Sheffield Hallam Publishes List of 35,000 Companies Producing in Xinjiang

Sheffield Hallam University issued reports detailing Uyghur forced labor in the cotton, polysilicon, PVC and metals industries presaged withhold release orders and detentions against goods containing those inputs. Now, its Forced Labor Lab is offering the public a massive list of companies that operate in the Uyghur region, whose products are therefore considered to be made with forced labor unless importers can prove otherwise.

The university recently published two spreadsheets, one with more than 35,000 companies, with Chinese and English names and addresses, most likely to be related to mining, farming, manufacturing, technology and export. The companies are grouped by sector. It also published a larger list of more than 50,000 companies, including some unlikely to be relevant to U.S. importers, such as those operating retail establishments, doing construction work, or providing professional services.

The trade community has been asking CBP for a no-go list so it can avoid detentions of its products. If compliance officers are able to trace their supply chains back to the raw material, this could be what they've been asking for.

"This provides an expansive portrait of the corporate environment of the Uyghur Region, though it is not exhaustive," the writers said.

The lab also recently published a six-page paper on how to exclude products made with forced labor from your supply chains. The guide says a contract should say that you "will provide a full list of all suppliers and sub-suppliers across all tiers of the value chain, including registered company names in local language. You should be able to provide purchase orders, invoices, and receipts upon request at any time."

It also includes 13 questions to ask before contracting with a Chinese supplier. Many of those are designed to get at the problem of forced labor transfers, which also fall under the rebuttable presumption in the Uyghur Forced Labor Prevention Act. In those cases, a factory in Guandong province, 4,000 km from Xinjiang's capital, could still be subject to the act, because dozens of Uyghur or other Muslim minority workers were transferred to work there under a state-run poverty alleviation scheme.

"If a company can demonstrate that all of their Uyghur Region originated workers were brought onto staff through open recruitment fairs unaffiliated with central, regional, or local government recruitment or transfer programs, this could be an instance of legitimate employment," the guide said.