Company responses regarding commitments to apply a single global standard aligned with Uyghur Forced Labor Prevention Act (UFLPA)
The Uyghur Forced Labor Prevention Act (UFLPA) came into force in the US in June 2022. The Act bans the importation of goods to the United States containing any amount of content produced or processed in the Xinjiang Uyghur Autonomous Region in China unless companies provide “clear and convincing evidence” that no component was produced with forced labour.
While welcoming the implementation of the UFLPA, the Coalition to End Forced Labour in the Uyghur Region highlighted the importance for companies to ensure that goods with high risks of being tainted with forced labour are not shifted to other markets. They called on companies with global sourcing operations to comply fully with the UFLPA and to apply a single global standard, consistent with the requirements of the law, across their entire supply chain for all retail markets. The Coalition also calls 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.
The Business & Human Rights Resource Centre invited 56 companies across the apparel, ICT and solar sectors to respond to four questions from the Coalition regarding their commitment to applying the UFLPA (these companies are listed in the database of Jewish World Watch 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):
- [Whether the company] is 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?
- [Whether the company] is committed to not re-exporting goods detained under the auspices of the UFLPA to other markets?
- [Whether the company] is committed to the above statements, how is it implementing these commitments?
- [Whether 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?
Of the 56 companies invited to respond, the Resource Centre received a total of 28 responses.
- Ten ICT companies were outreached to, and of these a total of 6 (60%) responded.
- Thirteen Solar companies were outreached to, and of these a total of 6 (46%) responded.
- Thirty-three apparel companies were outreached to, and of these a total of 16 (48%) responded.
- The American Apparel & Footwear Association also reached out to the Resource Centre to provide a response, which is included below.
Notably, of the 28 companies that provided a reply to the Resource Centre's outreach, only 12 companies specifically cited the UFPLA in their response.