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Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Minimum Age Convention, 1973 (No. 138) - Israel (Ratification: 1979)

Other comments on C138

Observation
  1. 2025
  2. 1997

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The Committee takes note of the observations communicated by the General Federation of Labour in Israel (HISTADRUT), communicated with the Government’s report.
Article 7(1) and (3) of the Convention. Light work and determination of these types of activities. The Committee recalls that section 2(c) of the Youth Labour Law No. 5713-1953, provides that the Minister of Labour and Social Welfare may, in general or in specific cases, permit the employment of a child who is 14 years old and in respect of whom exemption has been granted from attending school. The Government indicates, in its report, that it has not adopted any regulations determining the types of light work that children from the age of 14 years may engage in, nor does it expect to make progress in this regard, due to constraints arising from other legislative priorities under the responsibilities of the Ministry of Labour. The Government refers again to the Youth Employment Regulations (Prohibited and Restricted Work), 5756–1995, which prohibit or restrict work that poses a potential safety risk to boys and girls and which were amended in 2018 to include a prohibition on employing youth at construction sites. This prohibition is in effect until the year 2028. The Government therefore states that, while the law and regulations do not explicitly define what constitutes “light work”, they set out which types of work are prohibited for youth.
The Committee notes the observations from HISTADRUT according to which the Youth Employment Regulations (Prohibited and Restricted Work) do not provide a comprehensive solution to the issue of determining light work activities for children, since these regulations do not differentiate between children aged 14 and older youth, and they do not address issues such as the permissible number of working hours for children.
The Committee observes that the Youth Employment Regulations (Prohibited and Restricted Work), 5756–1995, to which the Government refers, pertain to the types of hazardous work prohibited to children under the age of 16, rather than the types of light work permitted to children over the age of 14. Noting that it has been raising this point for more than 20 years, the Committee expresses its regret that regulations determining the types of light work activities for children from the age of 14 have yet to be adopted by the Government pursuant to section 2(c) of Youth Labour Law No. 5713-1953. The Committee recalls that, in accordance with Article 7(1) and (3) of the Convention, while light work may be permitted to children who are at least 13 years of age, the activities in which such employment or work may be permitted and the number of hours during which such employment or work may be undertaken must be prescribed by the competent authority. The Committee requests the Government to take all necessary measures to ensure that the regulations determining the activities permitted as light work and the number of working hours allowed in this type of employment, in accordance with Article 7(3) of the Convention, are developed and adopted in the near future. It requests the Government to provide information on any progress made in this regard.
Labour inspection and application of the Convention in practice. The Committee notes the observations of HISTADRUT referring to a survey from the Working and Studying Youth Federation of 2024, according to which 58 per cent of Israeli youth have worked or are currently working, 17 per cent of youth aged 14–15 were employed during the school year in violation of the law, and 43 per cent of working youth reported harm to their studies as a result of their work. HISTADRUT states that the Administration for Regulation and Enforcement at the Ministry of Labour should be strengthened by adding more inspectors.
The Committee notes that the Government – through the Ministry of Labour’s Strategy, Research and Regulation Division – states that administrative data is lacking because the employment of minors under 15 is not officially reported and surveys only cover employment starting from age 15 and above. The Government indicates that data from the Central Bureau of Statistics (CBS) Labour Force Survey on youth aged 15–17 for the period 2014–23 were reviewed. According to this data, youth employment in that age group did not exceed 17 per cent during summer vacations and averaged around 8 per cent during the school year. The Government further states that it can reasonably be inferred that employment rates among 14–15-year-olds are even lower, and therefore, official statistics do not support the figures reported by the HISTADRUT survey. The Committee strongly encourages the Government to take the necessary measures to ensure that data on the nature, extent and trends of child labour, particularly as regards children under the minimum age for employment or work, is collected and made available, to the extent possible disaggregated by sex and age category. The Committee requests the Government to provide information on the number and nature of the violations detected by the Labour Inspectorate related to child labour and the types of penalties imposed.
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