distinguish between foreign and domestic workers regarding union organization, practical barriers exist. Fishers operating on moving vessels, are often on fixed-term contracts and face high turnover, making it difficult to meet the 30-member threshold required to establish a union. The complex administrative procedures involved in forming unions further discourage foreign fishers. The NHRC recommends that the MOL address these challenges to ensure that foreign fishers can freely organize unions. Foreign fishers might want to organize or join unions in their home countries, flag States, or port States. The ITF generally encourages fishers to join unions in their flag States. As a flag State employing foreign fishers, Taiwan should at least support establishing relevant fishers’ unions, providing a local union option for fishers to join. A potential model is the system for merchant seafarers under the Regulations Governing the Management and Employment of Foreign National Seafarers, which requires foreign seafarers, whether boarding in Taiwan or abroad, to hold a membership card from the National Chinese Seamen’s Union to serve on a ship. 108 Freedom of communication must also be ensured to realize collective labor rights meaningfully. Enabling fishers to use Wi-Fi to contact unions will significantly support their ability to effectively organize and join a union Article 13 of the Regulations Governing the Management and Employment of Foreign National Seafarers: “Foreign national seafarers whose employments have been approved by the Maritime Administration, whether on board domestically or abroad, shall only carry out their on-board services upon completing the following procedures pursuant to their regulations: 1. Obtain the R.O.C. seafarer service manual and an approved on-duty visa. 2. Obtain a membership card to the National Chinese Seamen’s Union and pay the related dues. 3. Enroll in the labor insurance program. If a foreign national seafarer boards overseas due to continued employment or a change to the serving vessel or employer, the vessel owner or operator shall inform the port of registry or the Maritime Administration of any other domestic port of said seafarer’s service status within seven days and shall apply for the re-issuance of a service visa once the vessel returns or the seafarer is discharged. If employed foreign national seafarers need to enter the R.O.C., they shall submit the relevant documents provided by the Maritime Administration to the Ministry of Foreign Affairs or R.O.C. Foreign Embassies and Institutes that have been authorized by the Ministry of Foreign Affairs in order to apply for the proper entrance visa.” 108 137