Labour standards provisions contained within the European Union's (EU) free trade agreements (FTAs) are a major iteration of attempts to regulate working conditions in the global economy. This article develops an analysis of how the legal and institutional mechanisms established by these FTAs intersect with global value chain governance dynamics in countries with contrasting political economies. The article formulates an original analytical framework to explore how governance arrangements and power relations between lead firms in core markets and suppliers in FTA signatory countries shape and constrain the effectiveness of labour provisions in FTAs. This analysis demonstrates how the common framework of labour provisions in EU trade agreements, when applied in a uniform manner across differentiated political-economic contexts, face serious difficulties in creating meaningful change for workers in global value chains.