Critics argue that enforcing a minimum age for admission to employment diverts attention, energy and resources from “truly serious” abuse in the workplace, and that “abolition efforts” should be better spent on improving child labor conditions. In practice, most child labour inspection systems simultaneously enforce minimum age laws and the prohibition of hazardous work. One does not exclude the other. On the contrary, we would argue that focusing resources on improving the working conditions of young children is far less beneficial than investing those resources in improving family livelihoods and access to quality education. Developing awareness and understanding of the causes and consequences of child labour is the first step a company can take to combat child labour. This means identifying problems and determining whether child labour is a problem within the company. Companies that buy from certain sectors with geographically distant supply chains need to be particularly vigilant. However, child labour is also less visible in developed developed countries, where it occurs, for example, in some immigrant communities. Each state has a Child Labor Act that regulates the conditions under which employers may hire children and adolescents, as well as a School Attendance Act that requires children of a certain age to attend school.
The regulation of the minimum age for admission to employment is the dominant instrument in the fight against child labour worldwide. If enforced, these rules may change the type of work in which children participate, but minimum age rules are not a useful tool for promoting education. Despite their near-universal adoption, recent research in 59 developing countries shows little evidence that these regulations have a significant impact on children`s time allocation. In the future, coordination of compulsory education laws and minimum age regulations can help maximize the combined impact of these regulations on children`s time allocation, but these regulations should not be at the heart of the global fight against child labour. Human Rights Watch has been conducting research and advocacy on child labor since 1994. We conducted research on child labor in countries across all regions, and interviewed hundreds of children working in a variety of sectors, including domestic work, gold mining, silk production, and the cultivation and harvesting of bananas, sugar cane, tobacco, cotton, and other agricultural crops.  An exemplary case is that of the United States, which has not ratified Convention No. 138 and sets 16 as the minimum age for admission to employment in all sectors except agriculture, where the minimum age for work on large farms is 12 and there is no minimum age for employment on small farms. As a result, hundreds of thousands of children work in U.S.
agriculture at an age that is prohibited in all other sectors. According to government estimates, these children drop out of school four times more often than other children.  Most working children are involved in activities that fall outside the scope of the Minimum Age Regulations. A study examines the impact of laws restricting the minimum age for admission to employment using multiple indicator cluster data for 59 countries with a minimum age for labour legislation . Since existing minimum age laws change the age distribution of employment, it is necessary to examine the extent to which differences in paid employment can be explained by differences in age between children. Very little, as it turns out. Household characteristics such as home-sharing, parental education and income account for 63% of the differences in paid employment across the 59 countries. In none of the countries does age account for more than 3% of the change in paid employment (the average is less than 1%). Even if all age-related differences in paid employment are attributed to minimum age laws, which would be unrealistic since older children are also more mature and productive workers, the laws appear to be of minimal importance to account for age-related differences. The term “child labour” should not be confused with “youth employment” or “student work”. Child labour is a form of exploitation that constitutes a violation of a human right and is recognized and defined by international instruments. It is the stated policy of the international community and almost all governments to abolish child labour.
While the term “child” includes all girls and boys under the age of 18, it is not necessary to remove all children under the age of 18 from the labour market: the basic rules of international standards distinguish between acceptable work and unacceptable work for children of different ages and stages of development.  Bree Akesson et al., Open Letter to the Committee on the Rights of the Child, January 27, 2016, available at: www.opendemocracy.net/open-letter-better-approach-to-child-work (accessed April 1, 2016). Children can make a productive contribution to their household in many ways by working inside and outside the household (see Figure 1). Participation in unpaid household services is widespread and significant. Children cook, clean, shop and take care of their family members. Participation in these unpaid household services is 25 times more common than paid employment in MICS data. About 23% of children aged 8-14 also contribute economically to their households by participating in farms and family businesses. What is child labour under the Fair Labor Standards Act? Stepping up efforts to reduce family poverty and improve access to education will do more to improve children`s lives than to give young children the opportunity to work. In recent years, many countries have made great strides in increasing children`s school enrolment rates, expanding access to education and reducing family poverty through social protection programmes. Programs that provide poor families with a guaranteed monthly income – often referred to as “cash transfer programs” – have proven effective in reducing family poverty, increasing school enrolment, and reducing child labor. The implementation of cash transfer programs is credited with the elimination of 5 million people in Brazil and 60 million people in India.  Meta-analyses of cash transfer programs have found that recipients of these programs are 23-41% more likely to be educated than their peers.
 Many countries have also increased enrolment rates by abolishing school fees, providing school meals, improving school transportation, and covering the cost of books, uniforms, and other related school expenses. Such initiatives can also lead to a significant reduction in child labour. For example, in just over a decade, Morocco has used several of these strategies to increase the number of children completing primary school by more than 20 per cent and reduce the labour rate of children aged 7 to 15 from 9.7 per cent to 2.5 per cent.   See, for example, Human Rights Watch, Lonely Servitude: Child Domestic Labor in Morocco, November 2012, www.hrw.org/report/2012/11/15/lonely-servitude/child-domestic-labor-morocco. Our experience of child labour around the world makes us deeply sceptical about whether governments are willing or able to provide safe and decent working conditions for children under the minimum age for employment. Many governments are already failing to adequately enforce existing laws that set a minimum age for admission to employment and prohibit the worst forms of child labour. We believe that it is unlikely that the same governments would adequately monitor even younger children if the current minimum age were lifted. While some children may benefit from good working conditions, the lack of legal protection can put many others at risk. The idea that a mandatory minimum age rule primarily diverts children from regulated activities to unregulated activities, rather than eliminating child labour, differs from the premise of most theoretical articles on minimum age regulation, which generally assume that the child has only one potential job available (which the minimum age regulation prohibits). In the most cited model of child labour literature, there is only one sector of employment for child labour, and regulations may prohibit it altogether . Further refinement adds a second unregulated sector . In this two-sector model, declining employment in the regulated sector can lower wages and increase child labour throughout the economy (if the unregulated sector is also child labour), as lower household incomes encourage more children to work.
 K. Beegle, R. Dehejia, R. Gatti and S. Krutikova, The consequences of child labor: evidence from longitudinal data in rural Tanzania, Policy Research working paper no. WPS 4677, World Bank, 2008, documents.worldbank.org/curated/en/2008/07/9698636/consequences-child-labor-evidence-longitudinal-data-rural-tanzania (accessed April 1, 2016). Like most child lawyers, we agree that child labour can contribute positively to their development in an age-appropriate manner and in safe and healthy conditions. However, we do not believe that the removal of minimum age restrictions for employment is in the best interests of children.
We are writing on behalf of Human Rights Watch in response to a January 2016 open letter to the Commission on Child Labor and Minimum Age for Employment.  In particular, the letter opposes a minimum age for admission to employment and invites the Committee to refer to the International Labour Organization Convention on Minimum Age for Admission to Employment (Convention No.