEZs (prre



    elease by the Ministry of Labour and Employment dated 15 December 2008), several state governments have made amendments with respect to the applicability of labour laws. For instance, the Uttar Pradesh government exempted SEZs from the Contract Labour Act and the Andhra Pradesh government exempted SEZs from section 18 of the Minimum Wages Act. More such proposals are being tabled in various states (Pratap 2009).


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    Sampat, Preeti (2008): “Special Economic Zones in India”, Economic & Political Weekly, Vol 43, No 28.

    Shoesmith, Dennis, ed. (1986): Export Processing Zones in Five Countries: The Economic and Human Consequence (Hong Kong: Asia Partnership for Human Development).

    Wong, Kwan-Yiu and David K Y Chu (1984): “Export Processing Zones and Special Economic Zones as Generators of Economic Development: The Asian Experience”, Geografiska Annaler, 66 B.

    Yokota, Nobuko (1994): “The Structural Changes of Labour Market in Korea in the 1980s: The Case of Male Workers in Manufacturing”, Ajia Keizai, Vol 35, No 10 (in Japanese).

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