Research shows almost the entire global solar panel industry is at risk of being implicated in the forced labour of Uyghurs and other Turkic and Muslim-majority peoples:
- 95% of solar panels rely on one primary material – solar-grade polysilicon.
- The Uyghur Region accounts for approximately 35% of the world’s solar-grade polysilicon supply in 2022 (down from 45% since 2020) and approximately 32% of global metallurgical grade silicon production
- There are at least 90 Chinese and international companies whose supply chains are affected by Uyghur forced labour.
- The Uyghur Region’s largest raw materials supplier to the solar industry is heavily implicated in the forced labour of Uyghurs.
- All four of the Uyghur Region’s polysilicon manufacturers are implicated in Uyghur forced labour either through direct participation in forced labour schemes, and/or through their raw material sourcing.The four largest solar panel suppliers in the world all source from at least one of these polysilicon manufacturers.
- The vast majority of solar modules produced globally continue to have exposure to the Uyghur Region.
- Some of the world’s largest module manufacturers have bifurcated their supply chains to create alternative sources for polysilicon that they claim to have no exposure to the Uyghur Region
- Many companies that have created supply chains purportedly free of inputs from the Uyghur Region continue to source from suppliers or sub-suppliers that have exposure to the Uyghur Region for other product lines.
The Uyghur Forced Labor Prevention Act (UFLPA) went into effect in the United States on June 21, 2022. The UFLPA establishes a rebuttable presumption that the importation of any goods, wares, articles, and merchandise mined, produced, or manufactured wholly, or in part, in the Xinjiang Uyghur Autonomous Region (Uyghur Region), or produced by certain entities implicated in forced labour, is prohibited by Section 307 of the Tariff Act of 1930 and that such goods, wares, articles, and merchandise are not entitled to entry to the U.S. The presumption also applies to goods made in, or shipped through, China and other countries that include inputs made in the Uyghur Region. Companies must provide clear and convincing evidence that goods are not mined, produced, or manufactured wholly or in part by forced labor.
Silica-based products, including the raw materials used to make aluminum alloys, silicones, and polysilicon, have been identified as high-priority sectors for enforcement. Solar companies will have to demonstrate comprehensive due diligence and supply chain tracing, to comply with the law. This requirement extends throughout the entire supply chain, to include goods that may be shipped from elsewhere in China and to third countries for further processing.
The Coalition is demanding that companies apply a single global standard, consistent with the requirements of the UFLPA, across their entire supply chain for all retail markets. We also call on companies to refrain from re-exporting any goods denied entry to the U.S. under the auspices of the UFLPA and attempting to sell in other markets, which would create markets for goods tainted with forced labour. Specifically, we demand that companies comply fully with the UFLPA and:
- Commit to apply a single global standard, aligned with the legal requirements set forth in the UFLPA, to exclude Uyghur forced labour across its supply chains, and to not bifurcate their supply chains.
- Commit to not re-exporting goods detained under the auspices of the UFLPA to other markets.
We encourage shareholders and advocates to join us in calling on companies to make these commitments by asking:
- Is the company applying a single global standard, aligned with the legal requirements set forth in the UFLPA, to exclude Uyghur forced labour across its supply chains, and to not bifurcate its supply chains?
- Is the company committed to not re-exporting goods detained under the auspices of the UFLPA to other markets?
- If the company is committed to the above statements, how is it implementing these commitments?
- If the company is not committed to a single global standard, how is it ensuring that goods imported into markets other than the US are not tainted?
In particular, the Coalition calls on the following companies, which independent research has credibly and publicly identified as operating or having business relationships in the Uyghur Region, or as at high risk of sourcing from the Uyghur Region, and that have a presence or sell goods in the U.S., to commit to these demands.
In September 2022, the Business & Human Rights Resource Centre sought responses to the four above questions from these companies. Of the thirteen companies, only six (46%) responded. The Coalition will be following up with these companies about their actions to remove Uyghur forced labour across their supply chain. See all company responses here.
- Acciona S.A. (response)
- Canadian Solar Inc. (no response)
- Consolidated Edison Inc. (no response)
- DECMIL Group (no response)
- Enel SpA (response)
- Iberdrola S.A. (response)
- Marubeni Corporation (response)
- NextEra Energy Inc. (response)
- OCI Company Ltd (no response)
- Sunnova Energy International Inc. (response)
- Toyo Engineering Corp. (no response)
- Wacker Chemie AG (no response)
- WEG S.A. (no response)
The Coalition equally calls on all companies, including those without a US market, to apply a single global standard, in line with the Coalition’s Brand commitment to exit the Uyghur Region and prevent use of forced labour of Uyghur and other Turkic and Muslim-majority peoples / UFPLA, which includes a commitment to not bifurcate their supply chains. This demand is made in consideration of existing and forthcoming laws in other jurisdictions, particularly the EU and EU Member States, and to raise business standards globally.
For solar companies wishing to speak with the Coalition, please email [email protected].
- Over-Exposed: Uyghur Region Exposure Assessment for Solar Industry Sourcing, Sheffield Hallam University (Aug 2023)
- Solar Supply Chain Grows More Opaque Amid Human Rights Concerns, New York Times (Aug 2023)
- Some UK Solar Panels Likely Made by Uighur Slave Labour in China, The Times (Jul 2023)
- Sins of a Solar Empire an Industry Imperative to Address Unethical Solar Photovoltaic Manufacturing in Xinjiang, Breakthrough Institute (Nov 2022)
- In Broad Daylight: Uyghur Forced Labour and Global Solar Supply Chains, Sheffield Hallam University (May 2021)
- Solar Panels Are Key to Biden’s Energy Plan. But the Global Supply Chain May Rely on Forced Labor from China, CNN (May 2021)
- Report Warns of Uighur Forced Labour in Solar Panel Supply Chain, Aljazeera (May 2021)
- China Uses Uyghur Forced Labour to Make Solar Panels, Says Report, BBC (May 2021)
- Revealed: UK Solar Projects Using Panels From Firms Linked to Xinjiang Forced Labour, The Guardian (Apr 2021)
- Chinese Solar Companies Tied to Use of Forced Labor, New York Times (Jan 2021)