‘Tailoring Responsibility: Tracing Apparel Supply Chains from the Uyghur Region to Europe’ provides critical insight into the ways forced labour-made apparel is moving from the Uyghur Region into the European Union market.

This collaboration between the Uyghur Rights Monitor, the Helena Kennedy Centre for International Justice at Sheffield Hallam University, and the Uyghur Center for Democracy and Human Rights finds a substantial volume of apparel tainted by Uyghur forced labour is moving into the EU without restriction.

Throughout the report, 39 well-known brands are identified to be at high risk of sourcing apparel made by Uyghurs compelled to participate in state-imposed labour transfers.

The Uyghur Region produces approximately 23% of the global supply of cotton and 10% of the world’s PVC, a key material in the production of protective clothing and accessories. As a result, a huge quantity of the world’s clothes and footwear risk being implicated in the forced labour of the Uyghur people.

Since 2017, the PRC has imposed an unprecedented system of forced labour on Uyghurs and other Turkic, majority Muslim citizens of the Region. State-imposed forced labour programmes are a primary nexus through which the PRC government is inflicting its genocidal policies on the Uyghur people. Through the facilitation of familial separation, land expropriation and cultural assimilation, these schemes are eliminating vital resources for the continuity of community and culture.

This report traces various apparel supply chains from the Uyghur Region to high-street and high-end brands operating and selling to the EU. To conduct this mapping, the research team identified four major China-headquartered fabric and apparel manufacturers that have significant ties to the Uyghur Region, through sourcing, subsidiaries, and/or manufacturing. Using publicly available sources, including shipping data, corporate financial and media reporting, journalism, state propaganda, remote sensing data, and maps, they then traced the supply chains of these companies to brands and retailers in the EU.

The number of apparel companies identified in this mapping exercise indicates that EU policy is not protecting its consumers from buying products made with Uyghur forced labour. With the EU poised to decide on forced labour regulation and the Corporate Sustainability Due Diligence Directive, this report also addresses how legislation can insulate markets from complicity in human rights violations against the Uyghurs. In particular, the report highlights the efficacy of the US’s Uyghur Forced Labor Prevention Act in curbing imports from the Region. These successes may prove instructive for EU policymakers alarmed by the contents of the report. 

The report also evidence that companies are attempting to obfuscate their participation in state-imposed labour transfers. The report details a myriad of tactics companies are deploying to obfuscate their operations in the Region, from no longer advertising their engagement in labour transfers online to changing company names. These strategies indicate that companies continue to profit from forced labour practices under a thin veil of legitimacy.

In light of these findings, the report recommends companies conduct forensic due diligence to identify their links to the Uyghur Region and ensure that forced-labour-made goods do not reach EU consumers.

This report includes recommendations for legislative action to address the influx of forced-labour made goods into the EU market, such as to:

• Support the regulation to ban the import of products made with forced labour. The ban should include all products made in whole or in part with forced labour, should include no de minimis standard that would allow any portion of forced labour made goods to enter, and should apply to businesses of all sizes. Import bans must also incorporate a rebuttable presumption to apply in cases of state-imposed forced labour.
• Support the EU Corporate Sustainability Due Diligence Directive (CS3D) to ensure that companies are responsible for addressing human rights violations across the value chain.
• Support manifest transparency legislation that makes all ground, air, rail, and sea shipments publicly available, to aid in the investigation of supply chains tainted with forced labour.
• Support multi-lateral information sharing of data regarding cargo that has been identified as having been made with forced labour.

Sheffield Hallam University

December 2023