New Labor Governance? The German Supply Chain Act and National Governance Mechanisms in Brazil

ABSTRACT Due diligence laws respond to labor governance challenges and to a lack of public governance addressing human rights violations in Global Value Chains. Despite ongoing contestation, the German Supply Chain Due Diligence Act seeks to hold German‐based firms accountable for human rights risks in their supply chains. This paper explores how an underrepresented actor, organized labor, leverages this legal mechanism for local labor conflicts within transnational production systems, considering political‐economic specificities of the targeted countries. Drawing on a single case study based on expert interviews and document analysis, it examines the mobilization of a complaint filed under the Act in Brazil. The Act can function as a complementary transnational governance lever to national governance, yet its implementation requires a comprehensive National System of Industrial Relations and broader national labor‐related regulatory frameworks. The Act exemplifies a new form of transnational horizontal‐vertical labor governance while outsourcing sustainability governance to organized labor.