The purpose of this paper is to solve a relativization analysis problem which involves relabeling. Cecchetto and Donati (2015) argued that relative constructions are puzzling because they are clauses which have a nominal distribution. That is, the process from a clause to a nominal expression entails a change in labeling (i.e. re(labeling). Cecchetto and Donati (2015) also stated that the relative clauses are not CPs but NPs because the determiner of the head of the antecedent is merged with NP in the matrix clause. According to the raising analysis in relative clauses, the antecedent in the matrix originally derives from the object of the embedded verb. However, when the object of the verb in the relabeling analysis of relative clauses moves to the complement or the object position of matrix verb, it goes from A through A` and then to A position again. This movement cannot be permitted due to violating the Chain Uniformity Condition. Therefore, I argue that this movement in relabeling analysis of relative clauses has a theoretical problem. Applying Hicks` Smuggling Approach (2009) to relabeling analysis can solve this weakness in relative clauses. I show that the smuggled object with a Null OP in the relabeling analysis of relative clauses moves to the antecedent position in the matrix such as the object in Tough constructions which complies with the Chain Uniformity Condition.