A recent decision by the 인천지방노동위원회 (Incheon Regional Labor Committee) has affirmed the employer status of 인천국제공항공사 (Incheon International Airport Corporation) regarding its subcontracted labor force, and has approved the separation of bargaining units among those subcontracted unions based on their respective upper organizations.
Bargaining Unit Separation
The decision, reached on April 8, 2026, follows a similar ruling after the implementation of the 노란봉투법 (Yellow Envelope Law, or revised Labor Union Act Articles 2 and 3) regarding subcontracted workers at 포스코 (POSCO). The 인천지방노동위원회 ruled that 인천국제공항공사 exerts control over industrial safety issues, and subsequently separated bargaining units according to the unions’ affiliations – namely, those associated with 한국노총 (Korean Confederation of Trade Unions), 민주노총 (Democratic Confederation of Trade Unions), and other organizations.
The seven subcontracting companies involved in the decision are 전국공공운수사회서비스노동조합 (National Public Transport and Social Services Labor Union), 인천공항시설엔지니어노동조합 (Incheon Airport Facilities Engineer Labor Union), 보안검색통합노동조합 (Integrated Security Search Labor Union), 인천국제공항보안노동조합 (Incheon International Airport Security Labor Union), 한마음인천공항노동조합 (Hanmaum Incheon Airport Labor Union), 인천공항시설관리노동조합 (Incheon Airport Facilities Management Labor Union), and 전국환경시설노동조합 (National Environmental Facilities Labor Union). These unions all submitted requests for bargaining unit separation to the 인천지방노동위원회 last month.
The 인천지방노동위원회 determined that 인천국제공항공사 has control over key airport facilities and equipment, oversees the airport’s overall safety and health management system, and that both labor and management agree with this assessment. The committee considered similarities in union interests and potential for conflict when deciding to divide the subcontracted workforce into three bargaining units based on their upper organizational affiliation.
The 노란봉투법 allows for the use of a bargaining unit separation system within the framework of the ‘single negotiation window’ procedure when 원청 (original contractor) and 하청노조 (subcontracted unions) negotiate. While 원청노조 (original contractor unions) and 하청노조 (subcontracted unions) generally negotiate separately, subcontracted unions are typically subject to a single negotiation window procedure. However, if the nature of the work, characteristics, working conditions, or interests differ between subcontracted unions, the labor committee can approve the separation of bargaining units.
민길수 (Min Gil-su), Chairman of the 인천지방노동위원회, stated that 인천국제공항공사, as a representative public institution, employs many subcontracted workers and hopes this model for separating bargaining units will lead to “practical dialogue between 원·하청 노사 (original and subcontracted labor and management) to improve working conditions and provide better public services.”
Frequently Asked Questions
What was the outcome of the 인천지방노동위원회’s decision?
The 인천지방노동위원회 recognized 인천국제공항공사’s employer status regarding industrial safety issues and approved the separation of bargaining units among its subcontracted unions based on their upper organizational affiliations – 한국노총, 민주노총, and others.

When were the requests for bargaining unit separation submitted?
인천국제공항공사와 7개 하청노조 (Incheon International Airport Corporation and seven subcontracted unions) submitted requests for bargaining unit separation to the 인천지방노동위원회 last month, following the implementation of the 노란봉투법 on April 10th.
What factors did the 인천지방노동위원회 consider when making its decision?
The 인천지방노동위원회 considered 인천국제공항공사’s control over airport facilities and safety management, as well as the agreement of both labor and management, and the potential for conflict between unions when deciding to separate the bargaining units.
How might this decision impact future labor negotiations at 인천국제공항공사?
