Open Door submission to Labour Dept. re: FDW monthly minimum wage and food allowance


Labour Department, Government of the Hong Kong SAR


We wish to submit our views regarding the statutory minimum wage and the food allowance levels for foreign domestic workers in writing as follows:

The minimum wage and food allowance have very direct impacts on both employers and domestic workers. As part of the Hong Kong community, we must consider not only the benefit to Hong Kong families but also the level of fairness and decency we guarantee to everyone who comes to Hong Kong to work. This is not only our responsibility as a society, but serious consideration of these would make sure that our city’s reputation as a safe, caring and fair place for all is safeguarded and that this system of ‘imported’ domestic work is sustainable.

When there are reports of abuse and starvation in Hong Kong, we cannot just blame employers, or simply brush off such stories as exaggeration or isolated cases. It is our responsibility to show resolve and cooperative spirit to eliminate these things happening in Hong Kong. What is needed is decent government policies with sincere enforcement so that having a good or bad employer or domestic worker is not a matter of luck, and this system is sustainable and beneficial for all.
Our position on the minimum wage

Regarding the minimum wage for domestic workers, we agree with the suggestions of AMCB to raise it to $5,500 per month. We trust the Labour Department has received the rationale of AMCB, which we also agree with, as it has a basis in actual living costs in Hong Kong.

How to implement it

1)   [Some employers can bear the increased wage for their workers] For many employers, the increased wage would still be an acceptable cost, considering the enormous role the domestic worker plays in the household – often including cooking, cleaning, going to the market, as well as child and elderly care.

2)   [Some employers may change to local part-time domestic workers] An increasing number of households are now employers of more than one domestic worker; a higher monthly wage for foreign domestic workers may create the incentive to employ a local domestic worker instead, a positive effect for the local workforce. Households with no children or elderly would also be incentivized to consider employment of part-time local domestic workers.

3)   [Some employers would require care facilities or subsidy] For some employers with lower household incomes and child or elderly care needs, the increased expense would have a strong impact. For such households, the government should offer at least two options:

1)   modification of existing, or creation of new, childcare and elderly care facilities (which tend to have limited operating hours) so that these employers can avail of them, and

2)   in necessary cases, provide subsidies to families that meet certain income and needs criteria, to get child or elderly care subsidies.

For lower income families that employ domestic workers, it is important to provide other practical child and elderly care solutions, as their low incomes make them less able to provide decent food and accommodation for their domestic workers as well as less able to pay decent monthly salaries – i.e. these families tend to ‘compete’ for space and resources in the household, with their own workers, increasing the chances of depriving their workers.

The wage level of $5,500 appears to be a big jump from the previous level of $4,310 but the existing level was an extremely low increase ($100) from the previous level. The current level of $4,310 is also far below the amount that a local HK worker would receive for 10 hours a day of work under the statutory hourly minimum wage. We should also be aware that the Chinese government is considering to admit Filipino workers for domestic work, for a wage of about $15,000 per month. In contrast, the extremely low wage Hong Kong employers provide is less than one third of that.

Our position on the food allowance

We support the level of HK$2,500 as food allowance. We note that HK government statistics show monthly per capita household expenses of $9,253 per person, and average 27.9% of monthly expenses on food, i.e. the per capita expense on food per month is $2,525.

In practice, domestic workers often must eat bought food due to lack of time for preparation of less expensive food; and they also may require to consume food of their own culture which may be hard to obtain and sometimes be a bit costly. Furthermore, it is essential for a physically demanding job that the workers obtain enough nutrition.

Apart from setting a more decent food allowance level, we recommend the Labour Department indeed create a mechanism to monitor this and other conditions of the domestic workers, so that no case such as Erwiana’s can be repeated in Hong Kong ever again, where a person has been deprived of food and abused for months without discovery.


Thank you for your attention.



Doris Lee on behalf of
Open Door

25 August 2017

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