Disturbing New Research Finds the EU is Likely a Dumping Ground for Fashion Made with Uyghur Forced Labour

EU must adopt effective import bans

December 6, 2023

The European Union should urgently adopt measures that prevent the import and sale of goods made with state-imposed forced labour given new research showing clothing likely produced with Uyghur forced labour is flooding the EU market, said the Coalition to End Forced Labour in the Uyghur Region. According to new research, 30 major apparel brands based in or selling to the EU, including Hugo Boss, Ralph Lauren, Prada, Burberry, Zara and its parent company, Inditex, are at risk of sourcing products made by Uyghurs forced to work in state-imposed labour transfer programs.

The report, Tailoring Responsibility: Tracing Apparel Supply Chains from the Uyghur Region to Europe, published by Uyghur Rights Monitor, Sheffield Hallam University, and the Uyghur Center for Democracy and Human Rights, traces these brands through intermediaries to four major Chinese fabric and apparel manufacturers with, according to the report, significant links to the Uyghur Region: Zhejiang Sunrise, Beijing Guanghua Textile Group / Beijing Fashion Holdings, Anhui Huamao Group Co. Ltd., and Xinjiang Zhongtai Group / Xinjiang Lihua Group.

“Any brand in compliance with international due diligence obligations should have long since severed ties with any supplier that sources from the Uyghur Region. Any brand buying from these suppliers that claims its products are free from Uyghur forced labour should demonstrate how exactly they know that,” said Rushan Abbas, Founder and Executive Director of Campaign for Uyghurs. “It breaks my heart to think that my innocent sister, a retired medical doctor, may be forced to make clothing for those companies.”

Companies’ failure to transparently disclose their supply chains means it is not possible for the researchers to prove definitively that any specific product purchased by any particular brand contained content made in the Uyghur Region. However, the report does use publicly available sources, including shipping data, corporate financial and media reporting, journalism, state propaganda, remote sensing data, and maps to evidence that major brands are still doing business with companies known to source from the Uyghur Region. This creates a high risk of forced-labour-made goods entering their supply chain and demonstrates the failure of voluntary corporate social responsibility initiatives and non-binding due diligence measures.

Import data from the US shows a significant reduction of goods from the Uyghur Region imported into the US since the implementation of the Uyghur Forced Labor Prevention Act (UFLPA) in June 2022, demonstrating that such prohibitions are effective in protecting markets and consumers from forced labour-tainted goods. In contrast, the new research shows that a significant volume of clothing at high risk of being linked to Uyghur forced labour is being imported and sold in the EU without restriction, pointing to a need for urgent action.

The EU is currently debating the proposed Forced Labour Regulation, which has the potential to be effective to address state-imposed forced labour. This would require scope for regional bans, combined with the ‘reversal of the burden of proof’ on state-imposed forced labour, as applied through the UFLPA. The Coalition urges the European Council and Commission to approve these amendments, as already proposed by the European Parliament, and for the trilogue to begin urgently.

“This research highlights the need for strong legislative responses across the globe, from Canada to South Korea. Governments must introduce and enforce robust measures to control the import of products made with forced labour. This includes in the EU, where the proposed Forced Labour Regulation must be meaningfully designed to prevent EU Member States becoming dumping grounds for Uyghur forced labour goods.” said Chloe Cranston, Head of Thematic Advocacy Programmes at Anti-Slavery International.

Immediate action is needed from both corporations and governments to address the apparel industry’s continued complicity in forced labour. The state’s forced labour programmes are a core component of the Chinese government’s broader persecution targeting Uyghurs and other Turkic and/or Muslim-majority peoples, which experts have determined may amount to crimes against humanity.

Companies headquartered or selling in the European Union should:

  • Urgently conduct desk-based due diligence to trace their entire supply chain, including research in Chinese language, to address any points of exposure to Uyghur forced labour and identify whether any suppliers have participated in state labour transfer programs.
  • Regularly update and adapt supply chain mapping and traceability efforts to combat action taken by companies to obscure their operations in the Uyghur Region and their participation in state-imposed labour transfers.
  • Fully exit the Uyghur Region. This includes immediately terminating any direct or indirect relationships linked to Uyghur forced labour at every tier of their supply chain.

The European Union should:

  • Strengthen the proposed Forced Labour Regulation by:
    • Including appropriate mechanisms to address state-imposed forced labour, such as a rebuttable presumption of forced labour on specific product groups from specified countries or regions.
    • Lowering the evidentiary threshold to initiate all investigations and to take a decision. We recommend not to create any evidence threshold to initiate the full investigation (art. 5) beyond an assessment of the validity of the claim and to trigger an additional type of decision to either block entry/placing on the market or seize products.
    • Designating the European Commission also as a competent authority, to conduct politically sensitive investigations, such as those linked to state-imposed forced labour, or to contribute to the investigation process, in particular when investigations in third countries are required.
  • Impose targeted sanctions on individuals and entities that are responsible for, or benefit from, forced labour.
  • Use all possible mechanisms to pressure the Chinese government to end forced labour and human trafficking in the Uyghur Region.


Photo by Cristine Enero on Unsplash