"OVER- EXPOSED: Uyghur Region Exposure Assessment for Solar Industry Sourcing", November 2023

"In the last five years, the government of the People’s Republic of China (PRC) has imposed a region-wide, ethnically targeted program ofstate-imposed forced labor upon the Uyghur community and other minoritized citizens of the Xinjiang Uyghur Autonomous Region (XUAR or Uyghur Region). This oppressive program has been documented in numerous
academic and journalistic books, papers, and reports, and the consequences for global supply chains have been widely demonstrated.

The Uyghur Region produces between one third and one half of the world’s solar-grade polysilicon. The Chinese government deliberately located production in region over the last fifteen years, undercutting the price of the essential product, and leading to the shuttering of production in other parts of the world. When news of the human rights crisis emerged, the world was made aware of how reliant our renewable energy future was on that region. As early as October 2020, representatives of the solar energy industry
recognized that the crisis in the Uyghur Region significantly affected solar supply chains. Less discussed by the industry was the fact that the Uyghur Region was also a hub of production for polysilicon’s pre-cursor material, metallurgical grade silicon (MGS). The PRC government had capitalized on the availability of cheap coal in the region to make it the epicenter of the world’s solar industry.

Since 2021, a series of reports—including one by Sheffield Hallam University—has underscored the dominance of the Uyghur Region’s manufacturing in the solar industry. International outrage, both within the solar industry and among governments, investors, consumers, and affected communities, has fueled significant change in solar industry sourcing, and we have seen significant growth in the sector, mainly within other parts of China but also abroad. A 2021 US ban on the import of the products of one XUAR-based
company essential to the solar supply chain and the enactment of the US Uyghur Forced Labor Prevention Act (UFLPA) have likely been significant encouragement for the solar industry’s extraordinarily rapid shifts away from Uyghur Region sourcing, an expansion of manufacturing, and the development of dedicated supply chains that do not include inputs from the region...

This report addresses the lack of transparency by mapping—to the extent that available data and expertise in the field make possible—the supply chains of the solar industry’s titans as well as a selection of other solar module manufacturers. Given the data available, the report assesses ten manufacturers’ exposure to the Uyghur Region, carefully selecting for size and diversity. We assessed the top five manufacturers (which together manufacture 70% of the world’s solar modules) as well as some of the smaller brands; we assess companies operating in China, Southeast Asia, the EU, and the US; we review some that had previously been known to be connected to the Uyghur Region and others that were suspected to be less exposed; and we selected some because they are highly vertically integrated and others that are reliant on external suppliers throughout the value chain.

Because the vast majority of companies are unwilling to make their full supply chains transparent, the report deploys the expertise of a solar industry expert for analysis of certain aspects of the supply chains that remain opaque. Industry expertise provides insight into XUAR-sourcing exposure through the application of historical supply contracts, sourcing trends, and geographical information that would be relevant to sourcing decisions for each individual company. Every company was provided the opportunity to amend or supplement the supply chain maps provided in this report and to respond to our claims. Most companies did not respond or referred to Chinese anti-sanctions and espionage laws as an explanation for not providing detailed information regarding their supply chains...

The most significant findings of the report include the following:

• The Uyghur Region now accounts for approximately 35% of the world’s polysilicon (down from 45%) and as much as 32% of global metallurgical grade silicon production.
• The vast majority of modules produced globally continues to have exposure to the Uyghur Region. Production in China significantly increases exposure.
• Some of the world’s largest module manufacturers appear to have bifurcated their supply chains to create a product line that they claim to be free of XUAR inputs, though evidence of these claims varies by supplier. Most companies have suggested that these supply chains are dedicated to the US market or designed with UFLPA compliance in mind. The portion of modules made by China-based companies on these dedicated supply chains appears to range from 7–14% of the companies’ total production capacity globally.
• Companies that have created supply chains purportedly free of XUAR inputs continue to source from suppliers or sub-suppliers that have exposure to the Uyghur Region for other product lines.
• It is sometimes impossible to determine if it is indeed the case that these dedicated product lines are XUAR-input-free because com panies do not disclose sufficient supply chain information.
• Despite significant global pressure for increased transparency, information regarding solar industry sourcing is becoming less transparent over time, thwarting the world’s ability to source ethically.

Our assessments indicate the extent to which a company or module is exposed to the Uyghur Region. By exposure, we mean the heightened risk that a supply chain includes within it a Uyghur Region input, based on available sourcing disclosures..."